2019 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 and 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, 2020. (5 C.F.R. 2638.207(a)). However, because February 1 falls on a Saturday, responses will be due February 3, 2020.

PART 2. INSTRUCTIONS

Your response to this questionnaire should reflect the 2019 calendar year (i.e., 1/1/2019 through 12/31/2019), except where specified. The answers provided should reflect the aggregate data for your agency. 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 2018 report. After OGE has reviewed your questionnaire submission, you may be contacted for follow-up.

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If you have any further 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 Treasury

2. Employees

  • Number of full-time agency employees as of December 31, 2019
90164

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

a. Vacant (as of December 31, 2019)?
No

b. Time in current DAEO position
1 - 4 years

c. Total years performing ethics duties
5 - 9 years

d. Percent of time spent on ethics
0-25%

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.
3

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

a. Vacant (as of December 31, 2019)?
No

b. Time in current ADAEO position
Less than 1 year

c. Total years performing ethics duties
5 - 9 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 2019 (e.g., financial disclosure, education and training, advice and counseling, and 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
56
90
7
8
9
170
b. Outside the D.C. Metro area
61
69
5
3
2
140
TOTAL
117
159
12
11
11
310

* FTE = Full Time Equivalent

Example: The table below provides an example of an agency with 13 employees that performed ethics
program duties in 2019.

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
Not applicable (no contractors supported the ethics program)



  • Please describe IT support (optional)
    NA

  • Please describe administrative support (optional)
    NA

  • Please describe substantive support (optional)
    NA

  • Specify Other
    NA

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

  • Select Yes or No
No

  • Please provide the name of the federal agency or entity:

  • Describe the services or support received:

8. Did your agency provide ethics program services or support for any board, commission, or agency that is independant of your agency?

  • Select Yes or No
Yes

  • Please provide the name of the board, commission, or agency:
    Women’s Suffrage Centennial Commission

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

  • Select type of resources
    No additional resources needed

  • Specify Other
    NA

10. Did the agency head meet with the ethics staff to discuss the strengths and weaknesses of the ethics program in 2019?

  • Select Yes, No, or Not Applicable
Yes

  • If Not applicable above, specify why
    NA

11. Did your agency (e.g., ethics office, Inspector General, General Counsel, etc.) evaluate any aspect of the ethics program in 2019 (5 C.F.R. 2638.104(c)(16))?

  • Select Yes or No
Yes

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

    Agency Head, DAEO, General Counsel, Other

  • Specify Other
    DO: internal ethics staff at one bureau: senior executive team at another bureau: Director and Assistant Director, Administrative and Internal Law Division at another bureau: Chief Counsel/Deputy Ethics Officer

13. What kind of changes resulted from the assessment?

    Programmatic changes (please describe), Policy changes (please describe)

  • Please Describe: (Please describe programmatic or policy changes; Specify why no changes resulted; Specify why not applicable)
    Programmatic: DO: Enhanced Hatch Act training bureaus: improved confidential financial disclosure processes outside activity process assignment of ethics training in electronic training management system enhanced guidance on procures and ethics roles and responsibilities.
    Policy changes: Enhanced processes for outside activities and confidential financial disclosure.
    No changes for some: In DO, we intend to enhance our invitation review process through development of an electronic template and engage in more ethics programmatic/educational outreach. At one bureau, no issues found.

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

Financial disclosure program, including for the filing, review, and when applicable, public availability 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
    DO=Departmental Offices (headquarters).
    Q2: This figure includes 11,873 F/T seasonal
    Q5: Note that the ADAEO who spent 100% of time on ethics departed in early May 2019 but is counted as 1 FTE, representative of a composite of people who worked on ethics for part of the year and are not counted. (One other attorney who worked P/T on ethics, departed in March 2019 and is not counted, and we hired 2 new ethics attorneys very late in 2019 who are not counted.) Ethics interns assist DO with data entry and other program-related tasks during most of the year.
    Q6: N/A for most bureau but some, including Departmental Offices (DO/HQ) indicated IT services.
    Q9: No for most bureaus.
    Q12: Agency head response refers to bureau agency head.

