2016 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 OGE’s Annual Ethics Program Questionnaire (Questionnaire) serve as your annual report.

OGE uses the data collected through the Questionnaire about the entire executive branch ethics program in many ways, including sharing 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 as the overall ethics program, and to make informed decisions about resource allocations and priorities. OGE posts a summary of Questionnaire responses as well as 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 1, 2017. (5 CFR § 2638.602(a)).

PART 2. INSTRUCTIONS

Your response to this Questionnaire should reflect the 2016 calendar year (i.e., 1/1/2016 through 12/31/2016), except where specified. The answers provided should reflect the aggregated numbers for your agency in total. 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. These comment sections should also be used to explain significant changes from your 2015 report. After OGE has reviewed your Questionnaire submission, you may be contacted for follow-up.

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

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.

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; and, 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

  • White House

2. Employees

  • Number of full-time agency employees as of December 31, 2016
443

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

  • Vacant (As of December 31, 2016)?
No

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

  • DAEO Name
W. Neil Eggleston

  • DAEO Title
Counsel to the President

  • Time in current DAEO position
1 - 4 years

  • Total years performing ethics duties
3

  • DAEO Grade Level
Executive Schedule

  • Percent of time spent on ethics
0-25%

  • Was the DAEO eligible to retire as of December 31, 2016?
Yes

  • Is the DAEO
Political employee

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

  • Position Vacant (As of December 31, 2016)?
No

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

  • ADAEO Name
Dana Remus

  • ADAEO Title
Deputy Counsel to the President

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

  • Total years performing ethics duties
2

  • ADAEO Grade Level
SES or equivalent

  • Percent of time spent on ethics
51-75%

  • Was the ADAEO eligible to retire as of December 31, 2016?
No

  • Is the ADAEO
Political employee

5. Number of employees who performed ethics program duties in 2016; 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
3
0
0
12
15
Outside the D.C. Metro area
0
0
0
0
0
0
TOTAL
0
3
0
0
12
15

* FTE = Full Time Equivalent

Example: The table below provides an example of an agency with 13 employees that performed ethics
program duties in 2016.

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

None

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

  • Additional Comments

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
4

    • Confidential financial disclosure program
2

    • Disciplinary process for violations
1

    • Education and training
4

    • Outside activity approval
2

    • Public financial disclosure program
4

    • Special Government employees' activities
1

    • Other (specify below, and rate at right)
      N/A
1

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

  • Select Yes or No
No (go to #14)

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

  • Select type of resources

  • 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

    • If No (please provide a comment or explanation)

15. Did the agency head meet with the ethics staff to discuss the strengths and weaknesses of the ethics program in 2016?

  • Select Yes or No
No

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 2016? Check all that apply.

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

    • Specify Other
      NA

  • Programatic tools
    Written standard operating procedures, Knowledge library (intranet, videos, shared drives)

    • Specify Other
      NA

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 2016?

  • Select Yes or No
Yes (go to #18)

18. What did you assess?

  • Check all that apply
Administration of confidential financial disclosure program, Administration of public financial disclosure program, Compliance with applicable ethics laws and regulations, Consistency 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
No

    • If Yes (please provide the names of the boards and commissions)

21. Please list any significant accomplishments your ethics program achieved in 2016.

  • Significant accomplishments
    The White House instituted case-based, interactive annual ethics training for the first time. Conception of this well-received course was supported by OGE, and prepared in coordination with an OGE detailee. The White House provided annual and post-employment briefings to the entire White House.

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

  • Greatest challenges
    Presidential Transition.

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

  • Additional Comments
    Question 15: The DAEO and ADAEO regularly coordinate with the Chief of Staff on matters of importance to the ethics program

PART 6. EDUCATION AND TRAINING

23. How many employees (including Special Government Employees) were required to receive Initial Ethics Orientation (IEO) by December 31, 2016.

  • Number required
114

    • a. How many of those employees received IEO within the 90 day requirement?
105

    • b. How many of those employees received IEO beyond the 90 day requirement?
7

    • c. How many of those employee have not received IEO as of today?
2

  • If applicable, please explain why some employees received IEO beyond the 90 day requirement or have yet to receive IEO.
    See Additional Comments Section.

