| US OGE

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 Defense - Department of the Army

2. Employees

Number of full-time agency employees as of December 31, 2023

655655

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

a. Vacant (as of December 31, 2023)?

b. Time in current DAEO position

1 - 4 years

c. Total years performing ethics duties

1 - 4 years

d. Percent of time spent on ethics

0-25%

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

Political employee

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, 2023)?

b. Time in current ADAEO position

1 - 4 years

c. Total years performing ethics duties

1 - 4 years

d. Percent of time spent on ethics

0-25%

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

Political 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	24	24	14	4	10	76
b. Outside the D.C. Metro area	430	600	103	52	215	1400
TOTAL	454	624	117	56	225	1476

* 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.)
Administrative support (e.g., tracking filing or training requirements, sending reminders, data entry, etc.)
Substantive ethics support (e.g., providing training, initial review of financial disclosures, drafting advice for further review, etc.)

Please describe IT support (optional)
Only one of the Army's subordinate organizations uses contractors in this manner. a small portion of the entire Army. These contractors monitor the organization's ethics email inbox, track incoming requests for ethics support, track filing and training requirements, and conduct initial reviews of financial disclosure reports.

Please describe administrative support (optional)
These contractors monitor the organization's ethics email inbox, track incoming requests for ethics support, and track filing and training requirements.

Please describe substantive support (optional)
These contractors also conduct initial reviews of financial disclosure reports.

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

Please provide the name(s) of the federal agency or entity:

Describe the services or support received:

8. Did your agency provide ethics program services or support for any board, commission, or agency that is independant of your agency?

Select Yes or No

Yes

Please provide the name(s) of the board, commission, or agency:
The Army's Financial Disclosure Management (FDM) program provided financial disclosure report filing support to the Office of the Secretary of Defense, Department of the Air Force and Navy, Armed Services Board of Contract Appeals, Defense Contract Audit Agency, Defense Counterintelligence and Security Agency, Defense Commissary Agency, State Department, Defense Financial Accounting Service, Department of of Homeland Security, Defense Intelligence Agency, Defense Information Systems Agency, Defense Logistics Agency, Department of Defense Inspector General, Defense Threat Reduction Agency, National Geospatial-Intelligence Agency, Office of Government Ethics, Special Inspector General of Afghan Reconstruction, United States National Guard, Uniformed Services University of the Health Sciences, Armed Forces Retirement Home, and the Department of Veterans Affairs.

Describe the services or support provided:
The FDM System is the Office of Government Ethics (OGE) approved on-line filing system and database used for each and every DoD OGE 450 filed by all DoD regular employees and service members, and the filing employees of several civilian departments and agencies listed above, to comply with the Ethics in Government Act and implementing regulations governing filing, review, and compliance reporting for OGE 450 Confidential Financial Disclosure reports and annual ethics training. In addition to providing the basic filing system, the FDM system provides users assistance with user logon issues and other issues that impact the filing and review of OGE 450s. The system also provides a function that allows agencies to track annual ethics training.

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

Select type of resources

Human Capital, Technology

Specify Other
NA

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

An entity outside of my agency, other than OGE, (e.g., GAO or a private auditing firm) conducted an evaluation (please describe)

Please Describe:
The Army continued its program of reviewing subordinate office ethics programs. Also, the Department of Defense Inspector General’s contracted Audit Team (KPMG) conducted an audit of the Army’s Ethics Program, and the Department of Defense Inspector General started a review of all the Department of Defense OGE 278e filings.

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)
In addition to continuing to build upon the programmatic and policy changes described in last year’s report, the Army established procedures regarding timely and interactive initial ethics training, revised its Post Government Employment Guides, and established accountability measures for timely initial and annual ethics training.

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
In question 5, it appears that personnel performing ethics duties for only a portion of their workweek are counted as FTEs in the same manner as those who work ethics on a full-time basis. For example, we list 117 employees who work ethics matters for "11-20 hours per week (up to .5 FTE)" which should amount to no more than 56.5 FTEs, but is listed as 117 FTEs. This creates the appearance that the Department of Army is adequately staffed with ethics personnel, which is not the case since most of our ethics officials do not work ethics matters full-time.

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		1
i. How many new agency leaders received their briefing within 15 days of their appointment?		1
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		98621
i. How many of those employees received IET within the 3-month requirement?		98004
ii. How many of those employees received IET beyond the 3-month requirement?		411
iii. How many of those employee have not received IET as of today?		206
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.
Some employees discontinued their Federal employment within 90 days of appointment without completing initial ethics training. Some of the initial ethics training was entered as annual ethics training in the training database. Some HR offices continued to be challenged with providing timely HR notification of new employees to the relevant ethics offices. Reorganizations, deployment to locations where ethics training was not available, HR and ethics personnel turn-over, and ethics counselor unfamiliarity with IET provisions also played a part. In one instance, the HR office discontinued in September to require new employees to complete IET, which the servicing ethics office didn’t discover until asking about it in November. The Army is in process of providing IET to these personnel.

