2022 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, 2023. (5 C.F.R. 2638.207(a)).

PART 2. INSTRUCTIONS

Your response to this questionnaire should reflect the 2022 calendar year (i.e., 1/1/2022 through 12/31/2022), 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 and to explain significant changes from your 2021 report. To safeguard privacy, in your responses, please avoid the use of Personally Identifiable Information (PII). 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 Chris Brown at cbrown@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, 2022
87614

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

a. Vacant (as of December 31, 2022)?
No

b. Time in current DAEO position
5 - 9 years

c. Total years performing ethics duties
10 or more years

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

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, 2022)?
No

b. Time in current ADAEO position
Less than 1 year

c. Total years performing ethics duties
10 or more years

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

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

5. Number of employees, including the DAEO and ADAEO, who performed ethics program duties in 2022 (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
28
48
19
2
7
104
b. Outside the D.C. Metro area
61
31
7
0
3
102
TOTAL
89
79
26
2
10
206

* FTE = Full Time Equivalent

Example: The table below provides an example of an agency with 13 employees that performed ethics
program duties in 2022.

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

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

  • Check all that apply

IT services (e.g., developing or supporting electronic filing systems, applications, websites, and/or databases, etc.)


  • Please describe IT support (optional)
    Support for database and e-filing

  • 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
No

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

  • Describe the services or support provided:

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 2022?

  • 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.) or any entity outside of your agency (e.g., GAO or private auditing firm) evaluate any aspect of the ethics program in 2022 (5 C.F.R. 2638.104(c)(16))? Exclude program reviews conducted by OGE. Select all that apply.

    My agency (e.g., ethics office, Inspector General, General Counsel, etc.) conducted an evaluation

  • Please Describe:
    NA

12. What kind of changes resulted from the evaluation?

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


  • Please Describe: (Please describe programmatic or policy changes; Specify why no changes resulted; Specify why recommendations still being considered; Specify why not applicable)
    One bureau issued more detailed guidance on the seeking employment rules a second bureau is working with its HR and Training offices to administer directly new employee ethics training for increased reliability over its current notification system a third bureau made policy changes to reflect revisions to Agency designations of positions as confidential filer another bureau is reviewing its internal procedures on identifying OGE 450 filers in a more efficient and timely manner and reviewing internal processes and procedures for review of financial disclosure filings. DO/HQ: Finalized SOP on OGE 201 requests & drafted and implemented SOP on late filing fee process 1 bureau revised its designated OGE 450 filing positions.

13. 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: Total includes 2 F/T seasonal in DO/HQ.
    Q6: None for most bureaus IT services for 4 bureaus.
    Q7: One bureau had support from another federal agency for OGE 450 review.
    Q9: No for most bureaus 2 indicated more support needed for Human Capital, and 2 also indicated technology.
    Q11: Nearly evenly split among bureaus for internal vs. no review one bureau had an external audit by a private firm of some aspects of its ethics program. Also, in DO/HQ, we have begun program reviews with Treasury bureaus, but responses are not due back until February 2023.

PART 5. EDUCATION AND TRAINING

14. 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 #16)

  • Please Explain why not all offices:
    NA

15. 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

16. Initial Ethics Briefing

a. How many agency leaders, as defined in 5 C.F.R. 2638.305(a), were required to receive ethics briefings by December 31, 2022? Exclude SGEs that were expected to serve less than 60 days on a board, commission, or committee.
Total Number
9
    i. How many new agency leaders received their briefing within 15 days of their appointment?
9
    ii. How many of those leaders received their briefing beyond the 15-day requirement?
0
    iii. How many new agency 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.

17. Initial Ethics Training

a. How many employees, as defined in 5 C.F.R. 2638.304(a), were required to receive Initial Ethics Training (IET) by December 31, 2022 (5 C.F.R. 2638.304)? Exclude SGEs that were expected to serve less than 60 days on a board, commission, or committee. (Note: Include employees who were not required to receive the interactive portion of the IET, as provided in 5 C.F.R. 2638.304(a)(2).)
Total Number
3922
    i. How many of those employees received IET within the 3-month requirement?
3708
    ii. How many of those employees received IET beyond the 3-month requirement?
157
    iii. How many of those employee have not received IET as of today?
57
    iv. Do not track

Example: If an employee started at the agency on December 15, 2022, 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, 2023, the employee has not completed IET, do not count that employee in your required numbers. Instead, include the employee in your 2023 questionnaire response to be filed in 2024.

