2015 AGENCY ETHICS PROGRAM QUESTIONNAIRE

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 (Section 402(e)(1) of the Ethics in Government Act of 1978, as amended). Your response(s) to this Questionnaire serves as your annual report.

OGE uses the data collected by the Annual Agency Ethics Program Questionnaire (Questionnaire) to compile information about the entire executive branch ethics program in order to share information about the 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 programs as well the overall program, and to make informed decisions about resource allocations and priorities. Lastly, OGE will post responses, unedited, on OGE’s website. Therefore, please ensure your responses are suitable for publication.

OGE encourages each agency to use the annual completion of the Questionnaire as an opportunity to evaluate your ethics program.

DUE DATE: By regulation, the Questionnaire is due to OGE by February 1, 2016. (5 CFR § 2638.602(a))

PART 2. INSTRUCTIONS

Your response to this Questionnaire should reflect the 2015 calendar year (i.e., 1/1/2015 through 12/31/2015), except where specified. The answers provided should reflect your agency in total. OGE will only accept one submission per an agency. Throughout the Questionnaire you will be offered an opportunity to provide comments. Please also use these sections to explain discrepancies between levels of required activity and actual activity or significant changes since last year. After OGE has reviewed your Questionnaire submission, you may be contacted for follow-up.

How do I save a draft of my response?

At a minimum, you must choose your agency from the drop down menu and add an email address in the point of contact section at the end of the Questionnaire. Then you can select “Click Exit and Save a Draft”. You will be prompted to click “Okay”. The next screen will have your unique link to the survey. You can either bookmark, save the link as a favorite, or copy the link and save it in a secure location. The questionnaire application will also send an email with the link, but spam filtering may prevent the email from getting through. Please wait for the email before leaving the saved draft page if you have not otherwise saved the link.

How do I access my saved draft and edit the Questionnaire?

Copy and paste your unique hyperlink into your browser or choose the link from your favorites tab on your browser. Select “Edit Questionnaire”. You many now begin to edit your Questionnaire response.

If you have any questions, contact Brandon Steele at (202) 482-9209 or at basteele@oge.gov.

PART 3. DEFINITIONS

Agency Head: For purposes of this Questionnaire, in the case of an agency headed by more than one person, the chair or comparable member of such agency.

D.C Metro Area: For purposes of this Questionnaire, D.C. Metro Area means the District of Columbia, DC; 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; Silver Spring-Frederick-Rockville, MD Metropolitan Division Frederick County, and Montgomery County.

Full-time Agency Employees: For purposes of this Questionnaire, the term full-time agency employees includes employees detailed to another agency. It also includes officers but does not include 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 Agriculture

2. Employees

  • Number of full-time agency employees as of December 31, 2015
110000

3. Information about the DAEO

  • Vacant (As of December 31, 2015)?
No

  • When did the position become vacant? (enter Month/Year)
/

  • DAEO Name
Stuart Bender

  • DAEO Title
Director, USDA Office of Ethics

  • Time in current DAEO position
5 - 9 years

  • Total years performing ethics duties
26

  • DAEO Grade Level
SES or equivalent

  • Percent of time spent on ethics
76-100%

  • Was the DAEO eligible to retire as of December 31, 2015?
No

  • Is the DAEO
Career employee

4. Information about the ADAEO

  • Position Vacant (As of December 31, 2015)?
No

  • When did the position become vacant? (enter Month/Year)
/

  • ADAEO Name
Andrew Tobin

  • ADAEO Title
Deputy Director, USDA Office of Ethics

  • Time in current ADAEO position (years)
1 - 4 years

  • Total years performing ethics duties
8

  • ADAEO Grade Level
GS15

  • Percent of time spent on ethics
76-100%

  • Was the ADAEO eligible to retire as of December 31, 2015?
No

  • Is the ADAEO
Career employee

5. Number of employees who performed ethics program duties in 2015; e.g., financial disclosure, education and training, advice and counseling, program administration.

