2023 AGENCY ETHICS PROGRAM QUESTIONNAIRE

Status >>>
Submitted and Locked
<<< Status

Here is the unique link to your questionnaire (the link below)

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 5 U.S.C. § 13122(e)(1)). Your response to OGE’s Annual Ethics Program Questionnaire (the 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, 2024. (5 C.F.R. § 2638.207(a)).

PART 2. INSTRUCTIONS

Your response to this questionnaire should reflect the 2023 calendar year (i.e., 1/1/2023 through 12/31/2023), 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 2022 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.

FAQ's:

Which Internet browser should I use?

How do I save a draft of my response?

How do I access my saved draft and edit the questionnaire?

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?

Can I increase the font size?

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 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, D.C.; 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, 2023
94454

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

a. Vacant (as of December 31, 2023)?
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
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, 2023)?
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 2023 (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
34
44
16
4
9
107
b. Outside the D.C. Metro area
61
32
5
0
3
101
TOTAL
95
76
21
4
12
208

* FTE = Full Time Equivalent

Example: The table below provides an example of an agency with 13 employees that performed ethics
program duties in 2023.

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)

  • 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 2023?

  • 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 2023 (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)

    Recommendations still being considered (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)
    The ADAEO evaluated all of the Treasury bureau ethics programs, including program administration financial disclosure training, and advice and counsel. Programs well-administered overall. Most feedback provided for financial disclosure review to meet regulatory and OGE technical review standards. The programmatic changes were varied among bureaus and include: updating ethics training presentations and reviewing additional methods of disseminating ethics information to employees developing and implementing a new process to better track and aggregate data related to the type of legal advice given regarding conflicts of interests improving consistency in providing cautionary guidance to financial disclosure filers more frequent outreach to employees on ethics issues, regular 278 reminders, improvements to financial disclosure review/notation procedures, improved guidance to HR and training personnel and increasing the number of ethics staff directly engaged in managing the intake and reviews of financial disclosures to increase attention to technical compliance. One bureau hopes to hire an FTE as the ethics program lead to improve its current structure of three FTEs performing duties in other program areas in addition to ethics.
    Policy changes: At one bureau, policy changes were made to reflect revisions to bureau designations of positions as confidential filers.
    Recommendations still being considered: At one bureau, implementation of possible programmatic changes are currently under consideration by new leadership others are considering or have implemented suggestions/recommendations from the ADAEO program review.

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

14. Did your agency head or DAEO evaluate, prior to November 5, 2023, whether your agency's ethics program has an adequate number of trained agency ethics officials to deliver effective support in the event of a Presidential transition (5 C.F.R. § 2638.210(a))?

  • Select answer
Yes

  • Please explain

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

  • Additional Comments
    Q6: N/A for most bureaus. Q9: A couple of bureaus expressed the need for more Human Capital resources, one expressed additional need for IT, and one indicated it is preparing hiring justification for an additional ethics specialist. Q11: For DO/HQ, individual program reviews of Treasury bureaus conducted in 2023. Most bureaus conducted a program evaluation. As a part of one bureau’s annual internal controls audit, a private auditing firm evaluated certain aspects of that bureau’s ethics program.

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. 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, 2023? Exclude SGEs that were expected to serve less than 60 days on a board, commission, or committee.
Total Number
3
    i. How many new agency leaders received their briefing within 15 days of their appointment?
3
    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.

18. 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, 2023 (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
4989
    i. How many of those employees received IET within the 3-month requirement?
4714
    ii. How many of those employees received IET beyond the 3-month requirement?
195
    iii. How many of those employee have not received IET as of today?
80
    iv. Do not track

Example: If an employee started at the agency on December 15, 2023, 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, 2024, the employee has not completed IET, do not count that employee in your required numbers. Instead, include the employee in your 2024 questionnaire response to be filed in 2025.