  • If applicable, please explain why some employees received IET beyond the 3-month requirement or have yet to receive IET.
    For the majority of bureaus, including DO/HQ, employees received required training within the 3-month period. At one bureau, two employees were not automatically assigned the training in their learning management system, but they have received training at another bureau, some employees were not able to complete the online ethics orientation to due to technical issues, but they were provided with ethics orientation materials and follow-up is being pursued with other employees. One bureau indicated the one employee who has not yet received IET is a police officer who was at off-site mandatory introductory federal law enforcement training for most of the year and upon assuming duties, does not yet have access to the training system, although the bureau is actively working to provide training access to this employee. A small number of employees who received IET beyond the 3-month requirement at two bureaus were delayed in complying, despite many reminders. Finally, one bureau did not always receive timely notifications from HR or the new employee supervisors for approximately half of its new employees. However, this error has been corrected and a new IET package, including an interactive test has been incorporated directly into the materials presented to each new employee on their start date.

18. 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:

19. Did the head of the agency complete either initial ethics training and/or annual ethics training in 2022?

  • Select One
Yes

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

20. Required Annual Ethics Training

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

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

    b. All other public filers (OGE Form 278e)
645
645

    c. Confidential filers (OGE Form 450 and OGE-approved alternative confidential financial disclosure forms)
9778
9625

    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
10425
10272

  • If applicable, please explain discrepancies between the number of employees who were required to receive training and the number of employees who received training:
    The vast majority of the confidential filers who did not timely complete training were at one small bureau, where the ethics office was experiencing staffing issues due to budgetary constraints (hiring pause in effect), a bureau-wide reorganization that required additional attention to its impact on employees subject to financial disclosure requirements, and the sudden departure of the ethics program lead late in the year. Although the employees did not complete their annual ethics training by December 31, most of them did complete the training in January 2023. That bureau is addressing these delays, the remaining employees are completing the training, and DO/HQ is working with the bureau’s ethics office on revising their internal processes. At the other bureaus, the filers who did not timely complete training were mostly on extended admin or medical leave or deployed at two bureaus, some employees overlooked reminders and/or failed to complete before year-end leave, but follow-up is

21. Did your agency establish additional requirements for the agency's ethics education program, pursuant to 5 C.F.R. 2638.309?

    My agency established additional training requirements for other groups of employees, beyond those described in 5 C.F.R. 2638.303-308 (notices to new employees and supervisors, initial ethics training, ethics briefings, annual ethics training) Please describe.

  • Please Describe
    For DO/HQ, new entrant public filers who onboarded before August 1 and confidential filers who onboarded before June 1 were required to complete annual ethics training, and all new supervisors must complete an interactive ethics training module. Five bureaus require all employees to take annual ethics training. One bureau requires ethics briefings for employees traveling on official duty outside the United States. Five bureaus did not establish additional requirements.

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, Conducted surveys to identify common and emerging ethics risks, Talked to employees about the ethics concerns they encounter in the workplace.
Other (please specify)

  • Please explain other:
    One bureau did not assess 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, 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:
    In DO/HQ, after globally emailing two 2022 ethics newsletters and electronic guidance on a variety of topics, including digital assets, Hatch Act, and guidance on holiday gifts, DO/HQ had an influx of questions, showing that people read this guidance and it is effective. One bureau informally surveyed training participants on their perceptions of the training. Some bureaus did not evaluate the effectiveness of ethics education.

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 2022. 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
Outside employment/activities
  • Selection 3
Gift acceptance

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

25. Number of notification statements of negotiation or recusal under section 17(a) of the STOCK Act submitted to the ethics office in 2022 (see 5 C.F.R. 2635.602(a)):

  • Enter total
99

26. Number of 18 U.S.C. 208 waivers granted in 2022:

Number Granted in 2022
Number Sent to OGE
    a. 208(b)(1) waivers
10
10
    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
    Q24: Responses provided are consolidated based on topics and quantities reported by bureaus. However, in DO/HQ, we rank Gifts #1, Financial Disclosure #2, and COI #3.

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. Which electronic filing system(s) does your agency use?

  • Select one
Integrity and Other (specify)

  • Specify Other
    DO/HQ and four bureaus have implemented different OGE 450 custom e-filing programs.

30. Indicate for which forms your agency uses the "Other" e-filing system.

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

  • Provide the name of the other system:
    DO/HQ and four bureaus have implemented different OGE 450 custom e-filing programs.

