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 Justice

2. Employees

  • Number of full-time agency employees as of December 31, 2015
113962

3. Information about the DAEO

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

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

  • DAEO Name
Lee J Lofthus

  • DAEO Title
Assistant Attorney General for Administration

  • Time in current DAEO position
10 or more years

  • Total years performing ethics duties
10

  • DAEO Grade Level
Executive Schedule

  • Percent of time spent on ethics
0-25%

  • Was the DAEO eligible to retire as of December 31, 2015?
Yes

  • 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
Michael H Allen

  • ADAEO Title
Deputy Assistant Attorney General, Policy, Management and Planning

  • Time in current ADAEO position (years)
10 or more years

  • Total years performing ethics duties
12

  • ADAEO Grade Level
SES or equivalent

  • Percent of time spent on ethics
0-25%

  • Was the ADAEO eligible to retire as of December 31, 2015?
Yes

  • 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
61
57
8
14
19
159
Outside the D.C. Metro area
20
258
1
0
0
279
TOTAL
81
315
9
14
19
438

* 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
No (go to #7)

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
Other (specify below)

  • Specify Other
    While DOJ's DAEO has authority over all of these elements of the ethics program (and more), ethics program duties are performed by employees, many of whom are not in the DAEO's direct supervisory chain.

8. Do contractors support the ethics program?

  • Select Yes or No
Yes (go to #9)

9. Describe the extent of their support.

  • Describe
    Some DOJ components utilize contractors to support the ethics program. The extent of the support includes IT needs such as utilizing databases and spreadsheets to help track financial disclosure and training, developing and maintaining ethics websites, tracking ethics program requirements, and other reporting and administrative duties. One component utilizes a contractor paralegal for additional program support including financial disclosure compliance, assistance with ethics opinions including review of approvals for employees, research and drafting opinions for the DDAEO, and preparing reports for OGE.

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

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

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

  • Additional Comments
    6/7 DOJ has 32 attorneys serving as Deputy DAEOs in its Components, Bureaus and Divisions, and in most of its Offices. In addition to the DDAEOs, as the Departmental Ethics Office (DEO) in the Justice Management Division (JMD) oversees the Department-wide ethics program and provides direct advice to DOJ's senior leadership offices, to JMD and to certain smaller offices.
    DEO's programmatic functions include issuance of Department-wide guidance, providing ethics information, advice and counsel to DDAEOs, preparation of training materials for use or adaptation by DDAEOs, delivery of ethics training, ethics program reporting, overall management of online public financial disclosure in Integrity, and retention of ethics documents including Pledges and certain financial disclosure records.

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
3

    • Disciplinary process for violations
2

    • Education and training
4

    • Outside activity approval
4

    • Public financial disclosure program
5

    • Special Government employees' activities
3

    • Other (specify below, and rate at right)
      Travel expenses paid by nonfederal sources, Hatch Act, ethics crossover with other rules (cont'd)
4

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, Other (specify below)

  • Specify Other
    Additional training opportunities

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
    Other (specify below)

    • Specify Other
      Meetings with DEO and other ethics officials to cross train, training on the FAR

  • 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
      Some components utilize shared email accounts that are dedicated to ethics questions for ethics officials' awareness of issues.

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, Administration of confidential financial disclosure program, Administration of public financial disclosure program, Compliance with applicable ethics laws and regulations, Consistency of advice and counsel, Employee knowledge after training, Employee perceptions about the agency’s ethical culture, Employee perceptions about the ethics program, Knowledge and skills of ethics officials, Employee satisfaction with training offered, Employee knowledge of the ethics rules, Timeliness of advice and counsel, Other (specify below)

    • Specify Other
      Resource allocation

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)
      FirstNet Board, prior to their hiring of an ethics official.

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

  • Significant accomplishments
    DOJ successfully launched online public financial disclosure in Integrity, the brand new system developed and launched by OGE DOJ was the first and largest Cabinet-level agency to successfully utilize Integrity. This initiative required significant devotion of DOJ resources in 2015, including ethics officials’ time and other programmatic resources. There were unanticipated difficulties in using the new system, for both DOJ’s filers and reviewers. For example, many DOJ filers had considerable difficulty with Integrity’s reliance on MAX.gov to log in. DOJ helped its users navigate MAX.gov so that filers were timely with their annual submission. By way of another example, DOJ’s programmatic structure for review and certification of reports was not reflected in Integrity’s development. However, DOJ developed alternate ways to have reports reviewed and certified in Integrity, allowing the appropriate officials in DOJ to have access to and certify reports. (cont'd)

