- Additional Comments
Q21: There is a fairly steep increase in the number of confidential financial disclosure filers that received annual ethics training this year. We believe that the number provided last year was artificially low, and would have been more consistent with the current numbers. We realized this year that not all offices rely on FDM to track their annual filers’ training, and it was assumed that they did, so we relied on FDM’s numbers last year. This year, as we now understand that is not the case, we have received the numbers throughout the Air Force, and believe that this is the most accurate count.
Q18 – How many employees, including SGEs, were required to receive Initial Ethics Training (IET) by December 31, 2020 (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. (If applicable, please explain why some employees received IET beyond the 3-month requirement, or have yet to receive IET): • Lack of communication between HR offices and the legal offices that provide the training.
• In the case of some employees, problems with email communications were the cause of their receiving the training beyond the three month requirement. All four eventually received training.
• There were new/inexperienced ethics counselors who inadvertently overlooked the requirement.
• Some offices perform the training quarterly, and there was an incident where the training had to be delayed one quarter, and some new employees went beyond the 90 day deadline.
• Delays due to transitions from live training to virtual due to COVID-19.
• Due to COVID-19 access restrictions on several installations/the move to teleworking for most employees, some new employees were not identified in a timely manner as not having received the training within three months. Others were unable to access the training online during the initial three months due to challenges with/availability of internet service from home.
• In some cases, individuals were deployed shortly after being hired, and were not available for training until after the initial three months of employment.
• Some employees departed the Air Force before three months had lapsed.
• In some cases, employees were non-responsive to requests to complete training.
• Some offices postponed trainings in the spring due to COVID-19, believing that the restrictions would be short-lived. Once they realized that was not the case, they developed a virtual training.
• Some offices have refused to count the training as completed unless the employee produces a certificate, however, there are problems with the current computer-based programs, and a certificate is not always generated. Moreover, although an employee may have been trained within 90 days, if they did not turn in the certificate before the 90 days was up, they were not counted as timely trained.
• There was confusion as to whether onboarding employees who were already DoD employees needed to be trained again.
• Due to the pandemic, a number of new hires did not have the requisite computer access to complete the training within 90 days.
• Some new hires were sent on temporary duty to a training academy, and were delayed beyond the 90 days due to travel restrictions.
• In 2020 there were transitions from live to computer-based interactive training. HR offices did not understand their obligation to notify new employees of their training obligation, so a substantial amount went untrained. However, those individuals are being contacted, and they will be trained ASAP. Q21 – 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 filers did not receive training due to significant illness, deployment, inability to access the materials due to technological difficulties.
• Some filers ignored repeated requests for completion, or, despite making contact, would never follow through on promises to complete the training.
• Some filers left the position (i.e., moved assignments, deployed, separated, retired) before the end of the year, without completing the training, and therefore, they are unaccounted for in the total trained.
• There were a number of instances where it was suspected that the training was completed, but the employees could not be reached in time for this reporting to confirm, so they were counted as having not completed the training.
• Due to the pandemic, there were a number of filers who had unreliable technological capabilities that impeded their ability to timely train.
• There is an issue with 450 filers not understanding that there is no connection between the computer-based training system and FDM, which some offices use to track training. Those individuals tend to ignore requests for reporting completion, because they believe that the ethics counselors should be able to see it. The emails sent out have emphasized that there is no connection, and we do rely on them self-reporting, but there are a large number of filers who don’t understand or appreciate that fact.
• There were filers who were assigned a 450 report in December, but did not actually file in 2020, but they populate as requiring training in 2020 anyway.
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