    Example: An employee came on board December 15, 2016. You do not need to count the employee toward the number of employees who were required to have received IEO in calendar year 2016 because you have until March 2016 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, Video, Written materials

    • Specify Other
      NA

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 278e) – PAS
0
0

    Public filers (OGE Form 278e) - non-PAS
151
149

    Confidential filers (OGE Form 450, 450A, and OGE-approved alternative confidential financial disclosure forms)
53
52

    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.)
327
317

TOTAL
531
518

* 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
    See Additional Comments Section.

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

  • Check all that apply
Classroom instruction (in-person), Video, Written materials

    • Specify Other
      NA

29. Who developed the annual training materials?

  • Check all that apply
    My agency, OGE
  • 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 2016?

  • Select Yes or No
No (go to #33)

32. Which groups did you target?

  • Check all that apply

    • Specify Other
      NA

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

  • Additional Comments
    Question 23: White House Counsel’s Office provides monthly in-person initial ethics briefings for all new officials, including detailees. These employees missed the in-person ethics briefings, but were provided briefing materials after the 90 day time period lapsed. Question 27: This number reflects the employees who received training as of November 15, 2016. All employees received training after November 15, 2016 and prior to December 31, 2016, except for one who had terminated Federal service.

PART 7. ADVICE AND COUNSELING

33. From the list below, select the three topics that your employees most frequently sought guidance on in 2016.

  • 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
Gift acceptance
  • Selection 2
Financial Disclosure Reporting
  • Selection 3
Post-employment restrictions

  • 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
    Memorialize advice and counsel
      Some
    Use advice and counsel templates, Use a database Check all that apply
      to track timeliness, to conduct research

  • 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 2016?

  • Enter total
223

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

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

  • 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 278e) required to be filed by December 31, 2016, excluding SGEs, and the number of reports actually filed (i.e., received in hand) by December 31, 2016.

OGE Form 278e Reports Required to be Filed in CY 2016

OGE Form 278e Reports
PAS2
Non-Career SES3
Career SES3
Schedule C
Other4
Nominee/New EntrantRequired
0
0
0
0
29
Filed
0
0
0
0
28
AnnualRequired
0
0
0
0
108
Filed
0
0
0
0
108
TerminationRequired
0
0
0
0
14
Filed
0
0
0
0
14
Combination1Required
0
0
0
0
1
Filed
0
0
0
0
1
    Total
Required
0
0
0
0
152
Filed
0
0
0
0
151

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, 2016, 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 2017 Questionnaire’s new entrant numbers in 2018.

  • If applicable, please explain discrepancies between the number of reports required to be filed and the actual number of reports filed.
    See Additional Comments Section.

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 278e Reports
33
11
3

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

  • Periodic Transaction Reports Filed
47
* 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
2
1
1

41. Number of public financial disclosure filers reported in calendar year 2016 to the Attorney General for failure to file.

  • Enter total
0

42. How many requests for public financial disclosure reports did you receive in 2016.

  • Enter total
239

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

    • 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
No (go to Part 9)

48. Which system does your agency use?

  • Select one

    • Specify Other
      NA

49. Indicate your fiscal year 2016 actual and fiscal year 2017 projected 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.

    a) Total FY 2016 actual costs
$

    b) Total FY 2017 projected costs
$

    c) amount paid to a non-federal vendor in 2016
$

    d) amount projected to be paid to a non-federal vendor in 2017
$

    e) amount paid to a federal agency in 2016
$

    f) amount projected to be paid to a federal agency in 2017
$

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

    h) amount projected for all internal costs associated with operating an e-filing system (e.g., FTE, overhead, etc.) in FY 2017
$

    i) number of public financial disclosure filers who filed in electronically in 2016

    j) number of public financial disclosure filers projected to file electronically in FY 2017

    k) number of confidential financial disclosure filers who filed electronically in FY 2016

    l) number of confidential financial disclosure filers projected to file electronically in FY 2017

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

  • Check all that apply

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

  • Additional Comments
    Question 37: One filer was not alerted to his filing obligation upon becoming a commissioned officer in 2016. He filed his report subsequent to November 15. Question 40: White House Office public financial disclosure filers were provided an extension on November 15, 2016, for transactions occurring in November and December, as such information is required to be reported on those individuals’ January termination reports. Termination reports for White House Office filers were pre-reviewed by the Office of the White House Counsel during November and December prior to certification in January. Transaction information was disclosed and vetted for potential conflicts of interest during pre-review.