Approximate amount of time spent each week performing ethics duties
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
0
0
0
0
19
19
Outside the D.C. Metro area
0
0
0
0
1
1
TOTAL
0
0
0
0
20
20

* FTE = Full Time Equivalent

Example: The table below provides an example of an agency with 13 employees that performed ethics
program duties in 2015.

EXAMPLE
Approximate amount of time spent each week performing ethics duties
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. Does the DAEO/ADAEO have supervisory authority over the employees identified in question #5?

  • Select Yes or No
Yes (skip to #8)

7. Indicate which elements of the ethics program have been delegated outside of the supervisory chain of the DAEO or ADAEO.

  • Check all that apply

  • Specify Other
    NA

8. Do contractors support the ethics program?

  • Select Yes or No
No (go to #10)

9. Describe the extent of their support.

  • Describe

10. Identify the agency ethics officials who have ethics duties as a distinct element in their performance standards.

  • Check all that apply
DAEO, ADAEO, All ethics officials (excluding DAEO/ADAEO)

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

  • Additional Comments
    10. The Office of Ethics is the centralized and consolidated Ethics Office for the entire Department of Agriculture. All 20 employees within the USDA Office of Ethics, including the DAEO and ADAEO have ethics duties as a distinct element in their performance standards.

PART 5. PROGRAM ADMINISTRATION

11. Use the following scale to rate the amount of time your agency spends to administer each item. The first six categories exclude time devoted to SGE’s.

  • Time Spent Scale:
1 = No time
2 = Limitedx
x3 = Moderate
4 = Significantx
5 = Very significant

    • Advice and counseling
5

    • Confidential financial disclosure program
5

    • Disciplinary process for violations
2

    • Education and training
5

    • Outside activity approval
4

    • Public financial disclosure program
5

    • Special Government employees' activities
3

    • Other (specify below, and rate at right)
      Training and Advice provided for the following areas: Non-Federal Sponsored Official Travel, Outside Activities/Outside Employment, Service on Outside Non-Profit Professional Association Boards, Combined Federal Campaign (CFC), Feds Feed Families Employee Voluntary Charitable In-Kind Giving Program (Collectively, USDA employees donated approximately 10 tons of food to food banks through the Feds Feed Families food drive), Hatch Act compliance training and advice.
5

12. Are additional resources needed for the ethics program? e.g. budgetary, human capital, technology?

  • Select Yes or No
Yes (go to #13)

13. If you answered YES to 12. above, which additional resources are needed? Select all that apply.

  • Select type of resources
    Budgetary, Human Capital, Technology

  • Specify Other
    NA

14. My agency's leadership (e.g., the agency head, senior executives, and first-line managers) demonstrates support for the ethics program.

  • Select Yes or No
Yes

15. Did the agency head meet with the ethics staff to discuss the strengths and weaknesses of the ethics program in 2015?

  • Select Yes or No
Yes

16. Which of the following tools did your agency use to ensure short- and long-term continuity of operations (succession planning) of its ethics program in 2015? Check all that apply.

  • Professional Development
    Competency/skills gap assessment, Developmental assignments (e.g., detail assignments, cross training, job rotation, use of agency developmental programs such as interns, fellows, or leadership development), Individual development plans, Mentoring
    Structured courses (e.g., classroom training, webinars, online modules, etc.)
      Provided by OGE, Provided by my agency, Provided by another agency

    • Specify Other
      NA

  • Programatic tools
    Written standard operating procedures, Job Aids, Knowledge library (intranet, videos, shared drives), Resources assessment (personnel and/or financial), Other (specify below)

    • Specify Other
      To further enhance cross-training opportunities and enhance succession planning, the Office of Ethics developed a set of six innovative teams 1) Financial Disclosure Programs, 2) Training Programs, 3)Advice and Counsel, 4) Policy and Processes, 5) Outreach,and 6) Internal Training/ Staff Professional Development. OE employees serve on two of these six teams to collaboratively develop best practices and further enhance employee skillsets to the maximum extent practicable.

17. Did your agency (e.g., ethics office, Inspector General, General Counsel) conduct a self-assessment to evaluate any aspect of the ethics program in 2015?