  • If applicable, please explain why some employees received IET beyond the 3-month requirement or have yet to receive IET.
    Most employees completed the required training in 100 days and many received at least a copy of the Treasury Ethics Handbook, but a variety of issues contributed to the delay, including: technology malfunctions with training assignments and computer access employees not taking training despite repeated reminders conflicts with mandatory off-site federal law enforcement training administrative errors and misunderstanding/miscommunication with the office responsible for assigning training. For the 80 employees who did not receive IET, 77 were from one bureau and over half of which were employees that departed during CY2023 prior to completing IET. Nearly all employees have now taken the training, and these issues have been addressed and processes improved at the respective bureaus.

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 2023?

  • 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)
710
708

    c. Confidential filers (OGE Form 450 and OGE-approved alternative confidential financial disclosure forms)
9719
9623

    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
10431
10333

  • If applicable, please explain discrepancies between the number of employees who were required to receive training and the number of employees who received training:
    At DO/HQ and several bureaus, extended illness/leave or family leave deployed some did not complete training despite reminders follow-up pursued. At one bureau, due to ongoing internal reorganization and shifting of employee responsibilities, many who did not complete training appear to have changed responsibilities, and the bureau is working with management to confirm filing status. At another bureau, technical issues prevented receipt of training completion reports for several weeks in December, hindering the ability to follow up with employees.

22. 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., 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
    a. At one bureau, Ethics Officials are requested to take OGE offered courses during the year.
    b. For DO/HQ, we required new entrant public filers who onboarded before August 1, 2023 and confidential filers who onboarded before June 1 to attend annual ethics training. All new supervisors must complete an interactive ethics training module. At one bureau, ethics briefing for employees traveling on official duty outside the United States. Six bureaus require ethics training for all employees.

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, 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 reviewed training modules and increased focus on conflicts of interest/impartiality to address issues raised in that area, with a particular emphasis on moving between private sector and government.

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, 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., Incorporated inclusivity principles in the development and delivery of ethics education, Ensured ethics education was accessible (508 compliant) to participants
Other (please specify)

  • Please explain other:
    Similar to 2022, in DO/HQ, after globally emailing two ethics newsletters (Spring and Holiday editions) and electronic guidance on Hatch Act and on holiday gifts, DO/HQ had an influx of questions, showing that people read this guidance and it is effective.
    One bureau conducted a focus group and online survey to better inform our thinking on training and communication needs via its intranet ethics website.
    Another bureau continues to informally canvas training participants on their perceptions of the training.

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

  • Additional Comments
    Q16: Our answer is "All" offers of employment included...The system shows the question without any responses to it.

PART 6. ADVICE, COUNSELING, AND REMEDIES

25. From the list below, select the three topics that your employees most frequently sought guidance on in 2023. 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
Financial Disclosure Reporting
  • Selection 3
Gift acceptance

  • 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 2023 (see 5 C.F.R. § 2635.602(a)):

  • Enter total
78

27. Number of 18 U.S.C. § 208 waivers granted in 2023:

Number Granted in 2023
Number Sent to OGE
    a. 208(b)(1) waivers
5
5
    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
    Q25: Many of the inquiries for financial disclosure cover conflicts of interest.

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. Were all public and confidential financial reports, in calendar year 2023, filed using an electronic filing system?

  • Select one
No

31. Indicate which forms your agency uses. Check all that apply.

  • Check all that apply
450 (pdf), 450 (excel)

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

  • Select one
Integrity and Other (specify)

  • Specify Other
    DO/HQ: OGE 450 e-filing in Sharepoint linked to ethics DB Other bureaus: Sharepoint site an internally developed Salesforce application named “Disclosure” that enables the uploading, review and storage of signed PDF versions of the OGE Form 450 Ethics Management System (EMS) Bureau-developed OGE Form 450 filing system.

33. 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:
    As indicated in Q32: DO/HQ: OGE 450 e-filing in Sharepoint linked to ethics DB other bureaus: Sharepoint site an internally developed Salesforce application named “Disclosure” that enables the uploading, review and storage of signed PDF versions of the OGE Form 450 Ethics Management System (EMS) Bureau-developed OGE Form 450 filing system.

