2018 AGENCY ETHICS PROGRAM QUESTIONNAIRE

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PART 1. INTRODUCTION

Executive branch agencies are required to submit an annual report to the United States Office of Government Ethics (OGE) concerning certain aspects of their ethics programs (Section 402(e)(1) of the Ethics in Government Act of 1978, as amended). Your response to OGE’s Annual Ethics Program Questionnaire (Questionnaire) serves as your annual report.

OGE uses the data collected through the Questionnaire in many ways, including sharing information about the entire executive branch ethics program with the public, Congress, and the ethics community. OGE also uses the information to carry out its oversight role, to gain knowledge about individual 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, 2019. (5 C.F.R. 2638.207(a)). However, because of the government shutdown, OGE has extended the deadline to March 15, 2019.

PART 2. INSTRUCTIONS

Your response to this Questionnaire should reflect the 2018 calendar year (i.e., 1/1/2018 through 12/31/2018), 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 2017 report. After OGE has reviewed your Questionnaire submission, you may be contacted for follow-up.

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If you have any questions, please contact Wendy Pond at wgpond@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; 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 not enlisted members, of the uniformed services.

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

PART 4. ORGANIZATION/RESOURCES

1. Agency

  • Department of the Interior

2. Employees

  • Number of full-time agency employees as of December 31, 2018
61169

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

a. Vacant (As of December 31, 2018)?
No

b. Time in current DAEO position
Less than 1 year

c. Total years performing ethics duties
10 or more years

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

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

f. Number of reporting levels between the DAEO and the agency head. (Zero is not a valid response; there is always at least 1 level.)
2

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

a. Vacant (As of December 31, 2018)?
No

b. Time in current ADAEO position
Less than 1 year

c. Total years performing ethics duties
10 or more years

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

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

5. Number of employees, including the DAEO and ADAEO, who performed ethics program duties in 2018 (e.g., financial disclosure, education and training, advice and counseling, program administration).

Number of employees by hours worked each week
Duty Station
Less than 1 hour per week
(up to .025 FTE*)
1-10 hours per week
(up to .25 FTE*)
11-20 hours per week
(up to .5 FTE*)
21-30 hours per week
(up to .75 FTE*)
31-40 hours per week
(up to 1 FTE*)
TOTAL
a. D.C. Metro area
4
4
2
2
25
37
b. Outside the D.C. Metro area
7
22
2
0
11
42
TOTAL
11
26
4
2
36
79

* FTE = Full Time Equivalent

Example: The table below provides an example of an agency with 13 employees that performed ethics
program duties in 2018.

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

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

  • Check all that apply

IT services (e.g., developing or supporting electronic filing systems, applications, websites, and/or databases, etc.), Administrative support (e.g., tracking filing or training requirements, sending reminders, data entry, etc.), Other (please describe)

  • Specify Other
    Contractor staff provided assistance to the Departmental Ethics Office on FOIA requests for ethics program records.

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

  • Select Yes or No
No

  • If yes above, please provide the name of the federal agency or entity and describe the services or support provided.

8. Does your agency's ethics program need additional resources? Check all that apply.

  • Select type of resources

    Budgetary, Human Capital, Technology

  • Specify Other

9. Did the agency head meet with the ethics staff to discuss the strengths and weaknesses of the ethics program in 2018?

  • Select Yes, No, or Not Applicable
Yes

  • If Not applicable above, specify why

10. Did your agency (e.g., ethics office, Inspector General, General Counsel, etc.) conduct a self-assessment to evaluate any aspect of the ethics program in 2018?

  • Select Yes or No
Yes


11. To whom were the results reported? Select all that apply.

    Agency Head, DAEO, Other

  • Specify Other
    Bureau/Office Head

12. What kind of changes resulted from the assessment?

    Programmatic changes (please describe)

  • Please Describe: (Please describe programmatic or policy changes; Specify why no changes resulted; Specify why not applicable)
    DOI Leadership approved a restructuring of the Departmental Ethics Office, and committed to significantly increase staffing, training, and budget support across the DOI Ethics Program.