  • Select Yes or No
Yes (go to #18)

18. What did you assess?

  • Check all that apply
Accuracy of advice and counsel, Consistency of advice and counsel, Employee perceptions about the ethics program, Knowledge and skills of ethics officials, Employee satisfaction with training offered, Timeliness of advice and counsel

    • Specify Other
      NA

19. Do you have written policies procedures in place for the following?

  • Check all that apply
Collection of confidential financial disclosure reports, Collection of public financial disclosure reports, Following up with delinquent confidential financial disclosure filers, Following up with delinquent public financial disclosure filers, Public availability of public financial financial disclosure reports, Review/evaluation of confidential financial disclosure reports, Review/evaluation of public financial disclosure reports

20. Does your agency provide ethics program services for any board, commission, or agency that is independent of your agency?

  • Select Yes or No
Yes

    • If Yes (please provide the names of the boards and commissions)
      The Office of Ethics provides ethics program services for the Federal Crop Insurance Corporation (FCIC) and the Delta Regional Authority (DRA). Separately, the Office of the Inspector General (OIG) provides services to the Council of Inspectors General for Integrity and Efficiency (CIGIE).

21. Please list any significant accomplishments your ethics program achieved in 2015.

  • Significant accomplishments
    Despite its small staff, under the leadership of USDA’s General Counsel, who has championed this Office, and with the strong support of the Secretary of Agriculture and the Deputy Secretary, the Office of Ethics (OE) has had numerous significant accomplishments in 2015. These accomplishments include: (1) Energetically enhancing and expanding the USDA Ethics Program’s reach outside of the Beltway to more effectively reach supervisors and employees across the nation. This was cost-effectively implemented by systematically utilizing video teleconferences, conference calls, webinars and, in some instances, large group in-person trainings. As a result, this year, for the first time, OE staff conducted over 62 hours of live large group trainings for USDA employees outside of the Washington, DC area. The DAEO and Alternate DAEO led by example and furthered this outreach by personally leading group separate large group ethics training for supervisors and employees across the country by long-distance webinar and in person large group training. The DAEO also led an innovative inter-active ethics training session for APHIS’ foreign veterinarians and other USDA employees stationed around world. (2) The DAEO expanded his creation and use of Ethics “One-Pagers,” a cost effective Office of Ethics innovation, which are distributed at the Secretary of Agriculture’s Sub-Cabinet meetings, Agency Head’s Meetings, and eight other weekly senior management meetings at USDA Headquarters. All told, the DAEO has personally presented over 400 "Ethics Moment" ethics mini-trainings in 2015. In addition, the Alternate DAEO provides initial ethics orientation training for all incoming USDA political appointees and ensures that all incoming appointees sign the Ethics Pledge on their first day at USDA. (3) The Office of Ethics developed innovative new ethics training materials on the Ethics rules for FSIS meat inspectors and GIPSA grain inspectors. These materials and the DAEO’s Ethics “One-Pagers” were requested and are used by the international Organization for Security and Economic Cooperation in Europe to train over 2,000 food safety inspectors in Serbia. (4) The DAEO personally developed and led a four-hour Ethics and Hatch Act training session for the unique needs of the Forest Service’s Job Corps Directors which was presented at their national conference. (5) Because USDA’s most complex ethics issues involve scientists, the Office of Ethics created the first ever USDA Ethics and Science Conference. This innovative two-day (no cost) Ethics conference brought together senior ARS Associate Area Directors from around the country and enhanced collaboration and communications among scientists and Office of Ethics staff. Building on the conference’s success, the Office of Ethics instituted quarterly Ethics conference calls between Ethics staff and ARS officials on the latest ethics issues involving scientists. In recognition of this high level of collaboration, the Secretary of Agriculture awarded the Office of Ethics the Department’s highest award for excellence and achievement. (6) USDA’s Office of Ethics has led the creation and dissemination of effective ethics rules for the Department’s Fed Feed Families Program. The Office of Ethics developed a “One-Pager” on ethics rules for the Feeds Feed Families campaign. This one pager has been widely distributed throughout USDA and has also been shared with other Federal agencies. 6) The DAEO created Ethics training on the overlay of State Bar Ethics rules and Federal Post-Employment Rules for Federal attorneys leaving government. This training was presented at USDA and was presented at the U.S. Office of Government Ethics’ Institute for Ethics in Government’s Advanced Practitioner’s Webinar Series. This webinar was recorded and is on OGE’s YouTube page. 7) The Office of Ethics has also modernized USDA's Ethics Webpage and led the creation of new Ethics training modules on USDA’s long-distance learning institute “AgLearn.” 8) To address the effects of years of under investment and the lowest level of staffing in the Office of Ethics in eight years (a 45% decrease to 20 employees in 2015 from 36 in 2008), The DAEO and Alternate DAEO led an innovative process improvement: The creation of six new Office of Ethics staff “action teams” to enhance collaborative team building, cross-training, and foster greater innovation in an era of diminished resources. As a group, we created six “action teams’ in the areas of: a) Financial Disclosure b) Ethics Training c) Ethics Advice d) Client Outreach, e) Policies and Procedures, and f) Internal Professional Development. As a result, every Office of Ethics employee serves on two committees of their choosing. 9) To assess the quality of ethics services Office of Ethics staff provided throughout the Department, we revamped the customer service surveys that are included in every e-mail sent by OE staff. These actions made the surveys more noticeable and increased customer service feedback from USDA employees. The changes led to more than a 200% increase in the number of surveys received in 2015 as compared to the same point in 2014 (293 versus 91). Survey feedback has been overwhelmingly positive (98% positive). 10) The Alternate DAEO has led the effort providing live ethics training to a number of USDA’s Federal Advisory Committees. These committees provide advice to the USDA Secretary on topics ranging from bio-technology, food safety, to encouraging new farmers and ranchers to sustain the nation's food supply. (11) OE has taken steps working with OGE to successfully implement Integrity, a new electronic financial disclosure reporting system created by OGE. (12) The DAEO worked to assist the Federal ethics community by delivering a presentation, sharing with the Inter-Agency Ethics Council, USDA's innovative educational ethics training tools. (13) Finally, the Office of Ethics continues to have one of the most successful mentoring programs for its ethics officials. The environment at the Office of Ethics is one where "each one, teaches one" from the DAEO and Alternate DAEO on down, everyone learns from everyone else to become better, more finely honed, ethics experts.

