2025 AGENCY ETHICS PROGRAM QUESTIONNAIRE

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PART 1. INTRODUCTION

Executive branch agencies are required to submit an annual report to the United States Office of Government Ethics (OGE) concerning certain aspects of their ethics programs (5 U.S.C. § 13122(e)(1)). Your response to OGE’s Annual Ethics Program Questionnaire (the questionnaire) serves as your annual report.

OGE uses the data collected through the questionnaire in many ways, including sharing information about the entire executive branch ethics program with the public, Congress, and the ethics community. OGE also uses the information to carry out its oversight role, to gain knowledge about individual agency programs as well as the overall executive branch ethics program, and to make informed decisions about resource allocation and priorities. OGE posts a summary of questionnaire responses and each agency’s unedited responses on OGE’s website. Therefore, please ensure your responses are suitable for publication.

OGE encourages each agency to use the annual exercise of completing the questionnaire as an opportunity to evaluate your ethics program.

DUE DATE: By regulation, the questionnaire is due to OGE by February 2, 2026. (5 C.F.R. § 2638.207(a)).

PART 2. INSTRUCTIONS

Your response to this questionnaire should reflect the 2025 calendar year (i.e., 1/1/2025 through 12/31/2025), except where specified. The answers provided should reflect the aggregate data for your agency. OGE will only accept one submission per agency.

Throughout the questionnaire you will be offered an opportunity to provide comments or explanations for your responses. Please use these comment sections to explain any discrepancies between levels of required activity and actual activity and to explain significant changes from your 2024 report. To safeguard privacy, please avoid the use of Personally Identifiable Information (PII) in your responses. After OGE has reviewed your questionnaire submission, you may be contacted for follow-up.

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PART 3. DEFINITIONS

Agency Head: For purposes of this questionnaire, the term "agency head" means the head of an agency. In the case of a department, it means the Secretary of the department. In the case of a board or commission, it means the Chair of the board or commission.

D.C Metro Area: For purposes of this questionnaire, D.C. Metro Area means the District of Columbia, D.C.; Calvert County, MD; Charles County, MD; Prince George's County, MD; Arlington County, VA; Clarke County, VA; Culpeper County, VA; Fairfax County, VA; Fauquier County, VA; Loudoun County, VA; Prince William County, VA; Rappahannock County, VA; Spotsylvania County, VA; Stafford County, VA; Warren County, VA; Alexandria City, VA; Fairfax City, VA; Falls Church City, VA; Fredericksburg City, VA; Manassas City, VA; Manassas Park City, VA; Jefferson County, WV; and, Silver Spring-Frederick-Rockville, MD Metropolitan Division Frederick County, and Montgomery County.

Agency Employees: For purposes of this questionnaire, the term “agency employees” means any officer or employee of an agency, including a special Government employee. It includes officers but not enlisted members of the uniformed services.

Special Government Employee (SGE): For purposes of this questionnaire, the term “special Government employee” (SGE) means an officer or employee who is retained, designated, appointed, or employed, to perform temporary duties either on a full-time or intermittent basis, with or without compensation, for not more than 130 days during any period of 365 consecutive days. The term “SGE” does not include enlisted members, of the Armed Forces. It does, however, include these categories of officers or employees:
  • Part-time United States commissioners;
  • Reserve officers of the Armed Forces and officers of the National Guard of the United States (unless otherwise officers or employees of the United States) while on active duty solely for training or serving involuntarily.

PART 4. ORGANIZATION/RESOURCES

1. Agency

  • Department of Education

2. Employees

  • Number of full-time agency employees as of December 31, 2025
2317

3. Information about the Designated Agency Ethics Official (DAEO):

a. Vacant (as of December 31, 2025)?
No

b. Time in current DAEO position
Less than 1 year

c. Total years performing ethics duties
Less than 1 year

d. Percent of time spent on ethics
51-75%

e. Is the DAEO a career employee or a political appointee?
Political employee

f. Number of reporting levels between the DAEO and the agency head.
2

4. Information about the Alternate Designated Agency Ethics Official (ADAEO):

a. Vacant (as of December 31, 2025)?
No

b. Time in current ADAEO position
Less than 1 year

c. Total years performing ethics duties
Less than 1 year

d. Percent of time spent on ethics
76-100%

e. Is the ADAEO a career employee or a political appointee?
Career employee

5. Report the number of employees, including the DAEO and ADAEO, who performed ethics program duties in 2025 (e.g., financial disclosure, education and training, advice and counseling, and program administration).