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

Collection of confidential financial disclosure reports (5 C.F.R. 2638.104(c)(8)(i)), Collection of public financial disclosure reports (5 C.F.R. 2638.104(c)(8)(i)), Follow up with delinquent confidential financial disclosure filers (DA-09-03-92), Follow up with delinquent public financial disclosure filers (DA-09-03-92), Public availability of public financial disclosure reports (5 C.F.R. 2638.104(c)(8)(i)), Review/evaluation of confidential financial disclosure reports (5 C.F.R. 2638.104(c)(8)(i)), Review/evaluation of public financial disclosure reports (5 C.F.R. 2638.104(c)(8)(i)), Issuance of notice of ethical obligations in written offers of employment (5 C.F.R. 2638.303), Provision of initial ethics training (5 C.F.R. 2638.304), Issuance of ethics notice to new supervisors (5 C.F.R. 2638.306)

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

  • Additional Comments
    #5: Please note that the employees identified in this chart include a significant number of part-time Assistant Ethics Counselors (AECs) who work only limited hours on ethics matters as a collateral duty and are not full-time ethics specialists. A number of Bureau and Office ethics programs discontinued utilizing part-time AECs to provide services to their respective ethics program in 2018. #10: Please note that only a limited number of Bureau and Office ethics programs completed self-assessments in 2018.

PART 5. EDUCATION AND TRAINING

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

    Some of the offices provided the certification to the DAEO (explain why not all offices)

  • Please Explain why not all offices:
    Certain Bureau and Office ethics programs experienced a breakdown in communication and coordination with DOI HR Offices, which are tasked with providing the ethics notices. This issue will be addressed in those Bureau and Office ethics programs in 2019.

15. How many new agency leaders, as defined in 5 C.F.R. 2638.305(a), were required to receive ethics briefings by December 31, 2018?

  • Total Number
32
    • a. How many of those leaders received their briefing within 15 days of their appointment?
32
    • b. How many of those leaders received their briefing beyond the 15-day requirement?
0
    • c. How many of those leaders have yet to receive their briefing as of today?
0

    • If applicable, please explain why some of the leaders received their briefing beyond the 15-day requirement or have yet to receive their briefing.

16. How many employees, including SGEs, were required to receive Initial Ethics Training (IET) by December 31, 2018 (5 C.F.R. 2638.304)? Include employees who were excluded, under 5 C.F.R. 2638.304(a), from the requirement to receive the interactive portion of the IET.

  • Number required
4760

    • a. How many of those employees received IET within the 3-month requirement?
2605

    • b. How many of those employees received IET beyond the 3-month requirement?
290

    • c. How many of those employee have not received IET as of today?
1865

  • If applicable, please explain why some employees received IET beyond the 3-month requirement or have yet to receive IET.
    Certain DOI employees did not receive IET within the 3-month requirement due to a variety of factors across certain Bureau and Office ethics programs including: a lack of ethics program resources, a breakdown in communication and coordination with HR, ethics program staff turnover leading to the loss of institutional memory, failure to develop and implement appropriate training and tracking procedures and practices, the transition to a new online training platform, and the partial government shutdown. For the same reasons, certain Bureau and Office ethics programs are not able to accurately identify the number of employees who actually received IET in 2018. Therefore, the 1,865 employees identified above as having not received IET as of today may have received IET, but this can not be confirmed at this time. DOI Leadership has made a significant investment across the DOI Ethics Program which will help ensure that Bureau and Office ethics programs timely provide IET in 2019.

    Example: If an employee started at the agency on December 15, 2018, and the employee completed IET prior to the end of the calendar year, include the employee in your required and received numbers. If, on January 1, the employee has not completed IET, do not count that employee in your required numbers. Instead, include the employee in your 2019 Questionnaire’s numbers in 2020.