22. Please list the greatest challenges facing your ethics program in the short term (next 1-3 years).

  • 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.

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

  • Additional Comments

PART 6. EDUCATION AND TRAINING

23. How many employees (including Special Government Employees) were required to receive Initial Ethics Orientation (IEO) by December 31, 2015.

  • Number required
4676

    • a. How many of those employees received IEO within the 90 day requirement?
3998

    • b. How many of those employees received IEO beyond the 90 day requirement?
678

    • c. How many of those employee have not received IEO as of today?
0

  • If applicable, please explain why some employees received IEO beyond the 90 day requirement or have yet to receive IEO.
    In 2015, 4,676 employees were required to receive the Initial Ethics Orientation. While all 4,676 received the Initial Ethics Orientation, 678 (14%) of new entrants did not take the training within 90 days. The 4,676 number reflects a more than 100% increase from 2014's 2,330 employees who were required to receive training just one year earlier. Because of this, the Office of Ethics (OE)is going to remind USDA Human Resources Offices of the importance of taking Initial Ethics Training within the 90 day window. Also, we will work with the AgLearn Administrator to develop a different reporting system which would allow us to better track and identify those required to take training within 90 days of their arrival at USDA.

    Example: An employee came on board December 15, 2015. You do not need to count the employee toward the number of employees who were required to have received IEO in calendar year 2015 because you have until March 2015 to provide the employee IEO.

