- Greatest challenges
Among the most daunting challenges facing USDA’s Ethics Program in the short term are issues related to the 2016 Presidential Election season and the Presidential Transition in 2016-2017. USDA’s Ethics Program is very small -- with 20 FTE employees in December, 2015 (a 45% reduction in staffing, compared to the 36 FTE employees USDA's Ethics Program had during the 2009 Presidential Transition). To better illustrate the diminutive size of USDA’s Ethics Program, USDA has only one Ethics Specialist for every 5,200 employees. With its resources so thinly stretched, USDA’s Ethics Program will need to successfully manage three simultaneous, challenges: (1) Providing extensive ethics advice, training and timely financial disclosure reviews for all incoming appointees in the new Administration (2) Providing extensive ethics post-Federal employment advice and training to all departing appointees and retiring career employees and (3) Responding to the heightened demand for timely and extensive Hatch Act guidance and training for all USDA employees to ensure compliance with the rules limiting political activities for Federal employees during the 2016 Presidential, and 2016 and 2018 Congressional, State and local election seasons. With regard to providing ethics services for incoming appointees in a new Administration, OE will need to successfully conduct hundreds of new complex and time-sensitive Public Financial Disclosure Report (OGE-278e) reviews. USDA will be implementing OGE’s Integrity system for all new entering appointees and career- SES and will need to provide extensive training and assistance to new OGE-278e filers. OE will also need to prepare necessary recusal documents, Ethics Agreements and -- for Senate-Confirmed Presidential Nominees (PAS) -- OE will need to conduct the necessary time-sensitive coordination with potential nominees, White House Counsel's Office, and the U.S. Office of Government Ethics, as well as ensuring timely 90-day follow up compliance reporting to OGE for all of USDA’s incoming Senate-Confirmed Presidential Appointees. At the same time that USDA’s Ethics Office will be working diligently on time-sensitive ethics issues related PAS nominations processing, the Office of Ethics will also be conducting ethics reviews for all incoming senior policy-making officials and other political appointees to USDA, including nearly 100 incoming senior policy-making political appointees serving in senior level positions (as FSA State Executive Directors and RD State Directors) within the 50 States. USDA is unique in that this Department has two senior political appointees in virtually every one of the 50 States, and these senior appointees all have backgrounds in farming and agriculture which necessitates extensive conflict avoidance vetting protocols. Simultaneously, the Office of Ethics' workload will increase dramatically with the need to provide ethics training and time-sensitive job search ethics counseling and post-employment ethics counseling to USDA’s departing political appointees in Washington, DC and across the country, as well as retiring career-SES executives, GS-15 and GS-14 managers, procurement officials, IT technology systems experts, loan officers, grant-making officials, risk management insurance reviewers, appraisers, food safety inspectors, nutritionists, forest rangers, conservationists, researchers, scientists, veterinarians, and economists. During the 2016 Presidential and the 2016 and 2018 Congressional elections cycles, the Office of Ethics will be heavily tasked to provide timely Hatch Act advice and training for all USDA employees to minimize risks of political activity violations. As noted above, the Office of Ethics will be taxed to successfully navigate all three of these challenges because of its very small staff size and because the Office of Ethics must also allocate its scant resources to continuing to conduct the regular training and advice-giving provided to all 100,000 USDA career staff and numerous USDA Advisory Committees throughout the Department. Moreover, as a result of the long-term effects of staffing reductions and budget constraints, OE's small but dedicated and innovative staff will need to maintain the high level of quality and excellent customer service provided to all employees at one of the largest Departments in the Executive Branch. Finally, because USDA's Ethics Program is so small, it will need to face the challenge of retaining experienced ethics staff, a daunting problem because we have no "backbench." These problems are exacerbated and compounded by the fact that for the past several years, the DAEO, Alternate DAEO,and other Office of Ethics staff have been required to spend several hundreds of hours of time to assist and work with a substandard and lethargic human resources servicing office. Due to these challenges, USDA’s Ethics Program is at risk of becoming a top notch “finishing school” successfully mentoring and training its staff to achieve very high levels of expertise where they can obtain higher paid ethics positions at other Executive Branch agencies.