17. How many non-supervisory positions at or below the GS-8 grade level, or the equivalent, were excluded from the requirement to receive the interactive portion of their initial ethics training during 2018, pursuant to 5 C.F.R. 2638.304(a)? (i.e., they received only written materials)

  • Number
0

18. Did all of the office(s) delegate the responsibility for providing initial ethics training (IET) provide the required certification to the DAEO, pursuant to 5 C.F.R. 2638.310?

    Not applicable because all IET was provided by an office under the DAEO's supervision

  • Please Explain why not all offices:

19. Did the head of the agency complete either initial ethics training and/or annual ethics training in 2018?

  • Select One
Yes

  • Please specify why if "No" or "Not Applicable"

20. Required Annual Ethics Training

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

    Executive Schedule Level I or Level II public filers (OGE Form 278e)
2
2

    All other public filers (OGE Form 278e)
384
372

    Confidential filers (OGE Form 450, 450A, and OGE-approved alternative confidential financial disclosure forms)
10165
9516

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

TOTAL
10551
9890

  • If applicable, please explain discrepancies between the number of employees who were required to receive training and the number of employees who received training:
    Certain DOI employees did not receive required annual training due to a variety of factors across certain Bureau and Office ethics programs including: a lack of ethics program resources, ethics program staff turnover leading to the loss of institutional memory, failure to develop and implement appropriate training and tracking procedures and practices, the transition to a new online training platform, and the partial government shutdown. Please note that certain employees across the Bureaus and Offices did not receive annual ethics training in 2018 due to extended medical and military leave, detail, resignation, and/or retirement. DOI Leadership has made a significant investment across the DOI Ethics Program which will help ensure that Bureau and Office ethics programs timely provide annual ethics training in 2019.

21. Did you provide annual ethics training to other employees not otherwise required by regulation to receive training (i.e., any other employees not covered by the chart above)?

  • Select Yes or No
Yes (please specify who)

  • If Yes above, please specify who:
    Certain Bureau and Office ethics programs provided annual training to all employees of their respective Bureau or Office.

22. Did you provide additional, specialized ethics training during 2018 (i.e., beyond any required initial ethics training or annual ethics training)?

  • Select Yes or No
Yes

23. Which groups did you target for additional, specialized ethics training?

  • Check all that apply

Procurement Officials, Supervisors
Other (specify all)

    • Specify Other
      Certain Bureau and Office OGE 278e filers and Targeted Hatch Act Training for certain Bureau and Office employees.

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

  • Additional Comments
    #18: All IET was provided by DOI Bureau and Office ethics programs under the leadership of DOI’s DAEO per Secretarial Order #3288. #21-23: A number of DOI Bureau and Office ethics programs provided additional ethics training to the groups identified in #23, including certain Bureau and Office ethics programs who provided training to all employees of their respective Bureau or Office. As a result, over approximately 15,500 DOI employees from various Bureaus and Offices, who were not required to receive annual ethics training, were provided with annual ethics training in 2018.

PART 6. ADVICE, COUNSELING, AND REMEDIES

24. From the list below, select the three topics that your employees most frequently sought guidance on in 2018. Please rate them in order, such that the first topic on which employees sought guidance the most frequently.

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

  • Selection 1
Outside employment/activities
  • Selection 2
Financial Disclosure Reporting
  • Selection 3
Gift acceptance

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

25. Number of notification statements of negotiation or recusal under section 17(a) of the STOCK Act submitted to the ethics office in 2018?

  • Enter total
30

26. Number of public financial disclosure filers who, in 2018, took specific remedial actions (e.g., divestiture, resignation from outside position, written disqualification, 18 U.S.C. § 208 waiver, reassignment, etc.) because of information on a new entrant, annual, periodic transaction, or termination report.