24. Is IEO part of your agency’s on-boarding process for new employees?

  • Select Yes or No
Yes

25. How do you deliver IEO to new employees?

  • Check all that apply
Classroom instruction (in-person), Instructor-led web-based, One-on-one briefings, Written materials, Other (specify below)

    • Specify Other
      USDA's Onboarding Portal, which is mandatory for all new employees, contains an Ethics Orientation Training module which employees are expected to view prior to their arrival at USDA. This onboarding requirement is mandated for all incoming employees by a USDA Departmental Regulation.

26. Who developed the the IEO training materials?

  • Check all that apply
    My agency
    • How did you access the training materials? Check all that apply.
      • Specify Other
        NA

    • Specify Other
      NA

27. Required Annual Ethics Training* (verbal and written)

Type of covered employees (Include SGE filers)
# Required
Received (Of those Required)
    Public filers (OGE Form 278) – PAS
15
15

    Public filers (OGE Form 278) - non-PAS
646
631

    Confidential filers (OGE Form 450, 450A, and OGE-approved alternative confidential financial disclosure forms)
13198
13098

    Other employees required by 2638.705(a) (employees appointed by the President; employees of the Executive Office of the President; Contracting Officers; other employees designated by the head of the agency or his or her designee based on their official duties.)
0
0

TOTAL
13859
13744

* Note about counting: Only include those employees that were required by 5 C.F.R. § 2638.705 to receive annual ethics training, either verbal or written, during the calendar year.

  • If applicable, please explain discrepancies between the number of employees who were required to receive training and the number of employees who received training
    Some filers left or retired from USDA before completing their annual Ethics training.

28. How do you deliver annual ethics training to employees required to receive training?

  • Check all that apply
Classroom instruction (in-person), Instructor-led web-based, One-on-one briefings, Video, Satellite broadcast/videoconference, Written materials, Other (specify below)

    • Specify Other
      USDA utilizes AgLearn, a long-distance electronic learning tool which contains several videotapes of live ethics training sessions, ethics modules, and USDA's "Ethics Sweepstakes" an interactive ethics game (a competitive horse race).

29. Who developed the annual training materials?

  • Check all that apply
    My agency
  • How did you access the training materials? Check all that apply.
    • Specify Other
      NA

30. Did you provide annual ethics training to other employees not otherwise required by regulation to receive training?

  • Select Yes or No
Yes

31. Did you provide additional, specialized ethics training during 2015?

  • Select Yes or No
Yes (go to #32)

32. Which groups did you target?

  • Check all that apply
HR Officials, IT personnel, Procurement Officials, Supervisors, Other (specify below)

    • Specify Other
      USDA Scientists, USDA Senior Executives, Forest Service Job Corps Directors, Farm Service Agency State Executive Directors and Administrative Officers, Food Nutrition Service employees in Regional Offices, Animal and Plant Health Inspection Service staff.

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

  • Additional Comments

PART 7. ADVICE AND COUNSELING

33. From the list below, select the three topics that your employees most frequently sought guidance on in 2015.

  • Awards
  • Conflicting financial interests
  • Gift acceptance (excluding awards and travel, subsistence, and related expenses from non-federal sources)
  • 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
Financial Disclosure Reporting
  • Selection 2
Outside employment/activities
  • Selection 3
Travel, subsistence, and related expenses from non-federal sources

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

34. Has your agency ethics program implemented any of the following practices?

  • Check all that apply
    Conduct customer satisfaction survey(s), Periodic supervisory review of advice given, Guided discussion among staff, Memorialize advice and counsel
      All
    Use advice and counsel templates, Use a database Check all that apply
      to conduct research, to identify topics for training

  • Specify Other
    NA

35. Number of notification statements of negotiation or recusal under section 17(a) of the STOCK Act submitted to the ethics office in 2015?

  • Enter total
24

36. How do you make employees aware of the availability of post-employment counseling?

  • Check all that apply
Part of out-processing, Emails, Training, Regulation or policy

  • Specify Other
    NA

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

  • Additional Comments

PART 8. FINANCIAL DISCLOSURE

37. Report the number of public financial disclosure reports (OGE Form 278) required to be filed by December 31, 2015, excluding SGEs, and the number of reports actually filed (i.e., received in hand) by December 31, 2015.

