2024 AGENCY ETHICS PROGRAM QUESTIONNAIRE

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PART 1. INTRODUCTION

Executive branch agencies are required to submit an annual report to the United States Office of Government Ethics (OGE) concerning certain aspects of their ethics programs (Section 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 3, 2025. (5 C.F.R. § 2638.207(a)).

PART 2. INSTRUCTIONS

Your response to this questionnaire should reflect the 2024 calendar year (i.e., 1/1/2024 through 12/31/2024), 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 2023 report. To safeguard privacy, in your responses, please avoid the use of Personally Identifiable Information (PII). After OGE has reviewed your questionnaire submission, you may be contacted for follow-up.

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If you have any further questions, please contact Nicole Stein at nstein@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, 2024
658564

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

a. Vacant (as of December 31, 2024)?
No

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.
1

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

a. Vacant (as of December 31, 2024)?
No

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 2024 (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
38
7
4
9
82
b. Outside the D.C. Metro area
360
586
113
42
21
1122
TOTAL
384
624
120
46
30
1204

* FTE = Full Time Equivalent

Example: The table below provides an example of an agency with 13 employees that performed ethics
program duties in 2024.

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.)

  • Please describe IT support (optional)
    The Army uses contractors to support the operation of its Financial Disclosure Management System for OGE submission by Army filers.

  • Please describe administrative support (optional)
    Only National Guard Bureau and US Army Intelligence and Security Command report using contractors for administrative support. These contractors monitor the organization's ethics inbox, track incoming requests for ethics support, and track filing and training requirements.

  • 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
Yes

  • Please provide the name(s) of the federal agency or entity:
    The Army has an agreement with GSA for the provision of log-in services to the Financial Disclosure Management System via login.gov.

  • Describe the services or support received:
    Log-in services to the Financial Disclosure Management System vial login.gov.

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 System is used on a reimbursable basis by the DoD and subordinate organizations, the Office of Government Ethics, Department Veterans Affairs, the Peace Corps, Department of Homeland Security, Department of State, the Armed Forces Retirement Home, and the Office of Personnel Management.

  • 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 when users encounter log-in 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 2024?

  • 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 2024 (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, we began the process of working with the office of the Assistant Secretary of the Army (Financial Management and Comptroller) in their Risk Management and Internal Control (RMIC), Entity Level Control (ELC) review, which is continuing into 2025. This review is assessing several aspects of our ethics program with particular attention to financial disclosures.

12. What kind of changes resulted from the evaluation?

    Programmatic 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)
    We developed a system of notification from the Army Civilian Human Resources Agency (CHRA) directly to Army OGC of all new entrant filers across the Army Enterprise. We now receive these new filer lists in a searchable and sortable excel worksheet every pay period. We then distribute to the appropriate DDAEOs who in turn, distribute to local installations' and organizations' ethics officials. We expect this to significantly improve our new entrant financial disclosure filer tracking.

13. Of the following required written procedures, which did you have in place?
Check all that apply.

Financial disclosure program, including for the filing, review, and when applicable, public availability of public financial disclosure reports (5 C.F.R. § 2638.104(c)(8)(i)), Issuance of notice of ethical obligations in written offers of employment (5 C.F.R. § 2638.303), Provision of initial ethics training (5 C.F.R. § 2638.304), Issuance of ethics notice to new supervisors (5 C.F.R. § 2638.306)

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

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

  • Additional Comments

PART 5. EDUCATION AND TRAINING

14. Did the office(s) responsible for issuing ethics notices to prospective employees, pursuant to 5 C.F.R. § 2638.303, provide the DAEO with the written confirmation required pursuant to 5 C.F.R. § 2638.310?

    All of the offices provided the written confirmation to the DAEO (skip to #16)

  • Please Explain why not all offices:
    NA

15. Did written offers of employment for positions covered by the Standards of Conduct include the information required by 5 C.F.R. § 2638.303?

  • Please Explain why not all offers:
    NA

  • Please Explain:
    NA

16. Initial Ethics Briefing

a. How many agency leaders, as defined in 5 C.F.R. 2638.305(a), were required to receive ethics briefings by December 31, 2024? Exclude SGEs that were expected to serve less than 60 days on a board, commission, or committee.
Total Number
0
    i. How many new agency leaders received their briefing within 15 days of their appointment?
    ii. How many of those leaders received their briefing beyond the 15-day requirement?
    iii. How many new agency leaders have yet to receive their briefing as of today?

