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 Veterans Affairs

2. Employees

  • Number of full-time agency employees as of December 31, 2022
425729

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

a. Vacant (as of December 31, 2022)?
Yes (skip to #4a)

b. Time in current DAEO position

c. Total years performing ethics duties

d. Percent of time spent on ethics

e. Is the DAEO a career employee or a political appointee?

f. Number of reporting levels between the DAEO and the agency head.

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

a. Vacant (as of December 31, 2022)?
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 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
3
1
1
0
4
9
b. Outside the D.C. Metro area
93
0
0
0
17
110
TOTAL
96
1
1
0
21
119

* 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
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
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

    Human Capital

  • 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)
    Program changes: Created Deputy DAEOs in each VA administration (VBA, VHA, NCA and OIT), and added Deputy Ethics Officials (trained VHA Compliance Officers in basic ethics issues). We continue to support them via continued consultation.
    Policy changes: Late fee notices and establishing electronic payment of late fees to ease administrative processing and improve compliance. Added a GS-15 attorney to manage the financial disclosure program. Alt-450 became an electronically processed document.

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
    3. DAEO Catherine Mitrano retired effective 12/31/2022. Former DAEO, Michael R. Hogan, was designated as DAEO effective 01/04/2023. Mr. Hogan is a career employee with the required ethics experience and authority. The DAEO reports directly to the Secretary.

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
2
    i. How many new agency leaders received their briefing within 15 days of their appointment?
2
    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.
    n/a

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
34882
    i. How many of those employees received IET within the 3-month requirement?
23377
    ii. How many of those employees received IET beyond the 3-month requirement?
6182
    iii. How many of those employee have not received IET as of today?
5323
    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.
    Incomplete notification of new entrant status and decentralized HR Management Offices. Some individual VA facilities cover the IET in their local onboarding and may not record individual training modules in the Talent Management System this includes National Cemetery Administration (NCA) staff who work outdoors and do not have computer access.

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?

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

  • Please Explain why not all offices:
    Incomplete notification of new entrant status and decentralized HR Management Offices. Some individual VA facilities cover the IET in their local onboarding and don't report that to Ethics. See above regarding NCA. Annual filers are reminded of their ethics training obligation during the CFD filing season.

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)
781
781

    c. Confidential filers (OGE Form 450 and OGE-approved alternative confidential financial disclosure forms)
12024
11026

    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
12807
11809

  • If applicable, please explain discrepancies between the number of employees who were required to receive training and the number of employees who received training:
    Annual ethics training is assigned electronically in the Talent Management System. Ethics does not track individually. Individual supervisors monitor their employees. Contracting officers are counted in the CFD filers. The annual financial disclosure report filing communications are used as an opportunity to remind filers of their training requirements.

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 employees performing ethics duties described in 5 C.F.R. 2638.104-105 (ethics and human resources officials) Please describe.

  • Please Describe
    VA requires all employees to receive annual ethics training. It is assigned and provided electronically. Our records show an overall government ethics training completion rate of 91.76%. This does not include SES, who receive live training every year. Some employees who do not have computer access, such as cemetery workers, may not show as having received the training.

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


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.

  • Please explain other:

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


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

  • Please explain other:
    Annual client satisfaction survey. Post-virtual training surveys.

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

  • Additional Comments
    VA requires annual ethics training for all employees. We estimate that approximately 390,600 employees, including PFD and CFD filers, received government ethics training in CY 2022.

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
Outside employment/activities
  • Selection 2
Conflicting financial interests
  • 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
21

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
    n/a

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
    Army Financial Data Management System (FDM)

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:
    Army Financial Data Management System (FDM)

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
0

b. Amount paid to a federal agency in FY 2022
0
259289

c. Amount for all internal costs associated with operating an e-filing system (e.g., FTE, overhead, etc.) in FY 2022Don’t know/don’t track
Don’t know/don’t track

  • Please explain "Don’t know/don’t track" answer above
    VA doesn't break out personnel costs in administering its financial disclosure program. VA uses Army's FDM system for confidential financial disclosure.

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
11812

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

  • Additional Comments
    n/a


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
18
64
8
35
125
Filed
0
17
64
8
35
124
b. AnnualRequired
11
40
435
15
123
624
Filed
11
40
432
15
123
621
c. TerminationRequired
0
9
49
1
10
69
Filed
0
9
47
1
10
67
d. Combination1Required
0
0
1
0
0
1
Filed
0
0
1
0
0
1
    Total
Required
11
67
549
24
168
819
Filed
11
66
544
24
168
813

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.
    Incomplete notification of new entrant or termination status. Annual filers were notified and received late fees for failure to file timely.