PART 5. EDUCATION AND TRAINING

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

    All of the offices provided the written confirmation to the DAEO (skip to #17)

  • Please Explain why not all offices:

16. Did written offers of employment for positions covered by the Standards of Conduct include the information required by 5 C.F.R. 2638.303?

  • Please Explain why not all offers:

  • Please Explain:

17. How many new agency leaders, as defined in 5 C.F.R. 2638.305(a), were required to receive ethics briefings by December 31, 2019?

Total Number
9
    • a. How many of those leaders received their briefing within 15 days of their appointment?
9
    • 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.

18. How many employees, including SGEs, were required to receive Initial Ethics Training (IET) by December 31, 2019 (5 C.F.R. 2638.304)? Include employees who were excluded, under 5 C.F.R. 2638.304(a)(2), from the requirement to receive the interactive portion of the IET.

Number required
4339
  • a. How many of those employees received IET within the 3-month requirement?
4198
  • b. How many of those employees received IET beyond the 3-month requirement?
54
  • c. How many of those employee have not received IET as of today?
87

Example: If an employee started at the agency on December 15, 2019, 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, 2020, the employee has not completed IET, do not count that employee in your required numbers. Instead, include the employee in your 2020 questionnaire response to be filed in 2021.

  • If applicable, please explain why some employees received IET beyond the 3-month requirement or have yet to receive IET.
    Employees departed prior to completing training employees on extended leave follow-up pursued with others. At one bureau, training assignments were delayed and make-up training is ongoing for IET because of transition to a new interactive system.

19. Did the office(s) delegated the responsibility for providing initial ethics training (IET) provide the required written confirmation to the DAEO, pursuant to 5 C.F.R. 2638.310?

    Written confirmation not required because all IET was provided by an office under the DAEO's supervision

  • Please Explain why not all offices:

20. Did the head of the agency complete either initial ethics training and/or annual ethics training in 2019?

  • Select One
Yes

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

21. Required Annual Ethics Training

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

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

    b. All other public filers (OGE Form 278e)
537
534

    c. Confidential filers (OGE Form 450 and OGE-approved alternative confidential financial disclosure forms)
9548
9438

    d. 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
10087
9974

  • If applicable, please explain discrepancies between the number of employees who were required to receive training and the number of employees who received training:
    Some employees were in leave status (e.g., LWOP, military or other leave). 92 of the 113 OGE 450 filers did not receive timely ethics training due to transition of a training management system which disrupted system availability and reports generated by system for follow-up with filers. At another bureau, one regionally located public filer received training in late Jan. 2020, and training for other filers was delayed due to plant production schedule and manufacturing constraints. Finally, another filer transferred to another federal agency before receiving training. Make-up sessions in progress.

22. If your agency assessed risk to help inform the content, format, and/or timing of ethics education and communications, select all that apply (see PA-19-05 for reference):


Reviewed advice logs for common issues, Discussed upcoming work and agency priorities with senior staff, Talked to program managers about risks inherent in their work, Talked to employees about the ethics concerns they encounter in the workplace.
Other (please specify)

  • Please explain other:
    Not all bureaus assessed risk.

23. If your agency evaluated the effectiveness of your ethics education and/or communication, select all that apply (see PA-19-05 for reference):


Conducted self-assessments to ensure that required employees are receiving training, Held discussions with agency leaders and employees to evaluate whether the training and communications they received have supported them in managing ethics risks.
Other (please specify)

  • Please explain other:
    Not all bureaus evaluated ethics education effectiveness.