  • Enter number
3

27. Number of individual remedial actions taken in 2018 because of information on a new entrant, annual, periodic transaction, or termination public financial disclosure report.

      a. Recusals
      Don’t know/don’t track

      b. Divestitures
42

      c. Resignations from outside positions
      Don’t know/don’t track

      d. Reassignments
      Don’t know/don’t track

      e. Other not listed (specify)
      Don’t know/don’t track

      • Specify Other
        NA

28. Number of 18 U.S.C. 208 waivers granted in 2018:

Number Granted in 2018
Number Sent to OGE
    a. 208(b)(1) waivers
1
1
    b. 208(b)(3) waivers
0
0

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

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

  • Additional Comments
    #26-27: Most DOI Bureau and Office ethics programs do not know or track this information. To the extent that this information is currently known or tracked, it is reported. As noted previously, DOI Leadership committed to significantly increase staffing, training, and budget support across the DOI Ethics Program and this will help the Bureau and Office ethics programs better track remedial actions in 2019.

PART 7. FINANCIAL DISCLOSURE PROGRAM MANAGEMENT AND ELECTRONIC FILING SYSTEMS

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

    • a. Public Filers
In Most Cases

    • If not applicable, specify why.

    • b. Confidential Filers
In Most Cases

    • If not applicable, specify why.

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

  • Public Filers
In Most Cases

  • If not applicable, specify why.

31. Did your agency use an electronic financial disclosure filing system (e-filing system) in calendar year 2018? Note: This includes Integrity.

  • Select Yes or No
Yes

32. Which system did your agency use?

  • Select one
Integrity AND Other (specify)

    • Specify Other
      FDOnline

33. Indicate for which forms your agency used the other (non-Integrity) e-filing system.

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


34. Indicate your fiscal year 2018 actual costs for using the other (non-Integrity) e-filing system. Note: Because OGE does not charge fees to use Integrity, there are no reportable costs associated with the use of Integrity.

Public (do not include Integrity)Confidential
a. Amount paid to a non-federal vendor in FY 2018Don’t know/don’t track

324000

b. Amount paid to a federal agency in FY 2018
0
0

c. Amount for all internal costs associated with operating an e-filing system (e.g., FTE, overhead, etc.) in FY 2018
0
0

  • Please explain "Don’t know/don’t track" answer above
    The figure listed for Confidential filers above reflects the combined cost of FDOnline for both DOI Public and Confidential filers.

35. Number of financial disclosure filers, not reports, who filed electronically in fiscal year 2018, excluding filers in Integrity.

    a. public financial disclosure filers
431

    b. confidential financial disclosure filers
10479

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

  • Additional Comments
    #29-30: Certain Bureau and Office ethics programs experienced a breakdown in communication and coordination with DOI HR Offices, which led to deficiencies in notifications about filers. This issue will be addressed in those Bureau and Office ethics programs in 2019.

PART 8. PUBLIC FINANCIAL DISCLOSURE

36. Report the number of public financial disclosure reports (OGE Form 278e) required to be filed by December 31, 2018, excluding SGEs, and the number of reports actually filed (i.e., received in hand) by December 31, 2018.

OGE Form 278e Reports
PAS2
Non-Career SES3
Career SES3
Schedule C
Other4
TOTAL
a. Nominee/New EntrantRequired
4
13
23
17
20
77
Filed
4
13
21
17
19
74
b. AnnualRequired
5
28
219
35
71
358
Filed
5
28
211
35
68
347
c. TerminationRequired
2
6
34
5
19
66
Filed
2
6
29
4
19
60
d. Combination1Required
0
0
1
1
0
2
Filed
0
0
1
1
0
2
    Total
Required
11
47
277
58
110
503
Filed
11
47
262
57
106
483

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


Example for new entrant and termination reports: If an employee started/left the agency on December 15, 2018, and the employee filed a new entrant/termination report prior to the end of the calendar year, include the report in your required and filed numbers. If, on January 1, the employee has not filed a new entrant/termination report, do not count that report in your required numbers. Instead, include the employee in your 2019 Questionnaire numbers in 2020.