    If applicable, please explain why some of the leaders received their briefing beyond the 15-day requirement or have yet to receive their briefing.

17. Initial Ethics Training

a. How many employees, as defined in 5 C.F.R. 2638.304(a), were required to receive Initial Ethics Training (IET) by December 31, 2024 (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
103239
    i. How many of those employees received IET within the 3-month requirement?
103013
    ii. How many of those employees received IET beyond the 3-month requirement?
156
    iii. How many of those employee have not received IET as of today?
70

Example: If an employee started at the agency on December 15, 2024, 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, 2025, the employee has not completed IET, do not count that employee in your required numbers. Instead, include the employee in your 2025 questionnaire response to be filed in 2026.

  • 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, HR and ethics personnel turn-over, and ethics counselor unfamiliarity with IET provisions also played a part. However, we have placed new emphasis on this requirement at our annual Ethics Officials Course this year. The Army is in process of providing IET to these personnel.

18. Did the office(s) delegated the responsibility for providing initial ethics training (IET) provide the required written confirmation to the DAEO, pursuant to 5 C.F.R. § 2638.310?

    All of the offices provided the written confirmation to the DAEO

  • Please Explain why not all offices:

19. Did the head of the agency complete either initial ethics training and/or annual ethics training in 2024?

  • Select One
Yes

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

20. Required Annual Ethics Training

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

    a. Executive Schedule Level I or Level II public filers (OGE Form 278e)
1
1

    b. All other public filers (OGE Form 278e)
1106
1106

    c. Confidential filers (OGE Form 450 and OGE-approved alternative confidential financial disclosure forms)
41989
41706

    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
43096
42813

  • 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. Additionally, the communication from Human Resources personnel and Ethics Officials concerning new hires that are financial disclosure filers needs improvement. As stated in question 12, we have developed a system of notification from the Army Civilian Human Resources Agency (CHRA) directly to Army OGC of all new entrant filers across the Army Enterprise. We now receive these new filer lists in a searchable and sortable excel worksheet every pay period. We then distribute to the appropriate DDAEOs who in turn, distribute to local installations' and organizations' ethics officials. We expect this to significantly improve our new entrant financial disclosure filer tracking.

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

    My agency established additional training requirements for employees performing ethics duties described in 5 C.F.R. § 2638.104-105 (ethics and human resources officials). Please describe., 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 Official continuing education program, requiring a minimum of one hour of additional ethics training for all ethics officials. Generally this year, that continuing education focused on recent changes to the Joint Ethics Regulations and 5 CFR Parts 2635 and 2601. Also, inspectors general, financial, and acquisition professional preformed annual ethics training.

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


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, conduct quarterly Army ethics telecons with topics based on surveys of Army ethics counselors, and fulfill the DAEO-mandated annual continued education program.

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


Conducted self-assessments to ensure that required employees are receiving training, Administered post-training evaluations to assess participants' perceptions of the training, Reviewed advice logs for increased activity after training presentations and communications, Held discussions with agency leaders and employees to evaluate whether the training and communications they received have supported them in managing ethics risks., Ensured ethics education was accessible (508 compliant) to participants

  • Please explain other:

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

  • Additional Comments

PART 6. ADVICE, COUNSELING, AND REMEDIES

24. From the list below, select the three topics that your employees most frequently sought guidance on in 2024. Please rate them in order, so that the first topic is the topic on which the employees sought guidance the most frequently.

  • Conflicting financial interests
  • Gift acceptance
  • Financial disclosure reporting
  • Impartiality in performance of official duties
  • Misuse of position, government resources, and information
  • Outside employment/activities
  • Post-employment restrictions
  • Travel, subsistence, and related expenses from non-federal sources
  • Other (specify)

  • Selection 1
Financial Disclosure Reporting
  • Selection 2
Gift acceptance
  • Selection 3
Post-employment restrictions

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

25. Number of notification statements of negotiation or recusal under section 17(a) of the STOCK Act submitted to the ethics office in 2024 (see 5 C.F.R. § 2635.602(a)):

  • Enter total
28

26. Number of 18 U.S.C. § 208 waivers granted in 2024:

Number Granted in 2024
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.