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

  • Additional Comments

PART 6. ADVICE, COUNSELING, AND REMEDIES

24. From the list below, select the three topics that your employees most frequently sought guidance on in 2019. 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
Gift acceptance
  • Selection 2
Financial Disclosure Reporting
  • Selection 3
Outside employment/activities

  • 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 2019 (see 5 C.F.R. 2635.602(a)):

  • Enter total
82

26. Number of 18 U.S.C. 208 waivers granted in 2019:

Number Granted in 2019
Number Sent to OGE
    a. 208(b)(1) waivers
6
7
    b. 208(b)(3) waivers
0
0

  • If applicable, please explain discrepancies between the number of waivers granted and the number provided to OGE.
    After consultation w/OGE, 1 waiver was not granted.

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

  • Additional Comments

PART 7. FINANCIAL DISCLOSURE PROGRAM MANAGEMENT AND ELECTRONIC FILING SYSTEMS

27. 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.
      NA

    • If "never" or "in some cases", please explain further:
      NA

    b. Confidential Filers
In Most Cases

    • If not applicable, specify why.
      NA

    • If "never" or "in some cases", please explain further:
      NA

28. 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 FilersIn Most Cases

    • If not applicable, specify why.
      NA

    • If "never" or "in some cases", please explain further:
      NA

29. Did your agency use an electronic financial disclosure filing system (e-filing system) in calendar year 2019? Note: This includes Integrity.

  • Select Yes or No
Yes

30. Which system did your agency use?

  • Select one
Integrity and Other (specify)

  • Specify Other
    Internally developed systems at DO + 2 bureaus.

31. Indicate for which forms your agency used the other e-filing system.

  • Check all that apply
Confidential Financial Disclosure (OGE Form 450 or OGE-approved alternative form)

32. Indicate your fiscal year 2019 actual 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.

Public (do not include Integrity)Confidential
a. Amount paid to a non-federal vendor in FY 2019
0		Don’t know/don’t track

b. Amount paid to a federal agency in FY 2019
0
0

c. Amount for all internal costs associated with operating an e-filing system (e.g., FTE, overhead, etc.) in FY 2019
0		Don’t know/don’t track

  • Please explain "Don’t know/don’t track" answer above
    It is not possible to break out filing costs from ethics database/tracking costs.

33. Indicate the number of filers who filed electronically in fiscal year 2019.

    a. public financial disclosure filers (exclude filers in Integrity)
0

    b. confidential financial disclosure filers
4503

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

  • Additional Comments

PART 8. PUBLIC FINANCIAL DISCLOSURE

34. Report the number of public financial disclosure reports (OGE Form 278e) required to be filed by December 31, 2019, excluding SGEs, and the number of reports actually filed (i.e., received) by December 31, 2019.

OGE Form 278e Reports
PAS2
Non-Career SES3
Career SES3
Schedule C
Other4
TOTAL
a. Nominee/New EntrantRequired
9
18
78
15
14
134
Filed
9
18
77
15
14
133
b. AnnualRequired
18
26
402
21
61
528
Filed
18
26
401
21
61
527
c. TerminationRequired
2
6
57
9
10
84
Filed
2
6
57
9
10
84
d. Combination1Required
0
2
11
1
3
17
Filed
0
2
11
1
3
17
    Total
Required
29
52
548
46
88
763
Filed
29
52
546
46
88
761

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 category in the chart, etc.


Example for new entrant and termination reports: If an employee joined/departed the agency on December 15, 2019, 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, 2020, 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 2020 questionnaire response to be filed in 2021.

  • If applicable, please explain discrepancies between the number of reports required to be filed and the actual number of reports filed.
    One Career SES filer, who has since been notified, was not notified to file upon appointment to Career SES. Some delay in notifying a new entrant filer because of difficulty determining whether the individual filed at previous agency.

35. Note the number of public financial disclosure reports certified or otherwise closed during the calendar year. Exclude reports of SGEs. Of those reports, indicate how many were initially reviewed within 60 days and how many were certified within 60 days. “Initially reviewed within 60 days” means having completed a full technical review and conflicts analysis. See 5 C.F.R. 2634.605.