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)

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

910

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

42368

42021

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.)

TOTAL

43279

42932

If applicable, please explain discrepancies between the number of employees who were required to receive training and the number of employees who received training:
Extended medical and military leaves, overseas deployments, and inaccurate accounting cover some of these discrepancies.

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., My agency established additional training procedures (e.g., certification procedures). See 5 C.F.R. § 2638.309(c). Please describe.

Please Describe
The Army continued its DAEO-mandated ethics counselor continued education program, requiring an hour of additional ethics training for all ethics counselors. Many ethics counselors used OGE-developed online training to fulfill this requirement. Also, inspectors general, financial, and acquisition professionals performed annual ethics training. Additional accountability measures were established for annual and initial ethics training shortfalls.

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:
The Army continued to assess the content of ethics training instruction during ethics staff assistance visits, instruct on ethics topics at the incoming quarterly SES trainings and assesses the content of this training at the session, and conduct quarterly Army ethics telecons with topics based on surveys of Army ethics counselors.

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

Conducted self-assessments to ensure that required employees are receiving training, Administered post-training evaluations to assess participants' perceptions of the training, Reviewed advice logs for increased activity after training presentations and communications, Held discussions with agency leaders and employees to evaluate whether the training and communications they received have supported them in managing ethics risks., 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:
Some on-line annual ethics training was audio-compliant.

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

Additional Comments

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	Gift acceptance
Selection 2	Financial Disclosure Reporting
Selection 3	Post-employment restrictions

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

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	0	0
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

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 Some Cases (specify why, below)

If not applicable, specify why.
NA

If "never" or "in some cases", please explain further:
Inconsistent coordination with human resources (HR) offices, HR office personnel turnover, and lack of HR procedural mandates affect Confidential Filer notifications of appointments to filing positions. But many Army ethics offices received excellent cooperation regarding Confidential Filer notifications. The Army continues to work on improving this communication with its HR offices.

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 Filers

In 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

Yes, all reports were filed in an election filing system (skip to #32)

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

Check all that apply

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

Select one

Integrity and Other (specify)

Specify Other
FDM

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:
FDM

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 2023	0	0

b. Amount paid to a federal agency in FY 2023

988928

c. Amount for all internal costs associated with operating an e-filing system (e.g., FTE, overhead, etc.) in FY 2023

233000

Please explain "Don’t know/don’t track" answer above

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

a. public financial disclosure filers

(exclude filers in Integrity)

b. confidential financial disclosure filers

45411

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

Additional Comments
Q.28 - The coordination with the Army senior official HR offices is good the only shortfall is notification of personnel detailed into acting SES positions.

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 Entrant	Required	0	0	32	5	43	80
a. New Entrant	Filed	0	0	32	5	43	80
b. Annual	Required	7	8	307	6	456	784
b. Annual	Filed	7	8	307	6	455	783
c. Termination	Required	0	0	66	2	36	104
c. Termination	Filed	0	0	66	2	36	104
d. Combination¹	Required	0	0	4	0	11	15
d. Combination¹	Filed	0	0	4	0	11	15
Total	Required	7	8	409	13	546	983
Total	Filed	7	8	409	13	545	982

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.
One Army general officer did not file an annual report under a combat zone extension. Army general officers detailed or assigned to non-Army DoD agencies file their reports under the Department of Army in Integrity. These officers are placed in Integrity org groups for which Army ethics counselors do not serve as ethics officials or certifiers. These individuals are not included in the Army agency OGE 278e numbers in Q 36 but are as follows: Not listed= 2 career new entrant reports required and filed 7 other new entrant reports required and 6 filed (combat zone exemption) 3 career annual reports required and filed and 100 other annual reports of which 96 are filed 3 other combination reports required and filed and 1 career termination report required and filed and 7 other termination reports required and 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 Entrant	i. How many reports did your agency certify or close in 2023?	0	0	31	5	43	79
	ii. Of those certified or closed in 2023, how many were initially reviewed within 60 days?	0	0	31	5	36	72
	iii. Of those certified or closed in 2023, how many were certified or closed within 60 days?	0	0	28	4	34	66
b. Annual		PAS²	Non-Career SES³	Career SES³	Schedule C	Other⁴	TOTAL
	i. How many reports did your agency certify or close in 2023?	7	8	306	6	455	782
	ii. Of those certified or closed in 2023, how many were initially reviewed within 60 days?	7	8	291	6	414	726
	iii. Of those certified or closed in 2023, how many were certified or closed within 60 days?	6	3	283	5	403	700
c. Termination		PAS²	Non-Career SES³	Career SES³	Schedule C	Other⁴	TOTAL
	i. How many reports did your agency certify or close in 2023?	0	0	65	2	36	103
	ii. Of those certified or closed in 2023, how many were initially reviewed within 60 days?	0	0	65	2	36	103
	iii. Of those certified or closed in 2023, how many were certified or closed within 60 days?	0	0	64	2	33	99
d. Combination		PAS²	Non-Career SES³	Career SES³	Schedule C	Other⁴	TOTAL
	i. How many reports did your agency certify or close in 2023?	0	0	4	0	11	15
	ii. Of those certified or closed in 2023, how many were initially reviewed within 60 days?	0	0	4	0	11	15
	iii. Of those certified or closed in 2023, how many were certified or closed within 60 days?	0	0	4	0	11	15
Total	i. How many reports did your agency certify or close in 2023?	7	8	406	13	545	979
	ii. Of those certified or closed in 2023, how many were initially reviewed within 60 days?	7	8	391	13	497	916
	iii. Of those certified or closed in 2023, how many were certified or closed within 60 days?	6	3	379	11	481	880

