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.

FAQ's:

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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

  • National Archives and Records Administration

2. Employees

  • Number of full-time agency employees as of December 31, 2019
2615

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

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

b. Time in current DAEO position
10 or more years

c. Total years performing ethics duties
10 or more 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.
1

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

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

b. Time in current ADAEO position
1 - 4 years

c. Total years performing ethics duties
5 - 9 years

d. Percent of time spent on ethics
26 -50%

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
3
5
1
0
0
9
b. Outside the D.C. Metro area
0
0
0
0
0
0
TOTAL
3
5
1
0
0
9

* 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




Other (please describe)

  • Please describe IT support (optional)
    NA

  • Please describe administrative support (optional)
    NA

  • Please describe substantive support (optional)
    NA

  • Specify Other
    NARA uses a USG shared services provider (through an IAA) for certain Human Capital services. For example, the provider prepares and sends offer letters and includes ethics information in those letters.

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
No

  • Please provide the name of the board, commission, or agency:

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

  • Specify Other
    NA

13. 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)
    A review resulted in a change to the initial ethics training process, as well as an evaluation and update of how certain materials are provided through the Human Capital office.

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)

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

  • Additional Comments
    Question 8--NARA provides ethics support to the Public Interest Declassification Board, which was not authorized to operate for most of 2019. Congress reauthorized PIDB in December 2019 and NARA will provide ethics support to PIDB going forward. Question 14--Ethics officials are working with Human Capital to implement written procedures for the issuance of ethics notices to new supervisors in CY 20.

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

    • 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
189
  • a. How many of those employees received IET within the 3-month requirement?
158
  • b. How many of those employees received IET beyond the 3-month requirement?
1
  • c. How many of those employee have not received IET as of today?
30

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.
    One employee received IET beyond the three month requirement because of administrative oversight. The 30 employees listed are from a single location that was unable to confirm by the reporting deadline that employees coming on board in the first half of CY19 received the required training. If those employees are determined to have not received the required training, ethics officials will ensure the training is provided in early CY20.

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?

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

  • Please Explain why not all offices:
    One location was unable to confirm by the deadline that IET was being provided in the time frame required during the first half of CY19.

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)
0
0

    b. All other public filers (OGE Form 278e)
41
41

    c. Confidential filers (OGE Form 450 and OGE-approved alternative confidential financial disclosure forms)
359
359

    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
400
400

  • If applicable, please explain discrepancies between the number of employees who were required to receive training and the number of employees who received training:

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, Talked to program managers about risks inherent in their work

  • Please explain other:

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, Reviewed advice logs for increased activity after training presentations and communications

  • Please explain other:

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
Financial Disclosure Reporting
  • Selection 2
Outside employment/activities
  • Selection 3
Travel, subsistence, and related expenses from non-federal sources

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

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
1

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
0
0
    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

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 Some Cases (specify why, below)

    • If not applicable, specify why.
      NA

    • If "never" or "in some cases", please explain further:
      NARA transitioned to a new provider for Human Capital services and some processes are being refined after the transition. DAEO was notified of public filers' appointments by other means in all cases.

    b. Confidential Filers
In Some Cases (specify why, below)

    • If not applicable, specify why.
      NA

    • If "never" or "in some cases", please explain further:
      NARA transitioned to a new provider for Human Capital services and some processes are being refined after the transition.

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 FilersNever (specify why, below)

    • If not applicable, specify why.
      NA

    • If "never" or "in some cases", please explain further:
      NARA transitioned to a new provider for Human Capital services and some processes are being refined after the transition. DAEO was notified of public filers' separations by other means in all cases.

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 ONLY (skip to Additional Comments for this Part)

  • Specify Other
    NA

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

  • Check all that apply

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

b. Amount paid to a federal agency in FY 2019

c. Amount for all internal costs associated with operating an e-filing system (e.g., FTE, overhead, etc.) in FY 2019

  • Please explain "Don’t know/don’t track" answer above

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

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

    b. confidential financial disclosure filers

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
0
0
1
0
1
2
Filed
0
0
1
0
1
2
b. AnnualRequired
1
0
23
0
15
39
Filed
1
0
23
0
15
39
c. TerminationRequired
0
0
0
0
2
2
Filed
0
0
0
0
2
2
d. Combination1Required
0
0
1
0
0
1
Filed
0
0
1
0
0
1
    Total
Required
1
0
25
0
18
44
Filed
1
0
25
0
18
44

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.