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

  • Greatest challenges
    Transition of leadership. Succession planning: continuity of ethics programs with departure/retirement of senior ethics officials. Maximizing ethics program effectiveness with limited resources and increasing requirements. The continued increase in ethics programmatic requirements, including reporting, coupled with the increasing number and complexity of ethics issues that arise strain already limited ethics program resources. Obtaining and maximizing technology support. SGE/FACA identification, ethics training and financial disclosure

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

  • Additional Comments
    11. (cont'd) e.g. Bar rules, contractor issues, joint collaboration with nonfederal entities, speaking requests
    21. Under expedited timeframes throughout 2015, DOJ worked extensively with OGE developers and contractors to help identify and develop solutions for Integrity difficulties, such that the vast majority of the Department’s annual public filers, which numbered in excess of 1,800, were able to successfully submit their financial disclosure reports in Integrity.
    DOJ provides live, in-person verbal annual ethics training to all public financial disclosure filers every calendar year. Confidential financial disclosure filers receive their annual ethics training live and in-person every third year, with web-based or other training methods used in the interim two years. 2015 was a “live” training year in DOJ. With minimal exceptions, DOJ delivered live, in-person or verbal annual ethics training to the Department’s nearly 80,000 confidential and public filers (cont'd at end)

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
8232

    • a. How many of those employees received IEO within the 90 day requirement?
8161

    • b. How many of those employees received IEO beyond the 90 day requirement?
35

    • c. How many of those employee have not received IEO as of today?
36

  • If applicable, please explain why some employees received IEO beyond the 90 day requirement or have yet to receive IEO.
    Verbal annual training was provided live and in-person throughout DOJ in 2015. Some attended those sessions rather than attending IEO. Notification delay or oversight due to live annual training activities and efforts. Scheduling conflicts, extended leave, departure from DOJ. Outstanding training is tracked and enforced.

    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), One-on-one briefings, Self-paced web-based, Video, Written materials, Other (specify below)

    • Specify Other
      Internal agency video-on-demand

26. Who developed the the IEO training materials?

  • Check all that apply
    My agency, OGE
    • 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
116
116

    Public filers (OGE Form 278) - non-PAS
2497
2412

    Confidential filers (OGE Form 450, 450A, and OGE-approved alternative confidential financial disclosure forms)
19595
19217

    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.)
55553
55437

TOTAL
77761
77182

* 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
    Departure/detail prior to training, extended leave status, military deployment. DEA experienced a delay due to technology delays with their LMS which wasn't launched until Jan '16. See comments below for more info about training in 2015.

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, Self-paced web-based, Video, Satellite broadcast/videoconference, Written materials, Other (specify below)

    • Specify Other
      Internal video on demand, Microsoft Lync and Skype for business

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
All agency personnel, HR Officials, Procurement Officials, Supervisors, Other (specify below)

    • Specify Other
      Attorneys, JMD Finance Staff, users of Integrity, contracting staff, Advisory Committee/Boards, interns, PAS employees, retirement seminars, overseas employees. FBI: Legal Attaches, Lab Division staff BOP: Wardens, Chaplains, education staff, prisoner re-entry staff

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

  • Additional Comments
    25. Written materials alone for IEO are utilized only for employees who can not attend live IEO, e.g. field personnel
    27. Others: Most attorneys in DOJ are required to receive 1 hour of government ethics training every year as a component of Professionalism Training. The # of attorneys who received ethics training under this requirement in 2015 was approximately 9,800. Most attorneys at DOJ are financial disclosure filers, but not all are. Also, some components of DOJ require all employees to receive annual ethics training independent of their financial disclosure status. Those components include BOP, ATF, the Criminal and National Security Divisions, and the Offices of Information Policy and Public Affairs. The # of employees who received ethics training under this requirement in 2015 was approximately 55,000. Many of these employees are also financial disclosure filers, but not all are.

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
Gift acceptance (excluding awards and travel, subsistence, and related expenses from non-federal sources)
  • Selection 3
Outside employment/activities

  • 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
      Some
    Use advice and counsel templates, Use a database Check all that apply
      to track timeliness, to conduct research, to identify topics for training
    Other (specify below)

  • Specify Other
    Most advice is memorialized.

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
90

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, Other (specify below)

  • Specify Other
    Post government information is available online 24/7.