31. Indicate your fiscal year 2022 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 2022
0		Don’t know/don’t track

b. Amount paid to a federal agency in FY 2022
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 2022
0		Don’t know/don’t track

  • Please explain "Don’t know/don’t track" answer above
    These are multiple systems for multiple bureaus and not all of them are parsed out by e-filing costs only they are part of larger contracts for IT services.

32. Indicate the number of filers who filed electronically in fiscal year 2022.

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

    b. confidential financial disclosure filers
4994

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

  • Additional Comments
    Q27 & 28: Most bureaus responded In All Cases, but since one or two bureaus responded Most, and one smaller bureau responded Never, we selected Most for the response.
    Q32: Number represents DO/HQ + four bureaus with e-filing.


PART 8. PUBLIC FINANCIAL DISCLOSURE

33. Report the number of public financial disclosure reports (OGE Form 278e) required to be filed by December 31, 2022, excluding SGEs, and the number of reports actually filed (i.e., received) by December 31, 2022.

OGE Form 278e Reports
PAS2
Non-Career SES3
Career SES3
Schedule C
Other4
TOTAL
a. New EntrantRequired
0
16
74
18
24
132
Filed
0
16
73
18
24
131
b. AnnualRequired
9
28
484
22
86
629
Filed
9
28
484
22
86
629
c. TerminationRequired
2
10
59
7
11
89
Filed
2
10
58
7
11
88
d. Combination1Required
0
3
5
1
1
10
Filed
0
3
5
1
1
10
    Total
Required
11
57
622
48
122
860
Filed
11
57
620
48
122
858

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 (or departed) the agency on December 15, 2022, and the employee filed a new entrant (or termination) report prior to the end of the calendar year, include the report in your required and filed numbers. If, on January 1, 2023, the employee has not filed a new entrant (or termination) report, do not count that report in your required numbers. Instead, include the report in your 2023 questionnaire response to be filed in 2024.

  • If applicable, please explain discrepancies between the number of reports required to be filed and the actual number of reports filed.
    At one bureau, upon the departure of a career SES employee and the promotion of an employee to act in the vacant position, it discovered that neither employee was informed of their termination and new entrant filing obligations, respectively. Both individuals have since been informed and its office is implementing an improved process with HR to ensure that these responsibilities are included in the checklist action items for incoming and departing SES employees.

34. 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 2022?
0
18
70
22
22
132
ii. Of those certified or closed in 2022, how many were initially reviewed within 60 days?
0
17
55
18
19
109
iii. Of those certified or closed in 2022, how many were certified or closed within 60 days?
0
14
42
15
17
88
b. Annual
PAS2
Non-Career SES3
Career SES3
Schedule C
Other4
TOTAL
i. How many reports did your agency certify or close in 2022?
11
25
467
25
87
615
ii. Of those certified or closed in 2022, how many were initially reviewed within 60 days?
11
18
391
22
81
523
iii. Of those certified or closed in 2022, how many were certified or closed within 60 days?
9
18
335
21
69
452
c. Termination
PAS2
Non-Career SES3
Career SES3
Schedule C
Other4
TOTAL
i. How many reports did your agency certify or close in 2022?
1
31
41
7
24
104
ii. Of those certified or closed in 2022, how many were initially reviewed within 60 days?
0
31
40
6
21
98
iii. Of those certified or closed in 2022, how many were certified or closed within 60 days?
0
27
39
6
7
79
d. Combination
PAS2
Non-Career SES3
Career SES3
Schedule C
Other4
TOTAL
i. How many reports did your agency certify or close in 2022?
0
4
5
1
1
11
ii. Of those certified or closed in 2022, how many were initially reviewed within 60 days?
0
2
4
1
1
8
iii. Of those certified or closed in 2022, how many were certified or closed within 60 days?
0
1
2
1
1
5
    Total
i. How many reports did your agency certify or close in 2022?
12
78
583
55
134
862
ii. Of those certified or closed in 2022, how many were initially reviewed within 60 days?
11
68
490
47
122
738
iii. Of those certified or closed in 2022, how many were certified or closed within 60 days?
9
60
418
43
94
624

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.
    In DO/HQ, filers slow to respond to inquiries in some cases, but primarily due to vacancy of ADAEO position for five months and one attorney position for more than two months vacancies caused increased workload for a minimal ethics staff who had constant competing priorities. For other bureaus, inadequate staffing, inexperienced ethics reviewers or reviewers with competing priorities, failure to reassign reports to new official after departure of office ethics team lead.