  • If applicable, please explain discrepancies between the number of reports required to be filed and the actual number of reports filed.
    The discrepancies are a result of a variety of factors across certain Bureau and Office ethics programs including: a lack of ethics program resources, a breakdown in communication and coordination with HR, ethics program staff turnover leading to the loss of institutional memory, and the failure to develop and implement appropriate OGE 278e filer identification, report collection, and tracking procedures and practices. DOI Leadership has made a significant investment across the DOI Ethics Program which will help ensure that Bureau and Office ethics programs better address these discrepancies going forward.

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

    • Periodic Transaction Reports Filed
276
Note: Count the total number of periodic transaction reports filed. Example 1: If two employees each file 5 periodic transaction reports during the calendar year, report “10” in the table above. Example 2: If an employee files one report each month, each report is counted separately. Report “12” in the table.

38. Extension and late fees for new entrant, annual, termination, and combination public financial disclosure reports, and periodic transaction reports, excluding those for reports filed by SGEs.

Granted filing extension
Granted waiver of late filing fee
Paid late filing fee
    a. Number of OGE Form 278e Reports
23
1
2
    b. Number of OGE Form 278-T Reports
0
1
8

39. Number of public financial disclosure filers reported in calendar year 2018 to the Attorney General for failure to file.

  • Enter total
0

40. How many requests for public financial disclosure reports did you receive in 2018? Count each OGE Form 201 as one request, even if it contains a request for documents for multiple individuals.

  • Enter total
28

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

  • Additional Comments

PART 9. CONFIDENTIAL FINANCIAL DISCLOSURE

41. Report the number of confidential financial disclosure reports required to be filed by December 31, 2018, excluding SGEs, and the number of reports actually filed by December 31, 2018.

Required
Filed
10598
450
4593
450A
5876
OGE-approved alternate form
0
Total
10598
10469

    Example for new entrant reports: If an employee started at the agency on December 15, 2018, and filed a new entrant report prior to the end of the calendar year, include the report in your required and filed numbers. If, on January 1, the employee has not filed a new entrant report, do not count that report in your required numbers. Instead, include the employee in your 2019 Questionnaire’s new entrant numbers in 2020.

    If applicable, please explain discrepancies between the number of reports required to be filed and the actual number of reports filed.
  • Explain, if applicable
    The discrepancies are a result of a variety of factors across certain Bureau and Office ethics programs including: a lack of ethics program resources, a breakdown in communication and coordination with HR, ethics program staff turnover leading to the loss of institutional memory, and the failure to develop and implement appropriate OGE 450 filer identification, report collection, and tracking procedures and practices. DOI Leadership has made a significant investment across the DOI Ethics Program which will help ensure that Bureau and Office ethics programs better address these discrepancies going forward.

42. Number of OGE 450, 450A, or OGE-approved alternative forms granted filing extensions in 2018.

  • Enter number
108

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

  • Additional Comments

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

43. Number of disciplinary actions taken based wholly or in part upon violations of the Standards of Conduct provisions (5 C.F.R. part 2635) or your agency's supplemental Standards (if applicable) in 2018. For purposes of this question, disciplinary actions include removals, demotions, suspensions, and written reprimands or their equivalents.

  • Enter number
0

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

    Subpart A (General Provisions)

    Subpart B (Gifts from Outside Sources)

    Subpart C (Gifts between Employees)

    Subpart D (Conflicting Financial Interests)

    Subpart E (Impartiality in Performing Official Duties)

    Subpart F (Seeking Other Employment)

    Subpart G (Misuse of Position)

    Subpart H (Outside Activities)

44. Number of disciplinary actions taken based wholly or in part upon violations of the criminal conflict of interest statutes, 18 U.S.C. sections 203, 205, 208, and 209, in 2018. For purposes of this question, disciplinary actions include removals, demotions, suspensions, and written reprimands or their equivalents.