OGE Form 278e Reports
PAS2
Non-Career SES3
Career SES3
Schedule C
Other4
TOTAL
a. Nominee/New Entranti. How many reports were certified or closed in 2019?
9
12
61
12
12
106
ii. Of those certified/closed in 2019, how many were initially reviewed within 60 days?
8
10
61
12
12
103
iii. Of those certified/closed in 2019, how many were certified or closed within 60 days?
8
9
53
11
11
92
b. Annual
PAS2
Non-Career SES3
Career SES3
Schedule C
Other4
TOTAL
i. How many reports were certified or closed in 2019?
18
18
387
20
61
504
ii. Of those certified/closed in 2019, how many were initially reviewed within 60 days?
15
16
358
17
61
467
iii. Of those certified/closed in 2019, how many were certified or closed within 60 days?
6
13
328
20
59
426
c. Termination
PAS2
Non-Career SES3
Career SES3
Schedule C
Other4
TOTAL
i. How many reports were certified or closed in 2019?
2
3
46
9
10
70
ii. Of those certified/closed in 2019, how many were initially reviewed within 60 days?
2
1
45
9
10
67
iii. Of those certified/closed in 2019, how many were certified or closed within 60 days?
2
2
41
9
9
63
d. Combination
PAS2
Non-Career SES3
Career SES3
Schedule C
Other4
TOTAL
i. How many reports were certified or closed in 2019?
2
3
15
1
3
24
ii. Of those certified/closed in 2019, how many were initially reviewed within 60 days?
2
2
13
0
2
19
iii. Of those certified/closed in 2019, how many were certified or closed within 60 days?
1
2
12
0
2
17
    Total
i. How many reports were certified or closed in 2019?
31
36
509
42
86
704
ii. Of those certified/closed in 2019, how many were initially reviewed within 60 days?
27
29
477
38
85
656
iii. Of those certified/closed in 2019, how many were certified or closed within 60 days?
17
26
434
40
81
598

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 category in the chart, etc.

  • If applicable, please explain why some reports were reviewed more than 60 days after submission.
    additional information being sought workload/staffing issues

  • If applicable, please explain why some reports were certified/closed more than 60 days after submission. Check all that apply.
    additional information was being sought
    other (specify)

  • Specify Other
    Reports were not being routed to the correct reviewer or to the certifying official in Integrity.

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

    • Periodic Transaction Reports Filed
588
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.

37. 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
210
11
0
    b. Number of OGE Form 278-T Reports
13
19
4

38. Number of public financial disclosure filers reported in calendar year 2019 to the Attorney General for failure to file.

  • Enter total
0

39. How many requests for public financial disclosure reports did you receive in 2019? Count each OGE Form 201 as one request, even if it contains a request for documents for multiple individuals.

  • Enter total
27

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

  • Additional Comments
    Q34 & 35: Integrity numbers are not entirely accurate, especially for initial review dates and filer status. Going forward, we will endeavor to enter data accurately. Q35: We generated data following instructions in the OGE Job Aid, which we found difficult to understand and apply. Accordingly, we are not entirely confident of data accuracy, given our internal spot checks. Q37: At DO and one bureau, Integrity shows differences in late fee numbers for 278s and 278-Ts because these may have been incorrectly categorized—i.e., waivers for a 278-T were noted on a 278 that was timely filed. Filers were not always required to file separate 278-T reports after already reporting the transactions on their 278e reports. Finally, Integrity also indicates that 1 report paid a late fee, but this is not the case. The box must have been inadvertently checked in error. The filer filed on time.

PART 9. CONFIDENTIAL FINANCIAL DISCLOSURE

40. Report the number of confidential financial disclosure reports required to be filed by December 31, 2019, excluding SGEs, and the number of reports actually filed by December 31, 2019.

a. Required
b. Filed
10930
450
7583
OGE-approved alternate form
3325
Total
10930
10908

    Example for new entrant reports: If an employee started at the agency on December 15, 2019, 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, 2020 the employee has not filed a new entrant report, do not count that report in your required numbers. Instead, include the employee in your 2020 questionnaire response to be filed in 2021.