Number of employees by hours worked each week
Duty Station
Less than 1 hour per week
(up to .025 FTE*)
1-10 hours per week
(up to .25 FTE*)
11-20 hours per week
(up to .5 FTE*)
21-30 hours per week
(up to .75 FTE*)
31-40 hours per week
(up to 1 FTE*)
TOTAL
a. D.C. Metro area
0
2
0
1
1
4
b. Outside the D.C. Metro area
0
2
0
0
0
2
TOTAL
0
4
0
1
1
6

* FTE = Full Time Equivalent

Example: The table below provides an example of an agency with 13 employees that performed ethics
program duties in 2025.

EXAMPLE
Number of employees by hours worked each week
Duty Station
Less than 1 hour per week
(up to .025 FTE*)
1-10 hours per week
(up to .25 FTE*)
11-20 hours per week
(up to .5 FTE*)
21-30 hours per week
(up to .75 FTE*)
31-40 hours per week
(up to 1 FTE*)
TOTAL
D.C. Metro area
1
0
2
2
1
6
Outside the D.C. Metro area
1
3
3
0
0
7
TOTAL
2
3
5
2
1
13

6. In what areas did contractors support the ethics program? Select all that apply.

  • Check all that apply

IT services (e.g., developing or supporting electronic filing systems, applications, websites, and/or databases, etc.)


  • Describe the IT support (optional):
    IT services (e.g., developing or supporting electronic filing systems, applications, websites, and/or databases, etc.)

  • Describe the administrative support (optional):

  • Describe the substantive support (optional):

  • Describe the other support:

7. Did your agency receive ethics services or support from another federal agency or federal entity? (Do not include contractors, OGE support, or OMB support of MAX.gov.)

  • Select Yes or No
Yes

  • Provide the name(s) of the federal agency or entity:
    General Services Administration, Health and Human Services

  • Describe the services or support received:
    Reviewing 278 nominee reports, providing initial ethics briefing for appointees, providing initial ethics training for new employees and SGEs serving on boards and committees, training for ethics staff on all areas of running the ethics program and use of Integrity, reviewing 278 reports, reviewing some 450 reports, evaluating conflicts for current and former employees

8. Did your agency provide ethics program services or support for any board, commission, or agency that is independant of your agency?

  • Select Yes or No
Yes

  • Provide the name(s) of the board, commission, or agency:
    National Assessment Governing Board (NAGB) and National Council on Disabilities (NCD)

  • Describe the services or support provided:
    Advice, counseling, ethics training and financial disclosure review and certifications.

9. Does your agency's ethics program need additional resources? Select all that apply.

  • Select type of resources

    Human Capital, Technology

  • Describe the other resources:

10. Did the agency head meet with the ethics staff to discuss the strengths and weaknesses of the ethics program in 2025?

  • Select Yes, No, or Not Applicable
No

  • Explain why not applicable:

11. Did your agency (e.g., ethics office, Inspector General, General Counsel, etc.) or any entity outside of your agency (e.g., GAO or private auditing firm) evaluate any aspect of the ethics program in 2025 (5 C.F.R. § 2638.104(c)(16))? Exclude program reviews conducted by OGE. Select all that apply.


    An entity outside of my agency, other than OGE, (e.g., GAO or a private auditing firm) conducted an evaluation

12. What kind of changes resulted from the evaluation?




    Evaluation has not been completed

  • Describe the programmatic; the policy changes; why no changes resulted; or why not applicable:

13. Of the following required written procedures, which did you have in place?
Select all that apply.

Financial disclosure program, including for the filing, review, and when applicable, public availability of public financial disclosure reports (5 C.F.R. § 2638.104(c)(8)(i)), Issuance of notice of ethical obligations in written offers of employment (5 C.F.R. § 2638.303), Provision of initial ethics training (5 C.F.R. § 2638.304), Issuance of ethics notice to new supervisors (5 C.F.R. § 2638.306)

  • Explain what steps you are taking to implement the required written procedures:

ADDITIONAL COMMENTS FOR PART 4. Indicate the question number to which the comment corresponds.

  • Additional Comments
    Due to agency reorganization, the entire OGC Ethics Division was placed on administrative leave pending RIF on March 11, 2025. For the rest of 2025, the new ethics team attempted to triage ethics compliance, but all aspects of the ethics program experienced backlogs and delays.

PART 5. EDUCATION AND TRAINING

14. Did the office(s) responsible for issuing ethics notices to prospective employees pursuant to 5 C.F.R. § 2638.303, provide the DAEO with the written confirmation required pursuant to 5 C.F.R. § 2638.310?

    All of the offices provided the written confirmation to the DAEO (skip to #16)

  • Explain why not all offices (then skip to #16):

15. Did written offers of employment for positions covered by the Standards of Conduct include the information required by 5 C.F.R. § 2638.303?