  • Enter number
5

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

    18 U.S.C. section 203 (Compensation in Matters Affecting the Government)
0

    18 U.S.C. section 205 (Claims Against and Matters Affecting the Government)
0

    18 U.S.C. section 208 (Acts Affecting a Personal Financial Interest)
5

    18 U.S.C. section 209 (Supplementation of Salary)
0

45. Number of referrals made to the Department of Justice of potential violations of the criminal conflict of interest statutes (18 U.S.C. sections 203,205, 207, 208, 209), failure to file or filing false public financial disclosures (5 U.S.C. app. section 104 or 18 U.S.C. section 1001), a civil matter involving outside earned income under 5 U.S.C. app. section 501, or outside activities under 5 U.S.C. app. section 502 in 2018.

  • Enter number
2

DOJ Referrals

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

    b. How many of those referrals were declined for prosecution?
2

    c. How many of those referrals were pending DOJ’s decision as of December 31, 2018?
0

Disciplinary Action

    a. How many of those referrals resulted in disciplinary or corrective action?
1

    b. How many of those referrals resulted in a determination not to take disciplinary or corrective action?
1

    c. How many of those referrals are pending a determination as to whether disciplinary or corrective action will be taken?
0

46. Did your agency submit all referral(s) and disposition(s) of the referral(s) to OGE via OGE Form 202 (as required by 5 C.F.R. 2638.206(a))?

  • Select answer
Yes

  • Please Specify Why
    `

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

  • Additional Comments
    #43-44: Most DOI Bureaus/Offices do not know or track this information. To the extent that this information is currently tracked, it is reported. As noted previously, DOI Leadership committed to significantly increase staffing, training, and budget support across the DOI Ethics Program and this will help the Bureaus and Offices better track disciplinary actions and referrals in 2019
    Q46: Based on a review of available information, the DOI has submitted all required referrals and dispositions of referrals to OGE. The Departmental Ethics Office and the OIG are collaboratively working to ensure that referrals and dispositions of referrals are tracked and provided to OGE in the format required.

PART 11. ETHICS PLEDGE ASSESSMENT

47. Were any full-time non-career appointees (e.g., Presidentially Appointed Senate Confirmed (PAS), Presidentially Appointed (PA), non-career Senior Executive Service (SES), Schedule C, etc.) appointed to or by your agency from January 1 through December 31, 2018? NOTE: For guidance on what constitutes a full-time non-career appointee for purposes of the Ethics Pledge, see LA-17-03 available at www.oge.gov.

  • Select answer
Yes

48. For each category of appointee, provide the number of full-time non-career appointees appointed between January 1 and December 31, 2018, and indicate the number who did and did not sign the Ethics Pledge. NOTE: Please include all appointees who did not sign, regardless of whether or not they were required to sign. Additional explanatory information is requested in the next question.

Number of Full-Time Non-Career Appointees
Type of Full-Time Non-Career Appointees
by Category
PAS
PA
Non- career SES
Schedule C
Other
Total
a. Appointed 01/01/2018 - 12/31/2018
3
0
20
25
0
48
      i. Signed the Ethics Pledge
3
0
20
25
0
48
      ii. Did not sign the Ethics Pledge
0
0
0
0
0
0

  • If applicable, please explain discrepancies between the number appointed and the number who signed or did not take the Pledge.

49. For each appointee who did not sign the Ethics Pledge, find the appropriate rationale(s) and indicate the total number of appointees who fit into that category.

Rationale for Not Signing the Ethics Pledge
Number and Type of Full-Time Non-Career Appointees
Who Did Not Sign the Ethics Pledge
PAS
PA
Non- career SES
Schedule C
Other
Total
a. Occupy an exempt non-policymaking position (Schedule C or other comparable authority)
0
0
0
0
0
0
b. Appointed without break in service after serving in another position for which the Ethics Pledge was already signed
0
0
0
0
0
0
c. Other (explain below)
0
0
0
0
0
0

  • If other, please explain.