27. Number of Legal Expense Fund documents filed in 2024 (see 5 C.F.R. § 2635.1007):

Number Filed in 2024
Number Sent to OGE
    a. Trust Documents
0
0
    b. Quarterly Reports
0
0
    c. Termination Report
0
0

  • If applicable, please explain discrepancies between the number of documents filed 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 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 2024, 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
    Financial Disclosure Management 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:
    Financial Disclosure Management System

34. Indicate your agency's fiscal year 2024 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 2024
0
0

b. Amount paid to a federal agency in FY 2024
0
1131521

c. Amount for all internal costs associated with operating an e-filing system (e.g., FTE, overhead, etc.) in FY 2024
0
234994

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

35. Indicate the number of filers who filed electronically in fiscal year 2024.

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

    b. confidential financial disclosure filers
44616

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

  • Additional Comments


PART 8. PUBLIC FINANCIAL DISCLOSURE

36. Report the number of public financial disclosure reports (OGE Form 278e) required to be filed by December 31, 2024, excluding SGEs, and the number of reports actually filed (i.e., received) by December 31, 2024.

OGE Form 278e Reports
PAS2
Non-Career SES3
Career SES3
Schedule C
Other4
TOTAL
a. New EntrantRequired
0
1
35
3
119
158
Filed
0
1
35
3
118
157
b. AnnualRequired
8
7
281
8
534
838
Filed
8
7
281
8
534
838
c. TerminationRequired
2
1
24
1
107
135
Filed
2
1
24
1
107
135
d. Combination1Required
0
0
7
0
22
29
Filed
0
0
7
0
22
29
    Total
Required
10
9
347
12
782
1160
Filed
10
9
347
12
781
1159

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, 2024, 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, 2025, 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 2025 questionnaire response to be filed in 2026.

  • If applicable, please explain discrepancies between the number of reports required to be filed and the actual number of reports filed.
    One GO filed late in January 2025, she is requesting a waiver of the late filing fee.

37. Report 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 2024?
0
1
28
3
123
155
ii. Of those certified or closed in 2024, how many were initially reviewed within 60 days?
0
1
28
3
117
149
iii. Of those certified or closed in 2024, how many were certified or closed within 60 days?
0
0
26
3
105
134
b. Annual
PAS2
Non-Career SES3
Career SES3
Schedule C
Other4
TOTAL
i. How many reports did your agency certify or close in 2024?
8
7
281
8
529
833
ii. Of those certified or closed in 2024, how many were initially reviewed within 60 days?
8
7
267
8
510
800
iii. Of those certified or closed in 2024, how many were certified or closed within 60 days?
8
7
244
7
456
722
c. Termination
PAS2
Non-Career SES3
Career SES3
Schedule C
Other4
TOTAL
i. How many reports did your agency certify or close in 2024?
1
1
23
1
100
126
ii. Of those certified or closed in 2024, how many were initially reviewed within 60 days?
1
1
23
1
100
126
iii. Of those certified or closed in 2024, how many were certified or closed within 60 days?
1
1
23
1
96
122
d. Combination
PAS2
Non-Career SES3
Career SES3
Schedule C
Other4
TOTAL
i. How many reports did your agency certify or close in 2024?
0
0
7
0
22
29
ii. Of those certified or closed in 2024, how many were initially reviewed within 60 days?
0
0
7
0
20
27
iii. Of those certified or closed in 2024, how many were certified or closed within 60 days?
0
0
6
0
20
26
    Total
i. How many reports did your agency certify or close in 2024?
9
9
339
12
774
1143
ii. Of those certified or closed in 2024, how many were initially reviewed within 60 days?
9
9
325
12
747
1102
iii. Of those certified or closed in 2024, how many were certified or closed within 60 days?
9
8
299
11
677
1004

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.
    More information needed, late review by supervisors, amendments to reports required, change in supervisors and ethics officials. The DoD supervisory review requirement, mandated by the Joint Ethics Regulation, necessarily adds to the total review time. Integrity prevents ethics official review until supervisory review is done, which inhibits early ethics counselor action to get supervisors acting on these reports.

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

  • Specify Other
    NA

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

    • Periodic Transaction Reports Filed
634
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. Extensions 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
165
9
0
    b. Number of OGE Form 278-T Reports
56
28
2

40. Number of public financial disclosure filers reported in calendar year 2024 to the Attorney General for failure to file.

  • Enter total
0

41. How many requests for public financial disclosure reports did you receive in 2024? Count each OGE Form 201 as one request, even if it contains a request for documents for multiple individuals.