  • Explain why not all offers:

  • Explain why not applicable:

16. Initial Ethics Briefing

a. How many agency leaders, as defined in 5 C.F.R. 2638.305(a), were required to receive ethics briefings by December 31, 2025? Exclude SGEs that were expected to serve less than 60 days on a board, commission, or committee.
Total Number
6
    i. How many new agency leaders received their briefing within 15 days of their appointment?
1
    ii. How many of those leaders received their briefing beyond the 15-day requirement?
5
    iii. How many new agency leaders have yet to receive their briefing as of today?
0

    If applicable, explain why some of the leaders received their briefing beyond the 15-day requirement or have yet to receive their briefing.
    Secretary’s briefing was held late because of agency restructuring immediately after the Secretary entered into her position. Other appointees received briefings late because ethics personnel were furloughed while the new appointees were entering into service.

17. Initial Ethics Training

a. How many employees, as defined in 5 C.F.R. 2638.304(a), were required to receive Initial Ethics Training (IET) by December 31, 2025 (5 C.F.R. 2638.304)? Exclude SGEs that were expected to serve less than 60 days on a board, commission, or committee. (Note: Include employees who were not required to receive the interactive portion of the IET, as provided in 5 C.F.R. 2638.304(a)(2).)
Total Number
182
    i. How many of those employees received IET within the 3-month requirement?
162
    ii. How many of those employees received IET beyond the 3-month requirement?
11
    iii. How many of those employee have not received IET as of today?
9

Example: If an employee started at the agency on December 15, 2025, and the employee completed IET prior to the end of the calendar year, include the employee in your required and received numbers. If, on January 1, 2026, the employee has not completed IET, do not count that employee in your required numbers. Instead, include the employee in your 2026 questionnaire response to be filed in 2027.

  • If applicable, explain why some employees received IET beyond the 3-month requirement or have yet to receive IET.
    Agency reorganization after March 11, 2025, caused significant disruption to the training program. We presume employees onboarded before March 11, 2025, received initial ethics training during HR orientations, per the prior ethics team's usual practice. Following agency reorganization, we have endeavored to ascertain who was onboarded and provide timely training. Some consultant and non-filing appointments evaded the ethics team's notice. Some employees failed to respond to requests to attend scheduled training events. By late 2025, the ethics team had resumed providing training HR orientations to minimize future missed trainings.

18. Did the office(s) delegated the responsibility for providing initial ethics training (IET) provide the required written confirmation to the DAEO, pursuant to 5 C.F.R. § 2638.310?

    Written confirmation not required because all IET was provided by an office under the DAEO's supervision

  • Please Explain why not all offices:

19. Did the head of the agency complete either initial ethics training and/or annual ethics training in 2025?

  • Select One
Yes

  • Explain why not or why not applicable

20. Required Annual Ethics Training

Type of covered employees (Include SGE filers)
# Required
# Received (of those required)

    a. Executive Schedule Level I or Level II public filers (OGE Form 278e)
0
0

    b. All other public filers (OGE Form 278e)
62
49

    c. Confidential filers (OGE Form 450 and OGE-approved alternative confidential financial disclosure forms)
579
465

    d. Other employees required by 5 C.F.R. § 2638.307(a) (employees appointed by the President; employees of the Executive Office of the President; contracting officers; or, other employees designated by the head of the agency.)
0
0

TOTAL
641
514

  • If applicable, explain discrepancies between the number of employees who were required to receive training and the number of employees who received training:
    Annual training was provided via a FedTalent module. Some employees failed to complete the training despite repeated reminders. We believe these numbers are accurate, but some additional required employees may have completed annual training requirements prior to the March 11, 2025, agency reorganization. No information about such training is available to the current ethics team.

21. Did your agency establish additional requirements for the agency's ethics education program, pursuant to 5 C.F.R. § 2638.309?


    No, my agency did not establish additional training requirements

  • Describe the additional training requirements / procedures:

22. If your agency assessed risk to help inform the content, format, and/or timing of ethics education and communications, select all that apply (see PA-19-05 for reference):


Discussed upcoming work and agency priorities with senior staff

  • Describe:

23. If your agency evaluated the effectiveness of your ethics education and/or communication, select all that apply (see PA-19-05 for reference):


Conducted self-assessments to ensure that required employees are receiving training

  • Describe:

ADDITIONAL COMMENTS FOR PART 5. Indicate the question number to which the comment corresponds.