50. How many appointees appointed between January 1 and December 31, 2018 and subject to the Ethics Pledge were registered lobbyists during the two years prior to their appointment?

  • Enter number
2

51. Section 3 of Executive Order 13770 provides a waiver mechanism for the restrictions contained in the Ethics Pledge. Indicate below how many waivers were granted to appointees in your agency in 2018, the names of these individuals granted waivers in 2018, and which of the Pledge paragraphs were implicated.

Number of Ethics Pledge Waivers Granted
By Pledge Paragraph
Name(s) of Individual(s) Granted Ethics Pledge Waivers
Paragraph 1
0
Paragraph 2
0
Paragraph 3
0
Paragraph 4
0
Paragraph 5
0
Paragraph 6
0
Paragraph 7
0
Paragraph 8
0
Paragraph 9
0
Other
(please explain)
0

  • If other, please explain

52. Were there any violations of the Ethics Pledge during 2018?

  • Select Yes or No
No (skip to next part)

53. Please provide information on enforcement actions taken as a result of violations of the Ethics Pledge.

  • Please type in the box below.

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

  • Please type in the box below.
    #52-53: DOI has received certain information indicating that Ethics Pledge violations may have occurred in 2018 and is currently reviewing available information to determine whether there were any violations of the Ethics Pledge.

PART 12. SPECIAL GOVERNMENT EMPLOYEES (SGEs)

54. How many Special Government Employees (SGEs) did your agency have, in total, during calendar year 2018?

  • Enter number
135

55. How many SGEs serving on a board, commission, or committee were required to receive Initial Ethics Training (IET) by December 31, 2018 (5 C.F.R. 2638.304(b)(2))?

  • Enter number
15

    a. How many of those SGEs received IET before or at the beginning of the first meeting?
15

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

    c. How many of those SGEs have not received IET as of today?
0

    • If applicable, please explain why some SGEs received IET after the first meeting or have yet to receive IET.

56. Report the number of SGE public and confidential financial disclosure reports required to be filed by December 31, 2018 and the number of reports actually filed by December 31, 2018.

Type of SGE
Confidential Reports
(OGE Form 450 or OGE- Approved Alternative Form)
Public Reports
(OGE Form 278e)
required
filed
required
filed
a. Advisory Committee Members (FACA)
37
24
0
0
b. Advisory Committee Members (non-FACA)
0
0
0
0
c. Experts/Consultants
1
1
0
0
d. Board Members
4
4
0
0
e. Commissioners
76
47
0
0
f. Other
3
3
0
0
TOTAL
121
79
0
0

    Example for new entrant and termination reports: If an employee started with the agency on December 15, 2018, and filed a new entrant report prior to the end of the calendar year, include the report in your required and filed numbers. If, on January 1, the employee has not filed a new entrant report, do not count that report in your required numbers. Instead, include the employee in your 2019 Questionnaire numbers in 2020.

  • If applicable, please explain discrepancies between the number of reports required to be filed and the actual number of reports filed.
    The discrepancies are a result of a variety of factors across certain Bureau and Office ethics programs including: a lack of ethics program resources, a breakdown in communication and coordination with HR, ethics program staff turnover leading to the loss of institutional memory, and the failure to develop and implement appropriate SGE filer identification, report collection, and tracking procedures and practices. DOI Leadership has made a significant investment across the DOI Ethics Program which will help ensure Bureau and Office ethics programs better address these discrepancies going forward.

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

  • Enter number
14

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

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

      b. Number of OGE Form 450 or OGE-Approved Alternative Forms
1

ADDITIONAL COMMENTS FOR PART 12. Please indicate the question number to which the comment corresponds.

  • Additional Comments

ADDITIONAL QUESTIONNAIRE COMMENTS:

  • Additional Comments