OGE Form 278 Reports Required to be Filed in CY 2015

OGE Form 278 Reports
PAS2
Non-Career SES3
Career SES3
Schedule C
Other4
Nominee/New EntrantRequired
1
5
20
25
5
Filed
1
5
18
25
5
AnnualRequired
14
32
203
148
190
Filed
14
32
203
147
190
TerminationRequired
0
1
5
9
12
Filed
0
1
5
9
12
Combination1Required
0
0
0
1
2
Filed
0
0
0
1
2
    Total
Required
15
38
228
183
209
Filed
15
38
226
182
209

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), etc.


Example: For new entrant and termination reports: If an employee starts/ leaves the agency on December 15, 2015, and s/he files a new entrant/termination report prior to the end of the calendar year, then you can include the report in your required and filed numbers. If, on January 1, the employee has not filed a new entrant/termination report, then you do not have to count that report in your required numbers, because it was was not required to be filed until January 15. You instead would include the employee in your 2016 Questionnaire’s new entrant numbers in 2017.

  • If applicable, please explain discrepancies between the number of reports required to be filed and the actual number of reports filed.
    Annual filer on extended medical leave. New entrants granted filing extension.

38. Extension and late fees for new entrant, annual, termination, and combination public financial disclosure reports, excluding SGEs.*

Granted filing extension
Granted waivers of late filing fee
Paid late filing fee
  • Number of OGE Form 278 Reports
142
0
0

39. Number of periodic transaction reports filed, excluding SGEs.*

  • Periodic Transaction Reports Filed
251
* Note about counting: 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 table above. Example 2: If an employee files one report each month, each report is counted separately. Report “12” in the table.

40. Extensions and late fees for periodic transaction reports, excluding SGEs.

Granted filing extension
Granted waivers of late filing fee
Paid late filing fee
  • Number of OGE Form 278 T Reports
1
1
0

41. Number of public financial disclosure filers reported in calendar year 2015 to the Attorney General for failure to file.

  • Enter total
0

42. How many requests for public financial disclosure reports did you receive in 2015.

  • Enter total
1

43. Does your agency use an automated system (e.g., Excel, Access, custom database) to track the administration of the financial disclosure program?

  • Select Yes or No
Yes

44. Did you receive timely notification of all new entrant employees required to file financial disclosure reports?

  • Select Yes or No
Yes

45. Does your agency require an intermediate review by someone other than ethics staff (e.g., supervisors and team leads) for public financial disclosure reports?

  • Select Yes or No
No

46. What steps do you take to collect delinquent public financial disclosure reports? Check all that apply.

  • Check all that apply
Repeated reminders to the filer, Notify supervisor, Certified letter to the filer

    • Specify Other
      NA

47. Does your agency use an electronic financial disclosure filing system (e-filing system)? Note: This includes Integrity.

  • Select Yes or No
Yes (go to 48)

48. Which system does your agency use?

  • Select one
Integrity AND Other (specify below)

    • Specify Other
      FDOnline

49. Indicate your fiscal year 2015 actual and fiscal year 2016 projected costs for using the e-filing system. Note: Do not include costs to operate Integrity.

    a) Total FY 2015 actual costs
$411259

    b) Total FY 2016 projected costs
$411259

    c) amount paid to a non-federal vendor in 2015
$0

    d) amount projected to be paid to a non-federal vendor in 2016
$0

    e) amount paid to a federal agency in 2015
$411259

    f) amount projected to be paid to a federal agency in 2016
$411259

    g) amount for all internal costs associated with operating an e-filing system (e.g., FTE, overhead, etc.) in FY 2015
$1500000

    h) amount projected for all internal costs associated with operating an e-filing system (e.g., FTE, overhead, etc.) in FY 2016
$1500000

    i) number of public financial disclosure filers who filed in electronically in 2015
661

    j) number of public financial disclosure filers projected to file electronically in FY 2016
661

    k) number of confidential financial disclosure filers who filed electronically in FY 2015
13316

    l) number of confidential financial disclosure filers projected to file electronically in FY 2016
13316