  • Additional Comments
    The new ethics team collaborated with the HHS Ethics Training Division to get new employees IET on an emergency basis in the first half of 2025. The HHS staff then trained ED staff on how to provide the required training going forward. ED staff ultimately took over live trainings, evaluated by HHS for the sufficiency of the presentation, before conducting trainings on their own through the latter half of 2025. For question 20, the current ethics team is unaware of any employees who required annual training but are not financial disclosure filers. The previous ethics team indicated the Department had 18 such employees in 2024. On question 22, the ethics staff evaluated our risk during agency realignment to ensure concurrent and post-government employment advice was provided timely to retired and RIF’d employees. The ethics team discussed our upcoming priorities, including OGE program review, with the Acting General Counsel and commenced a hiring process to add ethics staff capacity.

PART 6. ADVICE, COUNSELING, AND REMEDIES

24. From the list below, select the three topics that your employees most frequently sought guidance on in 2025. Rank them in order, so that the first topic is the topic on which the employees sought guidance the most frequently.

  • Conflicting financial interests
  • Gift acceptance
  • Financial disclosure reporting
  • Impartiality in performance of official duties
  • Misuse of position, government resources, and information
  • Outside employment/activities
  • Post-employment restrictions
  • Travel, subsistence, and related expenses from non-federal sources
  • Other (specify)

  • Selection 1
Post-employment restrictions
  • Selection 2
Outside employment/activities
  • Selection 3
Financial Disclosure Reporting

  • Explain Other 1
  • Explain Other 2
  • Explain Other 3

25. Number of notification statements of negotiation or recusal under section 17(a) of the STOCK Act submitted to the ethics office in 2025 (pursuant to 5 C.F.R. § 2635.602(a):

  • Enter total
28

26. Number of 18 U.S.C. § 208 waivers granted in 2025:

Number Granted in 2025
Number Sent to OGE
    a. 208(b)(1) waivers
5
5
    b. 208(b)(3) waivers
0
0

  • If applicable, explain discrepancies between the number of waivers granted and the number provided to OGE.

27. Number of Legal Expense Fund documents filed in 2025 (pursuant to 5 C.F.R. § 2635.1007):

Number Filed in 2025
Number Sent to OGE
    a. Trust Documents
0
0
    b. Quarterly Reports
0
0
    c. Termination Report
0
0

  • If applicable, explain discrepancies between the number of documents filed and the number provided to OGE.

ADDITIONAL COMMENTS FOR PART 6. Indicate the question number to which the comment corresponds.

  • Additional Comments

PART 7. FINANCIAL DISCLOSURE PROGRAM MANAGEMENT AND ELECTRONIC FILING SYSTEMS

28. How often, within the 15-day deadline, did the human resources office(s) notify the DAEO of appointments to public and confidential financial disclosure filing positions (5 C.F.R. § 2638.105(a)(1))?

    a. Public Filers
In Most Cases

    • If not applicable, specify why:

    • If "never" or "in some cases", explain:

    b. Confidential Filers
In Most Cases

    • If not applicable, specify why:

    • If "never" or "in some cases", explain:

29. How often, within the 15-day deadline, did the human resources office(s) notify the DAEO of terminations from public financial disclosure filing positions (5 C.F.R. § 2638.105(a)(2))?

Public FilersIn Most Cases

    • If not applicable, specify why:

    • If "never" or "in some cases", explain:

30. Were all public and confidential financial reports, in calendar year 2025, filed using an electronic filing system?

  • Select one
No

31. Indicate which forms your agency uses. Select all that apply.

  • Select all that apply
450 (pdf)

32. Which electronic filing system(s) does your agency use?

  • Select one
INTEGRITY and Other

33. Indicate for which forms your agency uses the "Other" e-filing system.

  • Select all that apply
Confidential Financial Disclosure (OGE Form 450 or OGE-approved alternative form)

  • Provide the name of the other system:
    FDOnline

34. Indicate your agency's fiscal year 2025 actual costs for using the e-filing system. Note: Because OGE does not charge fees to use INTEGRITY, there are no reportable costs associated with the use of INTEGRITY.

Public (do not include INTEGRITY)Confidential
a. Amount paid to a non-federal vendor in fiscal year 2025
0
64260

b. Amount paid to a federal agency in fiscal year 2025
0
0

c. Amount for all internal costs associated with operating an e-filing system (e.g., FTE, overhead, etc.) in fiscal year 2025
0
0

  • Please explain "Don’t know/don’t track" answer above

35. Indicate the number of filers who filed electronically in fiscal year 2025. Number of financial disclosure filers, not reports, who filed electronically in fiscal year 2025.

    a. public financial disclosure filers (exclude filers in INTEGRITY)
0

    b. confidential financial disclosure filers
680

ADDITIONAL COMMENTS FOR PART 7. Indicate the question number to which the comment corresponds.