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.
Army GOs detailed/assigned to non-Army DoD agencies submit under the Army in Integrity. They are not included in Q 36 but listed as follows: 2 career NE reports IRed and certified within 60 days, 6 other NE reports IRed and certified within 60 days 2 career annual reports IRed and certified within 60 days, 1 of which was IRed within 60 days but certified outside of the 60-day window 96 other annual reports, 48 certified within 60 day 1 career termination report IRed and certified within 60 days 8 other termination reports, 7 IRed and certified within 60 days and one IRed but not certified within 60 days 3 combination reports filed, one IRed and certified within 60 days, 2 IRed within 60 days.

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

Specify Other
NA

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

Periodic Transaction Reports Filed		510
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	106	14	0

b. Number of OGE Form 278-T Reports

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

Enter total

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

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

Enter total

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

Additional Comments

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
	45669	OGE Form 450	45472
		OGE-approved alternate form	0
Total	45669		45472

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
Filing affected by HR office challenges with accurately or timely notifying the servicing ethics office of incoming financial disclosure report filers, combat zone extensions, inaccuracies in FDM filer list maintenance (such as employees assigned reports but departing the agency prior to filing and not being removed from the system).

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	45005	40291	38678

If applicable, please explain why some reports were reviewed more than 60 days after submission.
DoD's requirement of supervisory review, mandated by the Joint Ethics Regulations, necessarily adds to total review time. Also, requests for additional information or clarification, extremely large volume of reports, difficulty of keeping track of individual New Entrant report filers after the annual report season, late supervisory reviews, inconsistent oversight, ethics personnel shortfalls, and combat zone extensions contribute to slow processing.

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
DoD requirement of supervisory review necessarily adds to total review time extremely large volume of reports ethics personnel shortfalls difficulty of keeping track of individual New Entrant reports filed after the annual reporting season.

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

Enter number

275

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

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

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

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

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

Yes

Please Specify Why
Of the four cases referred to DOJ, two OGE Form 202 notifications have been submitted and two are pending submission.

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

Additional Comments

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

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
Number of Full-Time Non-Career Appointees	PAS	PA	Non- career SES	Schedule C	Other	Total
a. Appointed 01/01 - 12/31/2022	1	0	0	4	0	5
i. Signed the Ethics Pledge in 2023	1	0	0	4	0	5
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	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.

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).

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
		Name(s) of Individual(s) Granted Ethics Pledge Waivers
Paragraph 1	0
Paragraph 2	0
Paragraph 3	0
Paragraph 4	0
Paragraph 5	0
Paragraph 6	0
Paragraph 7	0
Paragraph 8	0
Paragraph 9	0
Other (please explain)	0

If other, please explain

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

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).

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

412

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

138

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

138

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

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

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)	125	125	0	0
b. Advisory Committee Members (non-FACA)	29	29	0	0
c. Experts/Consultants	142	129	0	0
d. Board Members	0	0	0	0
e. Commissioners	0	0	0	0
f. Other	80	80	23	23
TOTAL	376	363	23	23

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.
Thirteen experts/consultants were erroneously appointed when they actually performed no duties. All appointment have now been rescinded. The Army DAEO exempted thirteen FACA members from filing requirements given their lack of involvement in assets or issues that would affect the material interests of the non-Federal parties with whom they may be affiliated.

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?	363	23
b. Of those certified or closed in 2023, how many were initially reviewed within 60 days?	363	23
c. Of those certified or closed in 2023, how many were certified or closed within 60 days?	363	23

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

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	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.