    If applicable, please explain discrepancies between the number of reports required to be filed and the actual number of reports filed.
  • Explain, if applicable
    Filers on admin or extended leave or military deployment admin error technical issues with e-filing certification at one bureau, several filers filed OGE 450-A because it was unaware that 450-A no longer permitted. These are counted under Required and Filed.

41. Note the number of confidential financial disclosure reports certified or otherwise closed during the calendar year. Exclude reports of SGEs. Of those reports, indicate how many were initially reviewed within 60 days and how many were certified within 60 days. "Initially Reviewed within 60 days" means having completed a full technical review and conflicts analysis. See 5 C.F.R. 2634.605.

a. How many reports were certified or closed in 2019?
b. Of those certified/closed in 2019, how many were initially reviewed within 60 days?
c. Of those certified/closed within 2019, how many were certified/closed within 60 days?
450 and OGE-approved alternative
10905
10880
10801

  • If applicable, please explain why some reports were reviewed more than 60 days after submission.
    Delays were due to technical issues with e-filing certification permissions supervisor changes supervisor on extended leave change of duties/position of filer. Also reports received from another covered position should have been tracked as received on the date we received a report rather than the date the person originally filed at their previous agency. (This was not consistently the case, but will be going forward.) For reports where person came from another agency/position, the date filed at home agency may be several months before the new supervisor reviewed and signed the report upon appointment to Treasury, e.g, detail assignment.

  • If applicable, please explain why some reports were certified/closed more than 60 days after submission. Check all that apply.
    additional information was being sought
    other (specify)

  • Specify Other
    For DO, supervisors experience technical issues with certification of report via ethics DB neglected to inform us timely, despite several reminders. In limited cases, we permitted supervisor to sign a pdf copy rather than the e-filing. At one bureau, changes in duties after departure of long-time ethics program manager led to temporary increases in ethics duties for others in the office.

42. Number of OGE 450 or OGE-approved alternative forms granted filing extensions in 2019.

  • Enter number
107

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

  • Additional Comments
    Q40: DO and one bureau cannot be certain about numbers for the 60-day review and the accuracy of tracking. The DO OGE 450 e-filing does not have the capability to record an initial review date, and the bureau does not have a tracking system in place, although implementation efforts are underway at the bureau. For DO, this capability may require significant expense in modifying electronic form. Data is based on a random sampling.

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

43. Number of disciplinary actions taken in 2019 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). For purposes of this question, disciplinary actions include removals, demotions, suspensions, and written reprimands or their equivalents.

  • Enter number
128

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

    Subpart A (General Provisions)
0

    Subpart B (Gifts from Outside Sources)
0

    Subpart C (Gifts between Employees)
0

    Subpart D (Conflicting Financial Interests)
5

    Subpart E (Impartiality in Performing Official Duties)
0

    Subpart F (Seeking Other Employment)
0

    Subpart G (Misuse of Position)
103

    Subpart H (Outside Activities)
20

    Agency's supplemental Standards of Conduct
0

44. Number of disciplinary actions taken in 2019 based wholly or in part upon violations of the criminal conflict of interest statutes (18 U.S.C. sections 203, 205, 208, and 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 (5 U.S.C. app. section 501), or outside activities (5 U.S.C. app. section 502). 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 taken based wholly or in part upon violations of:

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

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

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

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

    5 U.S.C. app. section 104 or 18 U.S.C. section 1001 (Failure to file or filing false public financial disclosures)

    5 U.S.C. app. section 501 (outside earned income)

    5 U.S.C. app. section 502 (outside activities)

45. Number of referrals made to the Department of Justice of potential violations in 2019 of the 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 (5 U.S.C. app. section 501), or outside activities (5 U.S.C. app. section 502).

