2020 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, 2021. (5 C.F.R. 2638.207(a)).

PART 2. INSTRUCTIONS

Your response to this questionnaire should reflect the 2020 calendar year (i.e., 1/1/2020 through 12/31/2020), 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 2019 report. After OGE has reviewed your questionnaire submission, you may be contacted for follow-up.

FAQ's:

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Why is the field highlighted yellow?

After I have submitted the questionnaire, how do I save a copy for my records?

Can I edit my response if I made an error?

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Can more than one person work on the questionnaire response?

I accidentally created more than one agency response. Which one should I use?

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, 2020
83226

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

a. Vacant (as of December 31, 2020)?
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, 2020)?
No

b. Time in current ADAEO position
1 - 4 years

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 2020 (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
33
83
12
0
9
137
b. Outside the D.C. Metro area
68
63
6
0
3
140
TOTAL
101
146
18
0
12
277

* FTE = Full Time Equivalent

Example: The table below provides an example of an agency with 13 employees that performed ethics
program duties in 2020.

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(s) 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(s) of the board, commission, or agency:
    Women’s Suffrage Centennial Commission

  • Describe the services or support provided:
    FACA-related legal advice

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

  • Select type of resources

    Human Capital, Technology

  • Specify Other
    NA

10. Did the agency head meet with the ethics staff to discuss the strengths and weaknesses of the ethics program in 2020?

  • 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 2020 (5 C.F.R. 2638.104(c)(16))?

  • Select Yes or No
Yes

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

    DAEO, General Counsel, Inspector General, Other

  • Specify Other
    KPMG conducts financial audit of one bureau.

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)
    At DO/HQ, refined process for pre-vetting new employees hired for specific duties and programs (e.g., CARES Act) examined OFR employment offer letters to ensure inclusion of additional OFR post-employment restrictions reviewed accuracy of Integrity filer “background” data (e.g., position, filer appointment type, etc.)and updated as appropriate and procedural changes for review and reporting of gifts. At one bureau, amplified written instructions for financial disclosure reviewers to provide additional guidance on when to add a reviewer’s comment in connection with a reported outside activity encouraged one district to add reviewers to redistribute reviewer’s workload. Policies were updated at one bureau new policies established at another bureau. At one bureau, no changes resulted because audit was not completed.

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)

  • Explain what steps you are taking to implement the required written procedures:
    NA

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

  • Additional Comments
    Q2: 11,163 F/T seasonal employees are not included in above number.
    Q6: Some bureaus relied on IT support from contractors.

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:
    NA

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:
    NA

  • Please Explain:
    NA

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, 2020? Exclude SGEs that were expected to serve less than 60 days on a board, commission, or committee.

Total Number
4
    • a. How many of those leaders received their briefing within 15 days of their appointment?
4
    • 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, 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.

Number required
4581
  • a. How many of those employees received IET within the 3-month requirement?
4345
  • b. How many of those employees received IET beyond the 3-month requirement?
171
  • c. How many of those employee have not received IET as of today?
65

Example: If an employee started at the agency on December 15, 2020, 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, 2021, the employee has not completed IET, do not count that employee in your required numbers. Instead, include the employee in your 2021 questionnaire response to be filed in 2022.

  • If applicable, please explain why some employees received IET beyond the 3-month requirement or have yet to receive IET.
    Due to the pandemic, at one bureau, several employees were unable to access online training because they were not issued computers at another bureau, some employees had technical issues accessing training, and others were delayed despite reminders. At a third bureau, automated system designed by IT to assign new employees training worked well until a reassignment of IT duties caused miscommunication, and this process not to be reassigned to a new person in IT for several months. (The process has since been corrected.)
    All were provided ethics orientation materials.

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?

    All of the offices provided the written confirmation to the DAEO

  • Please Explain why not all offices:

20. Did the head of the agency complete either initial ethics training and/or annual ethics training in 2020?

  • 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)
585
585

    c. Confidential filers (OGE Form 450 and OGE-approved alternative confidential financial disclosure forms)
9523
9471

    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
10110
10058

  • If applicable, please explain discrepancies between the number of employees who were required to receive training and the number of employees who received training:
    Employees on extended or admin leave employees left prior to completion technical issues

22. Did your DAEO establish additional requirements for the agency's ethics education program, beyond those described in 5 CFR 2638.303-308? For example, did your DAEO establish specific government ethics training requirements for groups of agency employees?

  • Select Yes or No
Yes

  • Please Describe:
    At DO/HQ: Non-mandatory seeking and post-employment briefing for all departing political employees at five bureaus, annual ethics training is mandatory for all employees, regardless of filing status.