  • Additional Comments


PART 8. PUBLIC FINANCIAL DISCLOSURE

36. Report the number of public financial disclosure reports (OGE Form 278e) required to be filed by December 31, 2025, excluding SGEs, and the number of reports actually filed (i.e., received) by December 31, 2025.

OGE Form 278e Reports
PAS2
Non-Career SES3
Career SES3
Schedule C
Other4
TOTAL
a. New EntrantRequired
0
27
1
71
27
126
Filed
0
26
1
64
24
115
b. AnnualRequired
0
0
61
0
32
93
Filed
0
0
56
0
20
76
c. TerminationRequired
11
18
7
100
4
140
Filed
11
18
7
98
4
138
d. Combination1Required
0
0
0
0
0
0
Filed
0
0
0
0
0
0
    Total
Required
11
45
69
171
63
359
Filed
11
44
64
162
48
329

1 Includes reports filed to satisfy both annual and termination requirements, as well as new entrant and termination requirements.
2 Presidential appointees confirmed by the Senate.
3 Senior Executive Service, Senior Foreign Service, Senior Cryptologic Service, Defense Intelligence Senior Executive Service, etc.
4 Includes members of the Uniformed Services, Administrative Law Judges, Senior Level employees (SES Equivalent), administratively-determined positions, officials in the Executive Office of the President who do not otherwise meet the criteria of another category in the chart, etc.


Example for new entrant and termination reports: If an employee joined (or departed) the agency on December 15, 2025, and the employee filed a new entrant (or termination) report prior to the end of the calendar year, include the report in your required and filed numbers. If, on January 1, 2026, the employee has not filed a new entrant (or termination) report, do not count that report in your required numbers. Instead, include the report in your 2026 questionnaire response to be filed in 2027.

  • If applicable, explain discrepancies between the number of reports required to be filed and the actual number of reports filed.
    Due to agency reorganization, the entire OGC Ethics Division was placed on administrative leave pending RIF on March 11, 2025. For the rest of 2025, the new ethics team attempted to triage ethics compliance, but all aspects of the ethics program experienced backlogs and delays. The shutdown also exacerbated these backlogs.

37. Report the number of public financial disclosure reports certified or otherwise closed by your agency during the calendar year. Exclude reports of SGEs. Of those reports, indicate how many were initially reviewed within 60 days and how many were certified within 60 days. “Initially reviewed within 60 days” means having completed a technical review and conflicts analysis. See 5 C.F.R. § 2634.605 and section 4.02 of the Public Financial Disclosure Guide.

OGE Form 278e Reports
PAS2
Non-Career SES3
Career SES3
Schedule C
Other4
TOTAL
a. New Entranti. How many reports did your agency certify or close in 2025?
0
0
13
30
2
45
ii. Of those certified or closed in 2025, how many were initially reviewed within 60 days?
0
0
8
26
0
34
iii. Of those certified or closed in 2025, how many were certified or closed within 60 days?
0
0
1
7
0
8
b. Annual
PAS2
Non-Career SES3
Career SES3
Schedule C
Other4
TOTAL
i. How many reports did your agency certify or close in 2025?
0
0
0
0
2
2
ii. Of those certified or closed in 2025, how many were initially reviewed within 60 days?
0
0
0
0
1
1
iii. Of those certified or closed in 2025, how many were certified or closed within 60 days?
0
0
0
0
1
1
c. Termination
PAS2
Non-Career SES3
Career SES3
Schedule C
Other4
TOTAL
i. How many reports did your agency certify or close in 2025?
0
8
17
85
3
113
ii. Of those certified or closed in 2025, how many were initially reviewed within 60 days?
0
6
17
85
3
111
iii. Of those certified or closed in 2025, how many were certified or closed within 60 days?
0
6
17
84
3
110
d. Combination
PAS2
Non-Career SES3
Career SES3
Schedule C
Other4
TOTAL
i. How many reports did your agency certify or close in 2025?
0
0
0
0
0
0
ii. Of those certified or closed in 2025, how many were initially reviewed within 60 days?
0
0
0
0
0
0
iii. Of those certified or closed in 2025, how many were certified or closed within 60 days?
0
0
0
0
0
0
    Total
i. How many reports did your agency certify or close in 2025?
0
8
30
115
7
160
ii. Of those certified or closed in 2025, how many were initially reviewed within 60 days?
0
6
25
111
4
146
iii. Of those certified or closed in 2025, how many were certified or closed within 60 days?
0
6
18
91
4
119

1 Includes reports filed to satisfy both annual and termination requirements, as well as new entrant and termination requirements.
2 Presidential appointees confirmed by the Senate.
3 Senior Executive Service, Senior Foreign Service, Senior Cryptologic Service, Defense Intelligence Senior Executive Service, etc.
4 Includes members of the Uniformed Services, Administrative Law Judges, Senior Level employees (SES Equivalent), administratively-determined positions, officials in the Executive Office of the President who do not otherwise meet the criteria of another category in the chart, etc.