  • 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, remedial action was being taken
    other (specify)

  • Specify Other
    staffing issues and other issues as described under delayed review.

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

    • Periodic Transaction Reports Filed
715
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.

36. 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
139
14
4
    b. Number of OGE Form 278-T Reports
27
20
1

37. Number of public financial disclosure filers reported in calendar year 2022 to the Attorney General for failure to file.

  • Enter total
0

38. How many requests for public financial disclosure reports did you receive in 2022? Count each OGE Form 201 as one request, even if it contains a request for documents for multiple individuals.

  • Enter total
33

39. How many documents requested under the Ethics in Government Act did you release in calendar year 2022?

  • Enter total
0

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

  • Additional Comments
    Q33: At DO/HQ, Integrity numbers from the data pull may not be entirely accurate so we also relied on internal data.
    Q34: Remedial action including but not limited to recusal and divestiture.
    Q36: Integrity may reflect differences in late fee numbers for 278s and 278-Ts because these may have been incorrectly categorized—e.g., waivers for a 278-T were noted on a 278 that was timely filed. Filers are not required to file separate 278-T reports after already reporting the transactions on their 278e reports.
    Q39: Answer is Don’t know/Don’t track per Word doc selection.

PART 9. CONFIDENTIAL FINANCIAL DISCLOSURE

40. Report the number of confidential financial disclosure reports required to be filed by December 31, 2022, excluding SGEs, and the number of reports actually filed by December 31, 2022.

a. Required
b. Filed
10047
OGE Form 450
6946
OGE-approved alternate form
3088
Total
10047
10034

    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, 2022, 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, 2023 the employee has not filed a new entrant report, do not count that report in your required numbers. Instead, include the report in your 2023 questionnaire response to be filed in 2024.

    If applicable, please explain discrepancies between the number of reports required to be filed and the actual number of reports filed.
  • Explain, if applicable
    For most bureaus, employees were on extended admin/medical leave and deployed at one bureau, two employees on detail outside of agency who were required to file.

41. 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 2022?
b. Of those certified or closed in 2022, how many were initially reviewed within 60 days?
c. Of those certified or closed in 2022, how many were certified or closed within 60 days?
OGE Form 450 and OGE-approved alternative
9979
9765
9597

  • If applicable, please explain why some reports were reviewed more than 60 days after submission.
    In DO/HQ, overall, filers’ supervisors change/supervisors leave between the time of report submission and report review we are not always made aware of the changes and need to manually route the report to the correct supervisor, once that person is made known to us. New supervisors often have inquiries about identifying and resolving conflicts issues. Staffing changes in the Ethics office also led to fewer reminders to supervisors about the need to review and certify reports. (Although we have automated the reminder function, supervisors do not always receive those messages because they are filtered out by the email system or they go to a Spam folder.) Technical difficulties with e-filing program may also result in delayed reviews supervisors don’t always alert us timely if they encounter technical issues, and their review may have been close to the 60-day mark at that time. For many bureaus, additional information sought from filers who were delayed in responding for other bureaus, staffing/competing priorities and volume of reports administrative oversight or other errors and delay in obtaining form from prior agency for a filer who started late in the year accounted for delays. Note: At one bureau, an attorney was recently hired who will assist with the review of financial disclosure reports.

  • 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, remedial action was being taken
    other (specify)

  • Specify Other
    as explained for delay in review, above.

42. Number of OGE 450 or OGE-approved alternative forms granted filing extensions in 2022.

  • Enter number
101

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 2022 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.

a. Total number of disciplinary actions that met the above criteria
68

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

    i. Subpart A (General Provisions)
1

    ii. Subpart B (Gifts from Outside Sources)
0

    iii. Subpart C (Gifts between Employees)
0

    iv. Subpart D (Conflicting Financial Interests)
3

    v. Subpart E (Impartiality in Performing Official Duties)
0

    vi. Subpart F (Seeking Other Employment)
22

    vii. Subpart G (Misuse of Position)
25

    viii. Subpart H (Outside Activities)
16

    iv. Agency's supplemental Standards of Conduct
1

44. Number of disciplinary actions taken in 2022 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:

a. Disciplinary actions taken based on violation of ethics laws
0

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

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

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

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

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

    v. 5 U.S.C. app. section 104 or 18 U.S.C. section 1001 (Failure to File or Filing False Public Financial Disclosures)

    vi. 5 U.S.C. app. section 501 (Outside Earned Income)

    vii. 5 U.S.C. app. section 502 (Outside Activities)