34. Indicate your fiscal year 2023 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 2023Don’t know/don’t track
Don’t know/don’t track

b. Amount paid to a federal agency in FY 2023Don’t know/don’t track
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 2023Don’t know/don’t track
Don’t know/don’t track

  • Please explain "Don’t know/don’t track" answer above
    We only use Integrity for public filers, but program will not allow us to leave blank. We do not track these costs for confidential.

35. Indicate the number of filers who filed electronically in fiscal year 2023.

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

    b. confidential financial disclosure filers
5485

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

  • Additional Comments
    For Q28 & 29: Most bureaus responded In All Cases. However, since one or two responded Most, and one smaller bureau responded Never, we selected Most for the response.
    Questions 30-35: The Salesforce Disclosure application discussed above does not enable confidential filers to enter information into the system electronically. Confidential filers must complete and sign PDF versions of their OGE Form 450s outside the Disclosure system. Confidential filers subsequently upload their completed PDF forms into the Disclosure system so that the forms can be tracked, reviewed and stored using the Disclosure system.


PART 8. PUBLIC FINANCIAL DISCLOSURE

36. Report the number of public financial disclosure reports (OGE Form 278e) required to be filed by December 31, 2023, excluding SGEs, and the number of reports actually filed (i.e., received) by December 31, 2023.

OGE Form 278e Reports
PAS2
Non-Career SES3
Career SES3
Schedule C
Other4
TOTAL
a. New EntrantRequired
0
6
81
30
32
149
Filed
0
6
81
30
32
149
b. AnnualRequired
22
34
470
31
96
653
Filed
22
34
470
31
96
653
c. TerminationRequired
1
6
48
8
19
82
Filed
1
6
48
8
19
82
d. Combination1Required
0
0
4
7
0
11
Filed
0
0
4
7
0
11
    Total
Required
23
46
603
76
147
895
Filed
23
46
603
76
147
895

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, 2023, 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, 2024, 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 2024 questionnaire response to be filed in 2025.

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

37. 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 2023?
0
5
80
30
34
149
ii. Of those certified or closed in 2023, how many were initially reviewed within 60 days?
0
5
76
30
33
144
iii. Of those certified or closed in 2023, how many were certified or closed within 60 days?
0
5
59
30
28
122
b. Annual
PAS2
Non-Career SES3
Career SES3
Schedule C
Other4
TOTAL
i. How many reports did your agency certify or close in 2023?
21
25
471
31
97
645
ii. Of those certified or closed in 2023, how many were initially reviewed within 60 days?
21
25
416
31
94
587
iii. Of those certified or closed in 2023, how many were certified or closed within 60 days?
21
25
355
31
81
513
c. Termination
PAS2
Non-Career SES3
Career SES3
Schedule C
Other4
TOTAL
i. How many reports did your agency certify or close in 2023?
1
31
41
8
24
105
ii. Of those certified or closed in 2023, how many were initially reviewed within 60 days?
1
31
40
8
21
101
iii. Of those certified or closed in 2023, how many were certified or closed within 60 days?
1
27
39
8
17
92
d. Combination
PAS2
Non-Career SES3
Career SES3
Schedule C
Other4
TOTAL
i. How many reports did your agency certify or close in 2023?
1
0
4
7
0
12
ii. Of those certified or closed in 2023, how many were initially reviewed within 60 days?
1
0
4
7
0
12
iii. Of those certified or closed in 2023, how many were certified or closed within 60 days?
1
0
3
7
0
11
    Total
i. How many reports did your agency certify or close in 2023?
23
61
596
76
155
911
ii. Of those certified or closed in 2023, how many were initially reviewed within 60 days?
23
61
536
76
148
844
iii. Of those certified or closed in 2023, how many were certified or closed within 60 days?
23
57
456
76
126
738

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.
    Most reports had their initial reviews completed within 60 days. However, competing workload priorities and staffing, especially for employees who do not perform ethics duties full-time, caused delay at some bureaus. In other cases, contacting filers for additional information and awaiting responses and not adequately documenting contacts with filers in Integrity regarding initial reviews and follow-up.