23. 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:
    Note that responses for this question differed among bureaus.

24. 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, Administered post-training evaluations to assess participants' perceptions of the training, Reviewed advice logs for increased activity after training presentations and communications, 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:
    Note that some bureaus did not evaluate effectiveness of their ethics education.

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

  • Additional Comments
    Q16:At one bureau, some of the required ethics language was initially missing due to administrative error, but HR was notified and the error was swiftly corrected.

PART 6. ADVICE, COUNSELING, AND REMEDIES

25. From the list below, select the three topics that your employees most frequently sought guidance on in 2020. Please rate them in order, so that the first topic is the topic on which the 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
Gift acceptance
  • Selection 3
Outside employment/activities

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

26. Number of notification statements of negotiation or recusal under section 17(a) of the STOCK Act submitted to the ethics office in 2020 (see 5 C.F.R. 2635.602(a)):

  • Enter total
68

27. Number of 18 U.S.C. 208 waivers granted in 2020:

Number Granted in 2020
Number Sent to OGE
    a. 208(b)(1) waivers
8
9
    b. 208(b)(3) waivers
0
0

  • If applicable, please explain discrepancies between the number of waivers granted and the number provided to OGE.
    OGE was consulted on one waiver that was not issued because employee left.

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

28. 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

29. 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

30. Did your agency use an electronic financial disclosure filing system in calendar year 2020? Note: This includes Integrity, but would not include a mere digital signature of a PDF fillable form.

  • Select Yes or No
Yes

31. Which system did your agency use?

  • Select one
Integrity and Other (specify)

  • Specify Other
    Internally developed systems at DO/HQ + 3 bureaus (OGE 450 filing via ethics DB Disclosure (Salesforce appl.) Ethics Management System e-filing system created in Sharepoint.)

32. 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)

33. Indicate your fiscal year 2020 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 2020
0		Don’t know/don’t track

b. Amount paid to a federal agency in FY 2020
0		Don’t know/don’t track

c. Amount for all internal costs associated with operating an e-filing system (e.g., FTE, overhead, etc.) in FY 2020
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.

34. Indicate the number of filers who filed electronically in fiscal year 2020.

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

    b. confidential financial disclosure filers
4681

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

  • Additional Comments
    Q30: Most bureaus use Integrity only.

PART 8. PUBLIC FINANCIAL DISCLOSURE

35. Report the number of public financial disclosure reports (OGE Form 278e) required to be filed by December 31, 2020, excluding SGEs, and the number of reports actually filed (i.e., received) by December 31, 2020.

OGE Form 278e Reports
PAS2
Non-Career SES3
Career SES3
Schedule C
Other4
TOTAL
a. New EntrantRequired
0
7
105
13
11
136
Filed
0
7
105
13
11
136
b. AnnualRequired
22
25
441
25
60
573
Filed
22
25
441
25
60
573
c. TerminationRequired
3
8
34
6
10
61
Filed
3
8
34
6
10
61
d. Combination1Required
0
2
5
1
0
8
Filed
0
2
5
1
0
8
    Total
Required
25
42
585
45
81
778
Filed
25
42
585
45
81
778

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, 2020, 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, 2021, the employee has not filed a new entrant/termination report, do not count that report in your required numbers. Instead, include the report in your 2021 questionnaire response to be filed in 2022.

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

36. Note the number of public financial disclosure reports certified or otherwise closed by your agency 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 technical review and conflicts analysis. See 5 C.F.R. 2634.605 and section 4.02 of the Public Financial Disclosure Guide.

OGE Form 278e Reports
PAS2
Non-Career SES3
Career SES3
Schedule C
Other4
TOTAL
a. New Entranti. How many reports did your agency certify or close in 2020?
0
10
87
12
14
123
ii. Of those certified or closed in 2020, how many were initially reviewed within 60 days?
0
7
78
11
14
110
iii. Of those certified or closed in 2020, how many were certified or closed within 60 days?
0
5
65
11
14
95
b. Annual
PAS2
Non-Career SES3
Career SES3
Schedule C
Other4
TOTAL
i. How many reports did your agency certify or close in 2020?
22
27
418
25
60
552
ii. Of those certified or closed in 2020, how many were initially reviewed within 60 days?
19
23
363
25
59
489
iii. Of those certified or closed in 2020, how many were certified or closed within 60 days?
16
17
317
24
57
431
c. Termination
PAS2
Non-Career SES3
Career SES3
Schedule C
Other4
TOTAL
i. How many reports did your agency certify or close in 2020?
3
10
32
6
13
64
ii. Of those certified or closed in 2020, how many were initially reviewed within 60 days?
3
8
29
6
12
58
iii. Of those certified or closed in 2020, how many were certified or closed within 60 days?
3
7
27
6
11
54
d. Combination
PAS2
Non-Career SES3
Career SES3
Schedule C
Other4
TOTAL
i. How many reports did your agency certify or close in 2020?
1
2
5
1
1
10
ii. Of those certified or closed in 2020, how many were initially reviewed within 60 days?
1
1
5
1
1
9
iii. Of those certified or closed in 2020, how many were certified or closed within 60 days?
0
1
4
1
1
7
    Total
i. How many reports did your agency certify or close in 2020?
26
49
542
44
88
749
ii. Of those certified or closed in 2020, how many were initially reviewed within 60 days?
23
39
475
43
86
666
iii. Of those certified or closed in 2020, how many were certified or closed within 60 days?
19
30
413
42
83
587