45. Number of referrals made in 2022 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).

a. Referrals to Department of Justice
0

b. DOJ Referrals Status
Of the referrals to DOJ (line a.), please note the DOJ referral status:

    i. How many of those referrals were accepted for prosecution?

    ii. How many of those referrals were declined for prosecution?

    iii. How many of those referrals were pending DOJ’s decision as of December 31, 2022?

c. Agency Disciplinary Action Status
Of the referrals to DOJ (line a.), please note the agency disciplinary status:

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

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

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

    iv. 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?

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

46. 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
Not applicable because no covered referrals were made to DOJ

  • 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 (Executive Order 13989 ("Ethics Pledge"))

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, 2022? Note: For guidance on what constitutes a full-time non-career appointee for purposes of the Ethics Pledge, LA-21-07

  • Select answer
Yes

48. For each category of appointee, provide the number of full-time non-career appointees appointed between January 20 and December 31, 2022, 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 - 12/31/2022
10
2
15
21
0
48
    i. Signed the Ethics Pledge in 2022
8
1
15
21
0
45
    ii. Required to sign the Pledge in 2022 but signed in 2023
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
2
1
0
0
0
3
    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.

49. Registered Lobbyist/and or Registered under the Foreign Agents Registration Act

    a. How many appointees were registered lobbyists and/or registered under the Foreign Agents Registration Act during the two years prior to their appointment? For purposes of this question, please include individuals appointed between January 1 and December 31, 2022, and subject to the Ethics Pledge, as well as holdover appointees subject to the Pledge (if 0 skip to Q50).
0

    b. How many of those appointees were registered lobbyists and/or registered under the Foreign Agents Registration Act during the two years prior to their appointment have an ethics agreement addressing their obligations under paragraph 3 of the Ethics Pledge?

    c. For any of those appointees who do not have an ethics agreement, please provide their name and an explanation (e.g., Pledge paragraph 3 not reasonably expected to limit participation in any agency matters because appointee's duties sufficiently unrelated to prior lobbying activities).

50. Section 3 of Executive Order 13989 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 2022, the names of these individuals granted waivers in 2022, 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

51. Were there any violations of Executive Order 13989 during 2022?

  • Select Yes or No
No

52. Please provide information on enforcement actions taken in 2022 as a result of violations of the Executive Order 13989 Pledge (regardless of whether the violation itself took place in 2021 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.
    Q48: One political appointee signed the Pledge as a Non-Career SES in 2022, but was later confirmed and appointed as a PAS official (also in 2022, no break in service). As such, he is counted in both line i and line v.


PART 12. SPECIAL GOVERNMENT EMPLOYEES (SGEs)

53. How many Special Government Employees (SGEs) did your agency have, in total, during calendar year 2022? (If zero, skip to Additional Comments for this Part.)

  • Enter number
47

54. Initial Ethics Training

a. 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, 2022 (5 C.F.R. 2638.304(b)(2))?

Total number
36

    i. How many of those SGEs received IET before or at the beginning of the first meeting?
35

    ii. How many of those SGEs received IET after the first meeting?
1

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

    If applicable, please explain why some SGEs received IET after the first meeting or have yet to receive IET.
      One SGE member was appointed late in the calendar year.

55. Report the number of SGE public and confidential financial disclosure reports required to be filed by December 31, 2022 and the number of reports actually filed by December 31, 2022.

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
17
0
0
b. Advisory Committee Members (non-FACA)
19
19
0
0
c. Experts/Consultants
6
6
0
0
d. Board Members
0
0
1
1
e. Commissioners
0
0
0
0
f. Other
0
0
0
0
TOTAL
42
42
1
1

    Example for new entrant and termination reports: If an employee joined (or departed) the agency on December 15, 2022, and filed a new entrant (or 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 (or termination) report, do not count that report in your required numbers. Instead, include the report in your 2023 questionnaire response to be filed in 2024.

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

56. 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 2022?
42
1
b. Of those certified or closed in 2022, how many were initially reviewed within 60 days?
42
1
c. Of those certified or closed in 2022, how many were certified or closed within 60 days?
40
1

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

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

    other (specify)

  • Specify Other
    as noted above.

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

  • Enter number
4

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

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

      b. Number of OGE Form 450 or OGE-Approved Alternative Forms
0

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