  • If applicable, explain why some reports were reviewed more than 60 days after submission.
    Agency reorganization and government shutdown significantly impacted timeliness of ethics team in reviewing financial disclosure reports.

  • If applicable, explain why some reports were certified or closed more than 60 days after submission. Select all that apply.
    Additional information was being sought
    Other

  • Describe:
    Agency reorganization and government shutdown significantly impacted timeliness of ethics team in reviewing financial disclosure reports.

38. Number of periodic transaction reports filed, excluding those filed by SGEs

    • Periodic Transaction Reports Filed
96
Note: Count the total number of periodic transaction reports filed. Example 1: If two employees each file 5 periodic transaction reports during the calendar year, report “10” in the space above. Example 2: If an employee files one report each month, each report is counted separately. Report “12”.

39. Report the number of extensions and late fees for new entrant, annual, termination, and combination public financial disclosure reports, and periodic transaction reports, excluding those for reports filed by SGEs.

GRANTED FILING EXTENSION
GRANTED WAIVER OF LATE FILING FEE
PAID LATE FILING FEE
    a. Number of OGE Form 278e Reports
95
1
0
    b. Number of OGE Form 278-T Reports
1
1
0

40. Number of public financial disclosure filers reported in calendar year 2025 to the Attorney General for failure to file:

  • Enter total
0

41. Number of requests for public financial disclosure reports received in 2025: Count each OGE Form 201 as one request, even if it contains a request for documents for multiple individuals.

  • Enter total
15

42. Number of documents requested under the Ethics in Government Act released in calendar year 2025:

  • Enter total
86

ADDITIONAL COMMENTS FOR PART 8. Indicate the question number to which the comment corresponds.

  • Additional Comments
    Due to agency reorganization, the entire OGC Ethics Division was placed on administrative leave pending RIF on March 11, 2025. For the rest of 2025, the new ethics team attempted to triage ethics compliance, but all aspects of the ethics program experienced backlogs and delays.

PART 9. CONFIDENTIAL FINANCIAL DISCLOSURE

43. Report the number of confidential financial disclosure reports required to be filed by December 31, 2025, excluding SGEs, and the number of reports actually filed by December 31, 2025.

a. Required
b. Filed
680
OGE Form 450
680
OGE-approved alternate form
0
Total
680
680

    Note: If a 450 filer leaves the filing position before the due date, the report is not required per 5 C.F.R.§ 2634.903(a).

    Example for new entrant reports: If an employee started at the agency on December 15, 2025, and filed a new entrant report prior to the end of the calendar year, include the report in your required and filed numbers. If, on January 1, 2026 the employee has not filed a new entrant report, do not count that report in your required numbers. Instead, include the report in your 2026 questionnaire response to be filed in 2027.

    If applicable, explain discrepancies between the number of reports required to be filed and the actual number of reports filed.

44. Report the number of confidential financial disclosure reports certified or otherwise closed by your agency during the calendar year. Exclude reports of SGEs. Of those reports, indicate how many were initially reviewed within 60 days and how many were certified within 60 days. "Initially Reviewed within 60 days" means having completed a technical review and conflicts analysis. See 5 C.F.R. § 2634.605 and the Certification Requirements section of the Confidential Financial Disclosure Guide.

a. How many reports did your agency certify or close in 2025?
b. Of those certified or closed in 2025, how many were initially reviewed within 60 days?
c. Of those certified or closed in 2025, how many were certified or closed within 60 days?
OGE Form 450 and OGE-approved alternative
482
482
482

  • If applicable, explain why some reports were reviewed more than 60 days after submission:

  • If applicable, explain why some reports were certified or closed more than 60 days after submission. Select all that apply.

  • Describe:

45. Number of OGE 450 or OGE-approved alternative forms granted filing extensions in 2025.

  • Enter number
0

ADDITIONAL COMMENTS FOR PART 9. Indicate the question number to which the comment corresponds.

  • Additional Comments
    Due to agency reorganization, the entire OGC Ethics Division was placed on administrative leave pending RIF on March 11, 2025. For the rest of 2025, the new ethics team attempted to triage ethics compliance, but all aspects of the ethics program experienced backlogs and delays.