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.
    New workstream stemming from CARES/pandemic implementation staffing/workload issues, including new reviewers and parental leave of a primary reviewer departure of ethics officials administrative oversight in part due to PIV card issuance delays to new employees.

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

  • Specify Other
    new workstream stemming from CARES/pandemic implementation staffing/workload

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

    • Periodic Transaction Reports Filed
829
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
242
5
2
    b. Number of OGE Form 278-T Reports
19
13
1

39. Number of public financial disclosure filers reported in calendar year 2020 to the Attorney General for failure to file.

  • Enter total
0

40. How many requests for public financial disclosure reports did you receive in 2020? Count each OGE Form 201 as one request, even if it contains a request for documents for multiple individuals.

  • Enter total
23

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

  • Additional Comments
    Q35 & 36:At DO/HQ, Integrity numbers from the data pull may not be entirely accurate so we also relied on internal data.
    Q38: Integrity may reflect 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.

PART 9. CONFIDENTIAL FINANCIAL DISCLOSURE

41. Report the number of confidential financial disclosure reports required to be filed by December 31, 2020, excluding SGEs, and the number of reports actually filed by December 31, 2020.

a. Required
b. Filed
10291
OGE Form 450
7181
OGE-approved alternate form
3094
Total
10291
10275

    Note: If a 450 filer leaves the filing position before the due date, the report is not required per 5 C.F.R. 2634.903(a).

    Example for new entrant reports: If an employee started at the agency on December 15, 2020, 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, 2021 the employee has not filed a new entrant report, do not count that report in your required numbers. Instead, include the report in your 2021 questionnaire response to be filed in 2022.

    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 extended leave filers who were promoted were not timely notified (since corrected)

42. Note the number of confidential financial disclosure reports certified or otherwise closed by your agency 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 technical review and conflicts analysis. See 5 C.F.R. 2634.605 and the Certification Requirements section of the Confidential Financial Disclosure Guide.

a. How many reports did your agency certify or close in 2020?
b. Of those certified or closed in 2020, how many were initially reviewed within 60 days?
c. Of those certified or closed in 2020, how many were certified or closed within 60 days?
OGE Form 450 and OGE-approved alternative
10267
10009
9948

  • If applicable, please explain why some reports were reviewed more than 60 days after submission.
    Pandemic delays and staffing/workload. In DO, if a supervisor returns a report for revision, the system does not capture this initial review date supervisor vacancies may cause certification delays admin access issues related to e-filing supervisor reminders not heeded.

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

  • Specify Other
    Pandemic delays, including manual review of physical copies of reports and files at one bureau. Once access to files was restored, majority of reviews were completed and certified within 30 days. That bureau is transitioning to an electronic review method for 2021. At another bureau, administrative oversight in part due to PIV card issuance delays to new employees other delays include staffing/workload issues (training new reviewers and parental leave of a primary reviewer departure of ethics officials).

43. Number of OGE 450 or OGE-approved alternative forms granted filing extensions in 2020.

  • Enter number
261

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

  • Additional Comments
    Q42: DO/HQ 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. This capability requires significant expense in modifying electronic form.