50. Indicate which forms your agency uses the e-filing system for.

  • Check all that apply
Public Financial Disclosure (OGE Form 278), Periodic Transaction (OGE Form 278-T), Confidential Disclosure Forms (OGE Form 450, 450A, or OGE-approved alternative form)

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

  • Additional Comments

PART 9. CONFIDENTIAL FINANCIAL DISCLOSURE

51. Report the number of confidential financial disclosure reports required to be filed by December 31, 2015, excluding SGEs, and the number of reports actually filed by December 31, 2015.

  • Confidential financial disclosure reports required to be filed in CY 2015:

# Required to File
(By December 31)
#Filed
      OGE Form 450/450A
13046
450: 3747 450A: 9192
      OGE-approved alternative form
0
0
Total
13046
12939

    Example: For new entrant reports: If an employee starts the agency on December 15, 2015, and files a new entrant report prior to the end of the calendar year, then you can include the report in your required and filed numbers. If, on January 1, the employee has not filed a new entrant report, then you do not have to count that report in your required numbers, because it was was not required to be filed until January 15. You instead would include the employee in your 2016 Questionnaire’s new entrant numbers in 2017.

    If applicable, please explain discrepancies between the number of reports required to be filed and the actual number of reports filed below.
  • Explain, if applicable
    Some OGE-450 filers retired or otherwise left the department or were out on extended medical leave or other long-term leave. Other filers transferred to other positions (with different duties) within USDA which did not require them to file the OGE-450.

52. Number of OGE 450, 450A, or OGE-approved alternative forms granted filing extensions in 2015.

  • Enter number
79

53. What steps do you take to collect delinquent confidential financial disclosure reports?

  • Check all that apply
Repeated reminders to the filer, Notify supervisor, Notify agency head or other senior official

    • Specify Other
      NA

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

  • Additional Comments

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

54. Number of public financial disclosure filers who took specific remedial actions because of information on a new entrant, annual, or termination report (e.g., divestiture, resignation from outside position, written disqualification, 18 U.S.C. § 208 waiver, reassignment, etc.) in 2015.

  • Enter number
4

55. Number of individual remedial actions taken because of information on a new entrant, annual, or termination public financial disclosure (OGE Form 278) report in 2015.

  • Recusals
4

  • Divestitures
0

  • Resignations from outside positions
0

  • Reassignments
0

  • Other not listed (please specify below)
0

  • Specify Other

56. Number of public financial disclosure filers who took specific remedial actions because of information on periodic transaction reports (e.g., divestiture, resignation from outside position, written disqualification, U.S.C. § 208 waiver, reassignment, etc.) in 2015.

  • Enter number
0

57. Number of remedial actions taken because of information on a periodic transaction report in 2015.

  • Recusals
0

  • Divestitures
0

  • Reassignments
0

  • Other not listed (please specify below)
0

  • Specify Other

58. Number of § 208(b)(1) waivers granted in 2015.

  • Enter number
0

59. Number of § 208(b)(1) waivers provided to OGE in 2015.

  • Enter number
0

60. Number of § 208(b)(3) waivers granted in 2015.

  • Enter number
0

61. Number of § 208(b)(3) waivers provided to OGE in 2015.

  • Enter number
0

62. Number of disciplinary actions taken based wholly or in part upon violations of the Standards of Conduct provisions (5 CFR part 2635) in 2015. For purposes of this question, disciplinary actions include removals, demotions, suspensions, and written reprimands or their equivalents.

  • Enter number
0

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

    Subpart A

    Subpart B

    Subpart C

    Subpart D

    Subpart E

    Subpart F

    Subpart G

    Subpart H


63. Number of disciplinary actions taken based wholly or in part upon violations of the criminal conflict of interest statutes, 18 U.S.C. §§ 203, 205, 207, 208, and 209 in 2015. For purposes of this question, disciplinary actions include removals, demotions, suspensions, and written reprimands or their equivalents.