PART 10. ENFORCEMENT OF STANDARDS OF CONDUCT AND CRIMINAL AND CIVIL STATUTES

46. Report the number of disciplinary actions taken in 2025 based wholly or in part upon violations of the Standards of Conduct provisions (5 C.F.R. part 2635) or your agency's supplemental Standards (if applicable). For purposes of this question, disciplinary actions include removals, demotions, suspensions, and written reprimands or their equivalents.

a. Total number of disciplinary actions that met the above criteria
0

    Of those, how many were disciplinary actions were taken wholly or in part upon violations of:

    i. Subpart A (General Provisions)

    ii. Subpart B (Gifts from Outside Sources)

    iii. Subpart C (Gifts between Employees)

    iv. Subpart D (Conflicting Financial Interests)

    v. Subpart E (Impartiality in Performing Official Duties)

    vi. Subpart F (Seeking Other Employment)

    vii. Subpart G (Misuse of Position)

    viii. Subpart H (Outside Activities)

    ix. Subpart J (Legal Expense Funds)

    x. Agency's supplemental Standards of Conduct

47. Report the number of disciplinary actions taken in 2025 based wholly or in part upon violations of the criminal conflict of interest statutes (18 U.S.C. §§ 203, 205, 208, and 209), failure to file or filing false public financial disclosures (5 U.S.C. § 13106 or 18 U.S.C. § 1001), a civil matter involving outside earned income (5 U.S.C. § 13143), or outside activities (5 U.S.C. § 13144). For purposes of this question, disciplinary actions include removals, demotions, suspensions, and written reprimands or their equivalents.

a. Disciplinary actions taken based on violation of ethics laws
0

    Of those, how many were disciplinary actions taken based wholly or in part upon violations of:

    i. 18 U.S.C. § 203 (Compensation in Matters Affecting the Government)

    ii. 18 U.S.C. § 205 (Claims Against and Matters Affecting the Government)

    iii. 18 U.S.C. § 208 (Acts Affecting a Personal Financial Interest)

    iv. 18 U.S.C. § 209 (Supplementation of Salary)

    v. 5 U.S.C. § 13106 (Failure to File)

    vi. 18 U.S.C. § 1001 (Filing False Public Financial Disclosures)

    vii. 5 U.S.C. § 13143 (Outside Earned Income)

    viii. 5 U.S.C. § 13144 (Outside Activities)

48. Report the number of referrals made in 2025 to the Department of Justice (DOJ) of potential violations of the conflict of interest statutes (18 U.S.C. §§ 203,205, 207, 208, 209), failure to file or filing false public financial disclosures (5 U.S.C. § 13106 or 18 U.S.C. § 1001), a civil matter involving outside earned income (5 U.S.C. § 13143), or outside activities (5 U.S.C. § 13144).

a. Referrals to Department of Justice
1

b. DOJ Referrals Status
Of the referrals to DOJ (line a.), provide the status of each referral:

    i. How many of those referrals were accepted for prosecution?
0

    ii. How many of those referrals were declined for prosecution?
1

    iii. How many of those referrals were pending DOJ’s decision as of December 31, 2025?
0

c. Agency Disciplinary Action Status
Of the referrals to DOJ (line a.), provide the status of any associated agency disciplinary action:

    i. Of the cases referred to DOJ, how many resulted in disciplinary or corrective action?
0

    ii. Of the cases referred to DOJ, how many resulted in a determination not to take disciplinary or corrective action?
0

    iii. Of the cases referred to DOJ, how many are pending a determination as to whether disciplinary or corrective action will be taken?
1

    iv. Of the cases referred to DOJ, how many of those referrals involved employees who left the agency before the agency determined whether or not to take disciplinary action?
0

    v. Of the cases referred to DOJ, how many involved 18 U.S.C. 207, such that there was no option for disciplinary action?
0

49. Did your agency notify OGE of all referral(s) and disposition(s) of the referral(s) via OGE Form 202 pursuant to 5 C.F.R. § 2638.206(a)?

  • Select answer
Yes

  • Explain why not:

ADDITIONAL COMMENTS FOR PART 10. Indicate the question number to which the comment corresponds.

  • Additional Comments

PART 11. SPECIAL GOVERNMENT EMPLOYEES (SGEs)

50. How many special Government employees (SGEs) did your agency have, in total, during calendar year 2025? (If zero, skip to Additional Comments for this Part.)

  • Enter number
88

51. Initial Ethics Training

a. How many SGEs who were expected to serve for 60 days or less on a board, commission, or committee were required to receive Initial Ethics Training (IET) by December 31, 2025 (5 C.F.R. § 2638.304(b)(2))?

Total number
84

    i. How many of those SGEs received IET before or at the beginning of the first meeting?
48

    ii. How many of those SGEs received IET after the first meeting?
0

    iii. How many of those SGEs have not received IET as of today?
36

    If applicable, explain why some SGEs received IET after the first meeting or have yet to receive IET:
      Some SGEs served on a Board that apparently did not perform any work in 2025. Other SGEs were not identified by the new ethics team as receiving ethics support from the Department until the end of 2025 or early 2026. A solution for ensuring compliance for boards and committees was implemented in August 2025 but was disrupted due to staff departures at the end of September and further disrupted by the furlough until mid-November.