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

44. Number of disciplinary actions taken in 2020 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
90

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

    Subpart A (General Provisions)
1

    Subpart B (Gifts from Outside Sources)
0

    Subpart C (Gifts between Employees)
0

    Subpart D (Conflicting Financial Interests)
1

    Subpart E (Impartiality in Performing Official Duties)
0

    Subpart F (Seeking Other Employment)
0

    Subpart G (Misuse of Position)
79

    Subpart H (Outside Activities)
8

    Agency's supplemental Standards of Conduct
1

45. Number of disciplinary actions taken in 2020 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)

46. Number of referrals made in 2020 to the Department of Justice of potential violations 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
2

DOJ Referrals Status

    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, 2020?
0

Agency Disciplinary Action Status

    a. Of the cases referred to DOJ, how many resulted in disciplinary or corrective action?
1

    b. Of the cases referred to DOJ, how many resulted in a determination not to take disciplinary or corrective action?
0

    c. Of the cases referred to DOJ, how many are pending a determination as to whether disciplinary or corrective action will be taken?
1

    d. Of the cases referred to DOJ, how many of those referrals involved employees who left the agency before the agency determined whether or not to take disciplinary action?
0

    e. Of the cases referred to DOJ, how many involved 18 U.S.C. 207, such that there was no option for disciplinary action?
0

47. Did your agency notify OGE of all referral(s) and disposition(s) of the referral(s) 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

48. 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, 2020? 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

49. For each category of appointee, provide the number of full-time non-career appointees appointed between January 1 and December 31, 2020, and indicate the number who did and did not sign the Ethics Pledge.

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 01/01/2020 - 12/31/2020
4
0
10
15
0
29
i. Signed the Ethics Pledge in 2020
0
0
8
15
0
23
ii. Required to sign the Pledge in 2020 but signed in 2021
0
0
0
0
0
0
iii. Required to sign the Pledge, but did not sign (please explain)
0
0
0
0
0
0
iv. Not required to sign the Pledge because occupied an exempt non-policymaking position (Schedule C or other comparable authority)
0
0
0
0
0
0
v. Not required to sign the Pledge because appointed without break in service after serving in another position for which the Ethics Pledge was already signed
4
0
2
0
0
6
vi. Not required to sign for another reason (please explain)
0
0
0
0
0
0

  • For each appointee identified in line iii, please explain why that appointee did not sign the Pledge.

  • For each appointee identified in line vi, please explain why that appointee was not required to sign the Pledge.

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

50. How many appointees appointed between January 1 and December 31, 2020 and subject to the Ethics Pledge were registered lobbyists during the two years prior to their appointment?

  • Enter number
0

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 2020, the names of these individuals granted waivers in 2020, 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 2020?

  • Select Yes or No
No

53. Please provide information on enforcement actions taken in 2020 as a result of violations of the Pledge (regardless of whether the violation itself took place in 2020 or earlier).

  • Please type in the box below.
    N/A

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 2020? (If zero, skip to Additional Comments for this Part.)

  • Enter number
31

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, 2020 (5 C.F.R. 2638.304(b)(2))?

  • Enter number
19

    a. How many of those SGEs received IET before or at the beginning of the first meeting?
14

    b. How many of those SGEs received IET after the first meeting?
2

    c. How many of those SGEs have not received IET as of today?
3

    • If applicable, please explain why some SGEs received IET after the first meeting or have yet to receive IET.
      The three that did not receive the training have not participated in any activities with the committee for several years.

56. Report the number of SGE public and confidential financial disclosure reports required to be filed by December 31, 2020 and the number of reports actually filed by December 31, 2020.

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
13
0
0
b. Advisory Committee Members (non-FACA)
11
11
0
0
c. Experts/Consultants
1
1
0
0
d. Board Members
0
0
1
1
e. Commissioners
0
0
0
0
f. Other
0
0
0
0
TOTAL
29
25
1
1

    Example for new entrant and termination reports: If an employee joined/departed the agency on December 15, 2020, 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 report in your 2021 questionnaire response to be filed in 2022.

  • If applicable, please explain discrepancies between the number of reports required to be filed and the actual number of reports filed.
    One bureau did not receive 4 reports this year. Please note that the subpanel for which two of these members participate did not meet during CY 18, 19 nor 20. After repeated attempts and reminders two active panel members never submitted the form.

57. Note the number of SGE disclosure reports certified or otherwise closed by your agency 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 technical review and conflicts analysis. See 5 C.F.R. 2634.605, section 4.02 of the Public Financial Disclosure Guide, and the Certification Requirements section of the Confidential Financial Disclosure Guide.

Confidential Reports
Public Reports
a. How many reports did your agency certify or close in 2020?
25
1
b. Of those certified or closed in 2020, how many were initially reviewed within 60 days?
21
1
c. Of those certified or closed in 2020, how many were certified or closed within 60 days?
16
1

  • If applicable, please explain why some reports were reviewed more than 60 days after submission.
    Delays were due to evacuation orders as a result of the pandemic.

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

  • Specify Other
    pandemic

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
4

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

  • Additional Comments

ADDITIONAL QUESTIONNAIRE COMMENTS:

  • Additional Comments

      OGE Form 450A
0
hidden element