  • 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
    As stated above, in previous response. In one case, additional info was being sought and delayed because filer out of country on travel additional follow-up with filers slow to respond staffing issues and competing priorities, especially for ethics officials who are not dedicated to ethics full-time.

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

    • Periodic Transaction Reports Filed
659
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 space above. Example 2: If an employee files one report each month, each report is counted separately. Report “12”.

39. 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
168
12
2
    b. Number of OGE Form 278-T Reports
11
30
1

40. Number of public financial disclosure filers reported in calendar year 2023 to the Attorney General for failure to file.

  • Enter total
0

41. How many requests for public financial disclosure reports did you receive in 2023? Count each OGE Form 201 as one request, even if it contains a request for documents for multiple individuals.

  • Enter total
9

42. How many documents requested under the Ethics in Government Act did you release in calendar year 2023?

  • Enter total
75

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

  • Additional Comments
    For DO/HQ, for Q39, the late fee waivers granted are incorrect in Integrity because some reviewers categorized the late fee under the OGE 278e rather than as a 278-T waiver. Moreover, Integrity does not capture multiple 278-T waivers granted to a filer for more than one required 278-T report. One other bureau also notes that all late fee waivers for 278e reports were for transactions listed on the 278e reports that were not timely reported on a 278-T, not because the 278e itself was filed late. Q42: For DO/HQ, approximately 75 OGE 278es and 278-Ts released in 2023. We do not track.

PART 9. CONFIDENTIAL FINANCIAL DISCLOSURE

43. Report the number of confidential financial disclosure reports required to be filed by December 31, 2023, excluding SGEs, and the number of reports actually filed by December 31, 2023.

a. Required
b. Filed
10311
OGE Form 450
7074
OGE-approved alternate form
3208
Total
10311
10282

    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, 2023, 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, 2024 the employee has not filed a new entrant report, do not count that report in your required numbers. Instead, include the report in your 2024 questionnaire response to be filed in 2025.

    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 or other leave.
    At one bureau, after a change of responsibilities in HR, ethics counsel was not notified of promotions to positions requiring 450s. Seventeen were missed and have since been notified of the need to file.

44. 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 2023?
b. Of those certified or closed in 2023, how many were initially reviewed within 60 days?
c. Of those certified or closed in 2023, how many were certified or closed within 60 days?
OGE Form 450 and OGE-approved alternative
10282
10238
9999

  • If applicable, please explain why some reports were reviewed more than 60 days after submission.
    In DO/HQ, overall, filers’ supervisors change/supervisors leave (or in one case, go on a long-term detail) 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. In one case, we had a complex family trust with assets that could not be sold, and it took time to resolve the conflict issues with a new supervisor who inherited the form for review. In another case, we could not remediate the conflicts, and the filer was unwilling to divest and was eventually reassigned to a different office. In other cases, 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. At other bureaus, obtaining additional information from filers competing priorities with staffing/workload and filers on extended leave contributed to delays.

  • 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 in delay for review also admin error by certifying official--14 reports were certified the week after the deadline workload/competing priorities for ethics officials who are not performing ethics duties full-time.

45. Number of OGE 450 or OGE-approved alternative forms granted filing extensions in 2023.

  • Enter number
133

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

46. Number of disciplinary actions taken in 2023 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
60

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

    i. Subpart A (General Provisions)
0

    ii. Subpart B (Gifts from Outside Sources)
0

    iii. Subpart C (Gifts between Employees)
0

    iv. Subpart D (Conflicting Financial Interests)
2

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

    vi. Subpart F (Seeking Other Employment)
0

    vii. Subpart G (Misuse of Position)
19

    viii. Subpart H (Outside Activities)
35

    iv. Agency's supplemental Standards of Conduct
5

47. Number of disciplinary actions taken in 2023 based wholly or in part upon violations of the criminal conflict of interest statutes (18 U.S.C. §§ 203, 205, 208, and 209), failure to file or filing false public financial disclosures (5 U.S.C. § 13106 or 18 U.S.C. § 1001), a civil matter involving outside earned income (5 U.S.C. § 13143), or outside activities (5 U.S.C. § 13144). 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. § 203 (Compensation in Matters Affecting the Government)