  • Enter number
0

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

    18 U.S.C. §203

    18 U.S.C. §205

    18 U.S.C. §207

    18 U.S.C. §208

    18 U.S.C. §209


64. Number of referrals made to the Department of Justice of potential violations of the criminal conflict of interest statutes in 2015.

  • Enter number
0

    a. How many of those referrals were accepted for prosecution
0

    b. How many of those referrals were declined for prosecution
0

    c. How many of those referrals resulted in discliplanary or corrective action
0

65. Which individual(s) is responsible for filing the Notification of Conflict of Interest Referral (Form 202)?

  • Check all that apply
DAEO/ADAEO, IG

    • Specify Other
      NA

66. Did you submit all referral(s) and disposition(s) of the referral(s) to OGE via
OGE Form 202 (as required by 5 CFR 2638.603(c)).

  • Select answer
Not Applicable

ADDITIONAL COMMENTS FOR PART 10. Please indicate the question number to which the comment corresponds.
  • Additional Comments

PART 11. ADVISORY COMMITTEES & SPECIAL GOVERNMENT EMPLOYEES (SGEs)
67. Does your agency have any FACA or Non-FACA advisory committees, boards, or commissions?

  • Select Yes or No
Yes (go to #68)

68. Number of FACA advisory committees.

  • Enter number
149

69. Number of FACA advisory committee members.

  • Enter number
2098

70. Number of non-FACA advisory committees, boards, or commissions.

  • Enter number
50

71. Number of non-FACA advisory committee, board, or commission members.

  • Enter number
210


72. Does your agency have any SGEs (as of December 31, 2015)?

  • Select Yes or No
Yes (go to #73)


73. Number of Special Government Employees (SGEs) as of December 31, 2015.

  • Enter number
390

74. Does your agency have written policies or procedures for designating SGE status.

  • Select Answer
Yes

    • Specify why
      NA

75. Does the written policy or procedure include consultation with the ethics office?

  • Select Answer
Yes

    • Specify why
      NA

76. Does the ethics office provide training to SGEs, who serve on committees or participate in board meetings, prior to attendance at their first committee or board meeting?

  • Select Answer
Yes (go to #77)

77. If yes, which office provides the training?

  • Enter office
    The USDA Office of Ethics

78. Report the number of SGE public and confidential financial disclosure reports required to be filed by December 31, 2015 and the number of reports actually filed by December 31, 2015.

  • Financial disclosure reports required to be filed by SGEs in CY 2015:

Type of SGE
Confidential Reports
(OGE Form 450 or OGE- Approved Alternative Form)
Public Reports
(OGE Form 278)
required
filed
required
filed
Advisory Committee Members (FACA)
180
180
0
0
Advisory Committee Members (non-FACA)
210
210
0
0
Experts/Consultants
0
0
0
0
Board Members
0
0
0
0
Commissioners
0
0
0
0
Other
0
0
0
0
TOTAL
390
390
0
0

    Example: For new entrant reports: If an employee starts with the agency on December 15, 2015, and files a new entrant report prior to the end of the calendar year, then you can include the report in your required and filed numbers. If, on January 1, the employee has not filed a new entrant report, then you do not have to count that report in your required numbers, because it was was not required to be filed until January 15. You instead would include the employee in your 2015 Questionnaire’s new entrant numbers in 2016.
  • If applicable, please explain discrepancies between the number of reports required to be filed and the actual number of reports filed.

79. Number of SGEs excluded from all or a portion of the confidential filing requirements per 5 C.F.R. 2634.904(b).

  • Enter number
0

80. Extensions and late filing fees for SGE financial disclosure reports.

Granted filing extension
Granted waivers of late filing fee
Paid late filing fee
  • Number of OGE Form 278 Reports
0
0
0

81. Number of SGE OGE Form 450 Reports or OGE-Approved Alternative Form filers granted filing exenstions.

  • Enter number
0

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

  • Additional Comments

ADDITIONAL QUESTIONNAIRE COMMENTS:

  • Additional Comments