  • Enter total
0

42. How many documents requested under the Ethics in Government Act did you release in calendar year 2024?

  • Enter total
0

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, 2024, excluding SGEs, and the number of reports actually filed by December 31, 2024.

a. Required
b. Filed
45056
OGE Form 450
44805
OGE-approved alternate form
0
Total
45056
44805

    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, 2024, 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, 2025 the employee has not filed a new entrant report, do not count that report in your required numbers. Instead, include the report in your 2025 questionnaire response to be filed in 2026.

    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). As stated in question 12, we have developed a system of notification from the Army Civilian Human Resources Agency (CHRA) directly to Army OGC of all new entrant filers across the Army Enterprise. We now receive these new filer lists in a searchable and sortable excel worksheet every pay period. We then distribute to the appropriate DDAEOs who in turn, distribute to local installations' and organizations' ethics officials. We expect this to significantly improve our new entrant financial disclosure filer tracking.

44. Report 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 2024?
b. Of those certified or closed in 2024, how many were initially reviewed within 60 days?
c. Of those certified or closed in 2024, how many were certified or closed within 60 days?
OGE Form 450 and OGE-approved alternative
43976
40104
39825

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

  • Specify Other
    NA

45. Number of OGE 450 or OGE-approved alternative forms granted filing extensions in 2024.

  • 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 2024 based wholly or in part upon violations of the Standards of Conduct provisions (5 C.F.R. part 2635) or your agency's supplemental Standards (if applicable). For purposes of this question, disciplinary actions include removals, demotions, suspensions, and written reprimands or their equivalents.

a. Total number of disciplinary actions that met the above criteria
0

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

    i. Subpart A (General Provisions)

    ii. Subpart B (Gifts from Outside Sources)

    iii. Subpart C (Gifts between Employees)

    iv. Subpart D (Conflicting Financial Interests)

    v. Subpart E (Impartiality in Performing Official Duties)

    vi. Subpart F (Seeking Other Employment)

    vii. Subpart G (Misuse of Position)

    viii. Subpart H (Outside Activities)

    ix. Subpart J (Legal Expense Funds)

    x. Agency's supplemental Standards of Conduct

47. Number of disciplinary actions taken in 2024 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 2024 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, 2024?

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

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, 2024? Note: For guidance on what constitutes a full-time non-career appointee for purposes of the Ethics Pledge, LA-21-07

  • Select answer
No (skip to #53)

51. For each category of appointee, provide the number of full-time non-career appointees appointed between January 1 and December 31, 2024, 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 - 12/31/2024
0
0
0
0
0
0
    i. Signed the Ethics Pledge in 2024
0
0
0
0
0
0
    ii. Required to sign the Pledge in 2024 but signed in 2025
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.

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, 2024, 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 2024, the names of these individuals granted waivers in 2024, and which of the Pledge paragraphs were implicated.

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

  • If other, please explain

54. Number of violations, if any, of Executive Order 13989 in 2024.
0

55. Number of enforcement actions, if any, taken in 2024 as a result of violations of the Executive Order 13989 (regardless of whether the violation itself took place in 2024 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 2024? (If zero, skip to Additional Comments for this Part.)

  • Enter number
421

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, 2024 (5 C.F.R. § 2638.304(b)(2))?

Total number
146

    i. How many of those SGEs received IET before or at the beginning of the first meeting?
146

    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, 2024 and the number of reports actually filed by December 31, 2024.

Confidential Reports
(OGE Form 450 or OGE- Approved Alternative Form)
Public Reports
(OGE Form 278e)
required
filed
required
filed
a. Advisory Committee Members (FACA)
101
101
0
0
b. Advisory Committee Members (non-FACA)
45
45
0
0
c. Experts/Consultants
128
128
0
0
d. Board Members
0
0
0
0
e. Commissioners
0
0
0
0
f. Other
112
112
38
38
TOTAL
386
386
38
38

    Example for new entrant and termination reports: If an employee joined (or departed) the agency on December 15, 2024, 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 2025 questionnaire response to be filed in 2026.

  • 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 2024?
386
46
b. Of those certified or closed in 2024, how many were initially reviewed within 60 days?
386
46
c. Of those certified or closed in 2024, how many were certified or closed within 60 days?
386
46

  • 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
7

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
3
0
0

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

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

  • Additional Comments

ADDITIONAL QUESTIONNAIRE COMMENTS:

  • Additional Comments