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
19
67
8
33
127
ii. Of those certified or closed in 2022, how many were initially reviewed within 60 days?
0
18
66
8
33
125
iii. Of those certified or closed in 2022, how many were certified or closed within 60 days?
0
18
58
8
32
116
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
42
435
14
123
625
ii. Of those certified or closed in 2022, how many were initially reviewed within 60 days?
11
39
433
14
123
620
iii. Of those certified or closed in 2022, how many were certified or closed within 60 days?
10
31
370
11
108
530
c. Termination
PAS2
Non-Career SES3
Career SES3
Schedule C
Other4
TOTAL
i. How many reports did your agency certify or close in 2022?
0
9
54
2
11
76
ii. Of those certified or closed in 2022, how many were initially reviewed within 60 days?
0
9
53
1
10
73
iii. Of those certified or closed in 2022, how many were certified or closed within 60 days?
0
0
0
0
0
0
d. Combination
PAS2
Non-Career SES3
Career SES3
Schedule C
Other4
TOTAL
i. How many reports did your agency certify or close in 2022?
11
70
557
24
167
829
ii. Of those certified or closed in 2022, how many were initially reviewed within 60 days?
11
66
553
23
166
819
iii. Of those certified or closed in 2022, how many were certified or closed within 60 days?
10
57
479
20
150
716
    Total
i. How many reports did your agency certify or close in 2022?
22
140
1113
48
334
1657
ii. Of those certified or closed in 2022, how many were initially reviewed within 60 days?
22
132
1105
46
332
1637
iii. Of those certified or closed in 2022, how many were certified or closed within 60 days?
20
106
907
39
290
1362

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.
    Reviewer caseloads and filers waiting until the last minute to file.

  • 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

  • Specify Other
    NA

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

    • Periodic Transaction Reports Filed
305
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
53
1
7
    b. Number of OGE Form 278-T Reports
7
1
1

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

  • Enter total
1

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
11

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

  • Enter total
131

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

  • Additional Comments
    n/a

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
12024
OGE Form 450
11812
OGE-approved alternate form
0
Total
12024
11812

    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
    These are generally employees who left filing positions and Ethics did not receive notice from local HR offices.

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
11812
11647
11412

  • If applicable, please explain why some reports were reviewed more than 60 days after submission.
    Reviewer caseloads seeking additional information from filers.

  • 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

  • Specify Other
    NA

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

  • Enter number
153

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

  • Additional Comments
    Due to PIV card issues and FDM server difficulties, a number of extensions were granted. Q.42 153 extensions were granted for OGE-450. The Alt-450 is used only for vetting proposed VA Research projects for conflicts. The information disclosed on these reports may disclose the need for a waiver under 18 USC 208(b)(1), which is coordinated with OGE.

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
0

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

    i. Subpart A (General Provisions)

    ii. Subpart B (Gifts from Outside Sources)

    iii. Subpart C (Gifts between Employees)

    iv. Subpart D (Conflicting Financial Interests)

    v. Subpart E (Impartiality in Performing Official Duties)

    vi. Subpart F (Seeking Other Employment)

    vii. Subpart G (Misuse of Position)

    viii. Subpart H (Outside Activities)

    iv. Agency's supplemental Standards of Conduct

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
1

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?
1

    ii. How many of those referrals were declined for prosecution?
0

    iii. How many of those referrals were pending DOJ’s decision as of December 31, 2022?
0

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?
0

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

    iii. Of the cases referred to DOJ, how many are pending a determination as to whether disciplinary or corrective action will be taken?
0

    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?
1

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

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
Yes

  • Please Specify Why

ADDITIONAL COMMENTS FOR PART 10. Please indicate the question number to which the comment corresponds.

  • Additional Comments
    Q.43. For last year’s AQ, the Ethics Specialty Team attempted to obtain information Department-wide on disciplinary actions based on Standards of Conduct violations. We concluded, however, that the number we obtained from that process is likely very inaccurate. We are currently in the process of developing a more reliable way to track and compile that information. In the meantime, we are reporting zero disciplinary actions this year for Q43 rather than provide a number with no actual informational value. Q.44. VA does not track this information. Q.45. The DOJ referral was for failure to fully disclose information on a public financial disclosure report. After DOJ filed suit, the filer complied with the requirements and DOJ dismissed the case.

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
2
7
2
3
0
14
    i. Signed the Ethics Pledge in 2022
2
7
2
3
0
14
    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
0
0
0
0
0
0
    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.
    n/a

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

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

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).
1

    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?
0

    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).

    Maureen Elias received an ethics pledge waiver. See below.

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
1
Maureen Elias
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
    n/a

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.
    n/a


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
1059

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
306

    i. How many of those SGEs received IET before or at the beginning of the first meeting?
289

    ii. How many of those SGEs received IET after the first meeting?
0

    iii. How many of those SGEs have not received IET as of today?
17

    If applicable, please explain why some SGEs received IET after the first meeting or have yet to receive IET.
      17 SGEs will receive IET at the first meeting in CY 2023.

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)
101
101
2
2
b. Advisory Committee Members (non-FACA)
0
0
0
0
c. Experts/Consultants
0
0
0
0
d. Board Members
0
0
0
0
e. Commissioners
0
0
0
0
f. Other
0
0
0
0
TOTAL
101
101
2
2

    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.
    n/a

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?
101
2
b. Of those certified or closed in 2022, how many were initially reviewed within 60 days?
101
2
c. Of those certified or closed in 2022, how many were certified or closed within 60 days?
101
2

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

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

  • Specify Other
    NA

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

  • Enter number
959

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
    Q53. This number reflects SGEs on Parent Committees and on some Merit Review Boards/subcommittees.

ADDITIONAL QUESTIONNAIRE COMMENTS:

  • Additional Comments
    n/a

      OGE Form 450A
0
hidden element