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
10
9
120
7
209
Filed
10
9
113
6
208
AnnualRequired
121
75
680
34
1331
Filed
121
75
667
34
1331
TerminationRequired
14
4
41
3
219
Filed
14
4
39
3
219
Combination1Required
3
0
8
1
45
Filed
3
0
7
1
45
    Total
Required
148
88
849
45
1804
Filed
148
88
826
44
1803

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.
    The use of Integrity in 2015 required ethics officials and filers to navigate MAX.gov and a new online filing system for the first time. The MAX authentication was problematic. Many users, especially new entrant filers, and ethics officials who facilitate financial disclosure, were unfamiliar with the new system and with electronic financial disclosure generally, and had considerable difficulty with MAX and Integrity resulting in delayed or missing reports. Outstanding reports have since been submitted in Integrity and all outstanding reports are pursued until filing requirement are brought current. As DOJ becomes more familiar with Integrity and e-filing, delays and problems with filing in Integrity will decrease.

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
527
27
7

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

  • Periodic Transaction Reports Filed
1474
* 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
54
45
3

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
8

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
No

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
Yes

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, Notify agency head or other senior official

    • 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
      EOUSA used an internal e-filing system in 2015

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
$0

    b) Total FY 2016 projected costs
$0

    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
$0

    f) amount projected to be paid to a federal agency in 2016
$0

    g) amount for all internal costs associated with operating an e-filing system (e.g., FTE, overhead, etc.) in FY 2015
$0

    h) amount projected for all internal costs associated with operating an e-filing system (e.g., FTE, overhead, etc.) in FY 2016
$0

    i) number of public financial disclosure filers who filed in electronically in 2015
0

    j) number of public financial disclosure filers projected to file electronically in FY 2016
0

    k) number of confidential financial disclosure filers who filed electronically in FY 2015
0

    l) number of confidential financial disclosure filers projected to file electronically in FY 2016
0

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

  • Check all that apply
Public Financial Disclosure (OGE Form 278)

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

  • Additional Comments
    44. Ethics Officials in some components experience a delay in notification of new filers, in particular when employees serve in covered positions in an acting capacity. Components continue to work with their HR/Personnel offices to improve timely notification processes.
    45. In some offices an intermediate review is performed by an official in the filer's supervisory chain.
    48. EOUSA is unable to report these costs because they are included in the overall Case Management Budget which includes various systems, IT servers and other resources, and staffing. The internal system is being phased out and will be used only for Termination reports and historical records in 2016 due to transition to Integrity.

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
14155
450: 14106 450A: 0
      OGE-approved alternative form
5982
5981
Total
20137
20087

    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
    Departure from DOJ or from filing position prior to filing, extended leave including disability and maternity, and military deployment.

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

  • Enter number
123

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

Don’t know/don’t track

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

  • Divestitures

  • Resignations from outside positions

  • Reassignments

  • Other not listed (please specify below)

  • Specify Other
    NA

Don’t know/don’t track

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

Don’t know/don’t track

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

  • Recusals

  • Divestitures

  • Reassignments

  • Other not listed (please specify below)

  • Specify Other
    NA

Don’t know/don’t track

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

  • Enter number
5

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
275

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

    Subpart A
12

    Subpart B
1

    Subpart C
0

    Subpart D
0

    Subpart E
5

    Subpart F
0

    Subpart G
236

    Subpart H
0


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
2

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

    18 U.S.C. §203
0

    18 U.S.C. §205
0

    18 U.S.C. §207
0

    18 U.S.C. §208
2

    18 U.S.C. §209
0


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

  • Enter number
1

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

    b. How many of those referrals were declined for prosecution
1

    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
IG, Other (specify below)

    • Specify Other
      Director, Departmental Ethics Office

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
    54 through 57. DOJ components do not track remedial actions in this manner.
    62. The violations may overlap with or involve more than one Subpart of the Standards of Conduct.

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
9

69. Number of FACA advisory committee members.

  • Enter number
153

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

  • Enter number
1

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

  • Enter number
2


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
46

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
    Ethics office and appointing office

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)
30
30
1
1
Advisory Committee Members (non-FACA)
0
0
0
0
Experts/Consultants
7
7
0
0
Board Members
0
0
0
0
Commissioners
2
2
0
0
Other
2
2
0
0
TOTAL
41
41
1
1

    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
4

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
    One FACA member filed a Judiciary financial disclosure report.

ADDITIONAL QUESTIONNAIRE COMMENTS:

  • Additional Comments
    Part5/Q21 (cont)Accomplishments: ethics officials staffing changes in 2015 occurred without a loss of service quality in advice. New ethics officials received in-depth training in the component and through DEO.
    Additional notable accomplishments:
    ATF:new Ethics Order, BOP:new Ethics Newsletter, DEA: new post-employment Questionnaire, significantly enhancing advice and training on post-government restrictions to departing employees,EOUSA:Conference for more than 100 ethics advisors with speakers from OGE & OSC,DEA & OJP: enhanced outside activity approval with new processes and tracking, USMS: new e-filing system for confidential financial disclosure, CRM:new independent monitor policy, enhanced training for overseas employees.