PART 9. CONFIDENTIAL FINANCIAL DISCLOSURE

51. Report the number of confidential financial disclosure reports required to be filed by December 31, 2016, excluding SGEs, and the number of reports actually filed by December 31, 2016.

  • Confidential financial disclosure reports required to be filed in CY 2016:

# Required to File
# Filed
# Filed
# Filed
# Filed
(by 12/31)
OGE Form 450
OGE Form 450A
OGE approved alternate form
Total
52
52
0
0
52

    Example: For new entrant reports: If an employee starts the agency on December 15, 2016, 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 2017 Questionnaire’s new entrant numbers in 2018.

    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

52. Number of OGE 450, 450A, or OGE-approved alternative forms granted filing extensions in 2016.

  • Enter number
13

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

  • Check all that apply
Repeated reminders to the filer

    • Specify Other
      NA

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

  • Additional Comments
    Question 51: White House Office updated its confidential disclosure policy at the end of 2015, resulting in an increase in covered officials.

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 2016.

  • 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 278e) report in 2016.

  • 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 2016.

  • Enter number

Don’t know/don’t track

57. Number of remedial actions taken because of information on a periodic transaction report in 2016.

  • 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 2016.

  • Enter number
0

59. Number of § 208(b)(1) waivers provided to OGE in 2016.

  • Enter number
0

60. Number of § 208(b)(3) waivers granted in 2016.

  • Enter number
0

61. Number of § 208(b)(3) waivers provided to OGE in 2016.

  • 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 2016. 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
0

    Subpart B
0

    Subpart C
0

    Subpart D
0

    Subpart E
0

    Subpart F
0

    Subpart G
0

    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, 208, and 209 in 2016. 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
0

    18 U.S.C. §205
0

    18 U.S.C. §208
0

    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 2016.

  • 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, General Counsel

    • 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
    Questions 54-57: The Office of the White House Counsel provides individual guidance to every person entering a public filing position, including guidance on 18 U.S.C. 208 and directions on what steps the employee must take to comply with the ethics laws, such as recusal, divestiture, resignation, etc., which is based on the assets and relationships disclosed on the employee's new entrant form. Pursuant to longstanding White House policy, full-time employees in the White House Office are generally barred from holding outside positions.

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
No (go to #72)

68. Number of FACA advisory committees.

  • Enter number

69. Number of FACA advisory committee members.

  • Enter number

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

  • Enter number

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

  • Enter number


72. Does your agency have any SGEs (as of December 31, 2016)?

  • Select Yes or No
Yes (go to #73)


73. Number of Special Government Employees (SGEs) as of December 31, 2016.

  • Enter number
1

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

  • Select Answer
No

    • Specify why
      NA

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

  • Select Answer
Not applicable (specify why below)

    • Specify why
      See Additional Comments Section.

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
Not Applicable (skip to #78)

77. If yes, which office provides the training?

  • Enter office

78. Report the number of SGE public and confidential financial disclosure reports required to be filed by December 31, 2016 and the number of reports actually filed by December 31, 2016.

  • Financial disclosure reports required to be filed by SGEs in CY 2016:

Type of SGE
Confidential Reports
(OGE Form 450 or OGE- Approved Alternative Form)
Public Reports
(OGE Form 278e)
required
filed
required
filed
Advisory Committee Members (FACA)
0
0
0
0
Advisory Committee Members (non-FACA)
0
0
0
0
Experts/Consultants
1
1
0
0
Board Members
0
0
0
0
Commissioners
0
0
0
0
Other
0
0
0
0
TOTAL
1
1
0
0

    Example: For new entrant reports: If an employee starts with the agency on December 15, 2016, 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 2017 Questionnaire’s new entrant numbers in 2018.
  • 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 278e 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
    Question 75: White House Office does not have written procedures for designating SGEs. The Office of White House Counsel is consulted prior to the hiring of Experts and Consultants and a determination of the person's status is made based on OGE guidance.

ADDITIONAL QUESTIONNAIRE COMMENTS:

  • Additional Comments
    Response data in sections 4, 5, 7 (except for question 35), 9, 10, and 11 covers the period between January 1, 2016, and December 31, 2016. Response data in sections 6, 8, and question 35 (relating to the number of requests for financial disclosure reports WHO has received in 2016) covers the period between January 1, 2016, and November 15, 2016.

      OGE Form 450A
0
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