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?
0
0
1
0
1
2
ii. Of those certified/closed in 2019, how many were initially reviewed within 60 days?
0
0
1
0
1
2
iii. Of those certified/closed in 2019, how many were certified or closed within 60 days?
0
0
1
0
1
2
b. Annual
PAS2
Non-Career SES3
Career SES3
Schedule C
Other4
TOTAL
i. How many reports were certified or closed in 2019?
1
0
23
0
15
39
ii. Of those certified/closed in 2019, how many were initially reviewed within 60 days?
1
0
23
0
15
39
iii. Of those certified/closed in 2019, how many were certified or closed within 60 days?
1
0
22
0
14
37
c. Termination
PAS2
Non-Career SES3
Career SES3
Schedule C
Other4
TOTAL
i. How many reports were certified or closed in 2019?
0
0
0
0
2
2
ii. Of those certified/closed in 2019, how many were initially reviewed within 60 days?
0
0
0
0
2
2
iii. Of those certified/closed in 2019, how many were certified or closed within 60 days?
0
0
0
0
2
2
d. Combination
PAS2
Non-Career SES3
Career SES3
Schedule C
Other4
TOTAL
i. How many reports were certified or closed in 2019?
0
0
1
0
0
1
ii. Of those certified/closed in 2019, how many were initially reviewed within 60 days?
0
0
1
0
0
1
iii. Of those certified/closed in 2019, how many were certified or closed within 60 days?
0
0
1
0
0
1
    Total
i. How many reports were certified or closed in 2019?
1
0
25
0
18
44
ii. Of those certified/closed in 2019, how many were initially reviewed within 60 days?
1
0
25
0
18
44
iii. Of those certified/closed in 2019, how many were certified or closed within 60 days?
1
0
24
0
17
42

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.

  • 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

  • Specify Other
    NA

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

    • Periodic Transaction Reports Filed
51
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
6
0
0
    b. Number of OGE Form 278-T Reports
1
4
0

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
0

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

  • Additional Comments

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
429
450
337
OGE-approved alternate form
92
Total
429
429

    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

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
336
332
320

  • If applicable, please explain why some reports were reviewed more than 60 days after submission.
    Four forms were reviewed after 60 days due to administrative oversight.

  • 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
    Of the sixteen forms that were certified after more than 60 days, two were because of administrative oversight. Fourteen forms were certified after 60 days because additional information was being sought.

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

  • Enter number
8

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 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
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)

    Agency's supplemental Standards of Conduct

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
3

DOJ Referrals

    a. How many of those referrals were accepted for prosecution?
1

    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, 2019?
0

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?
2

    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
No (skip to #51)

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
i. Signed the Ethics Pledge in 2019
ii. Required to sign the Pledge in 2019 but signed in 2020
iii. Did not sign the Ethics Pledge

  • 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)
b. Appointed without break in service after serving in another position for which the Ethics Pledge was already signed
c. Other (explain below)

    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

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
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 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
2

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
0

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

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

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

    • 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, 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)
0
0
0
0
b. Advisory Committee Members (non-FACA)
0
0
0
0
c. Experts/Consultants
0
0
0
0
d. Board Members
0
0
0
0
e. Commissioners
2
2
0
0
f. Other
0
0
0
0
TOTAL
2
2
0
0

    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.

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?
2
0
b. Of those certified/closed in 2019, how many were initially reviewed within 60 days?
2
0
c. Of those certified/closed within 2019, how many were certified/closed within 60 days?
2
0

  • 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
0

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

  • Additional Comments
    NARA provides ethics support to the Public Interest Declassification Board. The PIDB was not authorized to operate for most of 2019, so no financial disclosure forms were collected. Congress reauthorized PIDB in December 2019 and NARA will resume providing ethics support for PIDB.

ADDITIONAL QUESTIONNAIRE COMMENTS:

  • Additional Comments

      OGE Form 450A
0
hidden element