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

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

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

    v. 5 U.S.C. § 13106 or 18 U.S.C. § 1001 (Failure to File or Filing False Public Financial Disclosures)

    vi. 5 U.S.C. § 13143 (Outside Earned Income)

    vii. 5 U.S.C. § 13144 (Outside Activities)

48. Number of referrals made in 2023 to the Department of Justice (DOJ) of potential violations of the conflict of interest statutes (18 U.S.C. §§ 203,205, 207, 208, 209), failure to file or filing false public financial disclosures (5 U.S.C. § 13106 or 18 U.S.C. § 1001), a civil matter involving outside earned income (5 U.S.C. § 13143), or outside activities (5 U.S.C. § 13144).

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, 2023?

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?

49. 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
    Q46: One bureau noted: There were six actions but one of them had charges that fell under two different sections.

PART 11. ETHICS PLEDGE ASSESSMENT (Executive Order 13989 ("Ethics Pledge"))

50. 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, 2023? Note: For guidance on what constitutes a full-time non-career appointee for purposes of the Ethics Pledge, LA-21-07

  • Select answer
Yes

51. For each category of appointee, provide the number of full-time non-career appointees appointed between January 20 and December 31, 2023, 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
1
6
33
0
42
    i. Signed the Ethics Pledge in 2023
1
1
6
31
0
39
    ii. Required to sign the Pledge in 2023 but signed in 2024
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
1
0
0
2
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.

52. 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, 2023, and subject to the Ethics Pledge, as well as holdover appointees subject to the Pledge (if 0 skip to Q53).
0

    b. How many of those appointees who 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).

53. 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 2023, the names of these individuals granted waivers in 2023, 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
2
Chief Marilynn Malerba
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

54. Number of violations, if any, of Executive Order 13989 in 2023.
0

55. Number of enforcement actions, if any, taken in 2023 as a result of violations of the Executive Order 13989 (regardless of whether the violation itself took place in 2023 or earlier).
0

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)

56. How many Special Government Employees (SGEs) did your agency have, in total, during calendar year 2023? (If zero, skip to Additional Comments for this Part.)

  • Enter number
51

57. 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, 2023 (5 C.F.R. § 2638.304(b)(2))?

Total number
26

    i. How many of those SGEs received IET before or at the beginning of the first meeting?
26

    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?
0

    If applicable, please explain why some SGEs received IET after the first meeting or have yet to receive IET.

58. Report the number of SGE public and confidential financial disclosure reports required to be filed by December 31, 2023 and the number of reports actually filed by December 31, 2023.

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
11
11
0
0
d. Board Members
0
0
1
1
e. Commissioners
0
0
0
0
f. Other
0
0
0
0
TOTAL
47
47
1
1

    Example for new entrant and termination reports: If an employee joined (or departed) the agency on December 15, 2023, 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 2024 questionnaire response to be filed in 2025.

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

59. 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 2023?
46
1
b. Of those certified or closed in 2023, how many were initially reviewed within 60 days?
46
1
c. Of those certified or closed in 2023, how many were certified or closed within 60 days?
46
1

  • 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

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

  • Enter number
0

61. 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
1
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
    Q57: For DO/HQ, one SGE public filer is a member of the IRS Oversight Board who received annual training in a session with with our other public filers. The member is a term appointee who is not reappointed each year and files the OGE 278e without regard to the number of days served by virtue of the appointment under 26 U.S.C. 7802. The Board has not conducted business in many years because this filer is currently the sole member and continues to file until termination of appointment.

    Q61: For DO/HQ, one SGE public filer, for whom it was determined OGE 278-Ts are required, was granted a waiver of the late filing fee for a 278-T.

ADDITIONAL QUESTIONNAIRE COMMENTS:

  • Additional Comments

      OGE Form 450A
0
hidden element