52. Report the number of SGE public and confidential financial disclosure reports required to be filed by December 31, 2025 and the number of reports actually filed by December 31, 2025.

Confidential Reports
(OGE Form 450 or OGE- Approved Alternative Form)
Public Reports
(OGE Form 278e)
required
filed
required
filed
a. Advisory Committee Members (FACA)
30
17
0
0
b. Advisory Committee Members (non-FACA)
54
24
0
0
c. Experts/Consultants
4
2
1
0
d. Board Members
0
0
0
0
e. Commissioners
0
0
0
0
f. Other
0
0
0
0
TOTAL
88
43
1
0

    Example for new entrant and termination reports: If an employee joined (or departed) the agency on December 15, 2025, and filed a new entrant (or termination) report prior to the end of the calendar year, include the report in your required and filed numbers. If, on January 1, the employee has not filed a new entrant (or termination) report, do not count that report in your required numbers. Instead, include the report in your 2026 questionnaire response to be filed in 2027.

  • If applicable, explain discrepancies between the number of reports required to be filed and the actual number of reports filed:
    A solution for ensuring compliance for boards and committees was implemented in August 2025 but was disrupted due to staff departures at the end of September and further disrupted by the furlough until mid-November.

53. Report the number of SGE disclosure reports certified or otherwise closed by your agency during the calendar year. Of those reports, indicate how many were initially reviewed within 60 days and how many were certified within 60 days. “Initially reviewed within 60 days” means having completed a technical review and conflicts analysis. See 5 C.F.R. 2634.605, section 4.02 of the Public Financial Disclosure Guide, and the Certification Requirements section of the Confidential Financial Disclosure Guide.

Confidential Reports
Public Reports
a. How many reports did your agency certify or close in 2025?
3
0
b. Of those certified or closed in 2025, how many were initially reviewed within 60 days?
3
0
c. Of those certified or closed in 2025, how many were certified or closed within 60 days?
3
0

  • If applicable, explain why some reports were reviewed more than 60 days after submission.

  • If applicable, explain why some reports were certified or closed more than 60 days after submission. Select all that apply.

  • Describe:

54. Number of SGEs excluded from all or a portion of the confidential filing requirements per 5 CFR § 2634.904(b).

  • Enter number
0

55. Number of extensions and late filing fees for SGE financial disclosure reports:

Granted filing extension
Granted waivers of late filing fee
Paid late filing fee
      a. Number of OGE Form 278e Reports
1
0
0

      b. Number of OGE Form 450 Reports or OGE-Approved Alternative Forms
0

ADDITIONAL COMMENTS FOR PART 11. Indicate the question number to which the comment corresponds.

  • Additional Comments
    Due to agency reorganization, the entire OGC Ethics Division was placed on administrative leave pending RIF on March 11, 2025. For the rest of 2025, the new ethics team attempted to triage ethics compliance, but all aspects of the ethics program experienced backlogs and delays. Priority was given to getting boards into compliance prior to meetings at the end of 2025. It is possible additional board and committee members completed their required training in 2025 before the March 11, 2025, agency reorganization. We do not have access to records or staff that could verify such activities. It is likely additional 450s were submitted by board and committee members and were certified by the former ethics team. We have not had time to inventory all records previously kept in paper and PDF instead of the FDOnline system. We also have not had access to the email and personal electronic storage used by the former ethics team.

ADDITIONAL QUESTIONNAIRE COMMENTS:

  • Additional Comments

Point of contact to answer OGE follow up questions regarding this questionnaire:

  • Name:
Charles Yordy

  • Title/Position:
ADAEO

  • Email Address:
Charles.Yordy@ed.gov

  • Confirm Email Address:
Charles.Yordy@ed.gov

  • Phone Number:
202-245-6823

What is the preferred mailing address for the Agency Head, Designated Agency Ethics Official, Chief Human Capital Officer, and Inspector General:

Agency Head

  • Street
    400 Maryland Ave. S.W.
  • City
    Washington
  • State
    DC District of Columbia
  • Zip
    20202

DAEO

    **Address is the same as above**
  • Street
  • City
  • State
  • Zip

Chief Human Capital Officer

    **Address is the same as above**
  • Street
  • City
  • State
  • Zip

Inspector General


    **Address is the same as above**
  • Street
  • City
  • State
  • Zip

      OGE Form 450A
0
hidden element

By POC
Submitted by POC (See above)

Date
02/04/2026