  • Enter number
1

DOJ Referrals

    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 were pending DOJ’s decision as of December 31, 2019?
1

Disciplinary Action

    a. How many of those referrals resulted in disciplinary or corrective action?
0

    b. How many of those referrals resulted in a determination not to take disciplinary or corrective action?
0

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

    d. How many of those referrals involved employees who left the agency before the agency determined whether or not to take disciplinary action
1

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

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, 2019? 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, 2019, 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 01/01/2019 - 12/31/2019
9
1
20
17
0
47
i. Signed the Ethics Pledge in 2019
2
0
20
16
0
38
ii. Required to sign the Pledge in 2019 but signed in 2020
0
0
0
0
0
0
iii. Did not sign the Ethics Pledge
7
1
0
1
0
9

  • 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
7
1
0
1
0
9
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, 2019 and subject to the Ethics Pledge were registered lobbyists during the two years prior to their appointment?

  • Enter number
1

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 2019, the names of these individuals granted waivers in 2019, 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
1
Monica Crowley
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 2019?

  • Select Yes or No
No (skip to Additional Comments for this 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.

PART 12. SPECIAL GOVERNMENT EMPLOYEES (SGEs)

54. How many Special Government Employees (SGEs) did your agency have, in total, during calendar year 2019? (If zero, skip to Additional Comments for this Part.)

  • Enter number
30

55. How many SGEs who were expected to serve for 60 days or less on a board, commission, or committee were required to receive Initial Ethics Training (IET) by December 31, 2019 (5 C.F.R. 2638.304(b)(2))?

  • Enter number
18

    a. How many of those SGEs received IET before or at the beginning of the first meeting?
16

    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?
2

    • If applicable, please explain why some SGEs received IET after the first meeting or have yet to receive IET.
      At one bureau, two panel members have not completed the training. These members did not participate in any of the meetings during 2019, and their subcommittee has not met.

56. Report the number of SGE public and confidential financial disclosure reports required to be filed by December 31, 2019 and the number of reports actually filed by December 31, 2019.

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)
17
16
0
0
b. Advisory Committee Members (non-FACA)
12
12
0
0
c. Experts/Consultants
0
0
0
0
d. Board Members
0
0
1
1
e. Commissioners
0
0
0
0
f. Other
0
0
0
0
TOTAL
29
28
1
1

    Example for new entrant and termination reports: If an employee joined/departed the agency on December 15, 2019, and 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 2020 questionnaire response to be filed in 2021.

  • If applicable, please explain discrepancies between the number of reports required to be filed and the actual number of reports filed.
    At one bureau, after repeated attempts, one panel member never submitted the form and bureau is attempting to secure the Form. The subpanel for which this member participates did not meet during CY 2019.

57. Note the number of SGE disclosure reports certified or otherwise closed during the calendar year. Of those reports, indicate how many were initially reviewed within 60 days and how many were certified within 60 days. “Initially reviewed within 60 days” means having completed a full technical review and conflicts analysis. See 5 C.F.R. 2634.605.

Confidential Reports
Public Reports
a. How many reports were certified or closed in 2019?
28
1
b. Of those certified/closed in 2019, how many were initially reviewed within 60 days?
28
1
c. Of those certified/closed within 2019, how many were certified/closed within 60 days?
28
1

  • If applicable, please explain why some reports were reviewed more than 60 days after submission.

  • If applicable, please explain why some reports were certified/closed more than 60 days after submission. Check all that apply.

  • Specify Other
    NA

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

  • Enter number
0

59. 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
2

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

  • Additional Comments
    Q54 & 56: The SGE is already counted in the Public Financial Disclosure numbers in #34, but we are also including that information here. He has not performed any work in 2019

ADDITIONAL QUESTIONNAIRE COMMENTS:

  • Additional Comments

      OGE Form 450A
0
hidden element