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 Agriculture

2. Employees

  • Number of full-time agency employees as of December 31, 2024
100000

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

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

b. Time in current DAEO position
10 or more years

c. Total years performing ethics duties
10 or more years

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

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

f. Number of reporting levels between the DAEO and the agency head.
2

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

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

b. Time in current ADAEO position
10 or more years

c. Total years performing ethics duties
10 or more years

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

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

5. Number of employees, including the DAEO and ADAEO, who performed ethics program duties in 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
0
0
0
0
18
18
b. Outside the D.C. Metro area
0
0
0
0
3
3
TOTAL
0
0
0
0
21
21

* 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
Not applicable (no contractors supported the ethics program)



  • Please describe IT support (optional)
    NA

  • Please describe administrative support (optional)
    NA

  • Please describe substantive support (optional)
    NA

  • Specify Other
    NA

7. Did your agency receive ethics services or support from another federal agency or federal entity? (Do not include contractors, OGE support, or OMB support of MAX.gov.)

  • Select Yes or No
No

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

  • Describe the services or support received:

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

  • Select Yes or No
No

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

  • Describe the services or support provided:

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

  • Select type of resources

    Human Capital, Technology
    Other (specify below)

  • Specify Other
    Budgetary

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.


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

  • Please Describe:
    USDA's ethics officials met with GAO in connection with their review of Executive Branch financial disclosure programs. The results of their review were issued in their report which can be found here: https://www.gao.gov/products/gao-25-107039

12. What kind of changes resulted from the evaluation?


    No changes resulted (specify why not)


  • Please Describe: (Please describe programmatic or policy changes; Specify why no changes resulted; Specify why recommendations still being considered; Specify why not applicable)
    The GAO report noted that USDA has the largest number of ethics financial disclosure reports among large Federal agencies but because the GAO report focused on the content and format of the OGE-278e form itself, GAO did not make any recommendations for change to USDA's Ethics Program.

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
    Question 9: As the sole Ethics Office within the U.S. Department of Agriculture (USDA), the USDA Office of Ethics has a total staff of only 21 employees servicing all of USDA’s 100,000 employees. This means that, proportionally, USDA has only one Ethics Advisor servicing 5,000 USDA employees. The long-standing under-investment in USDA’s Ethics Program was exacerbated in Congress’ FY 2024 enacted budget. The FY 2024 budget imposed a 20% cut to the Office of Ethics’ (OE) already small budget (OE’s budget was $5.556 million in FY 2023 and was cut to $4.5 million for FY 2024). This 20% reduction in funding doesn’t include the effects of separate 4% and 2% government-wide salary pay increases for Federal employees in CYs 2024 and 2025, The effect of the budget cut and salary pay increases means that USDA’s Office of Ethics is currently under an effective budget cut of 26%. Moreover, for the FY’25 budget, although the full year budget is not yet known, the Congressional markups which were released during the summer of 2024 portend serious concerns for the continued sustainability of USDA’s centralized Ethics Program. The House’s markup would reduce OE’s budget by a further 8%, down to $4.136 million, for a 34% total cut. The Senate markup would continue the 26% reduction and keep OE at the $4.5 million mark for FY2025. Both of these budget reductions threaten the continued sustainability of USDA’s Department-wide Ethics Program. Without additional funding in the FY’25 budget the Office of Ethics cannot afford its current staff, even under the Senate’s $4.5 million mark up. Simply put, the significant budget cuts to USDA’s Ethics Program place in peril an already significantly understaffed Ethics Program that services 100,000 USDA employees across the country.

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
9158
    i. How many of those employees received IET within the 3-month requirement?
7798
    ii. How many of those employees received IET beyond the 3-month requirement?
604
    iii. How many of those employee have not received IET as of today?
756

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.
    Despite regular reminders and follow up notices, approximately 6.5% of employees required to complete Initial Ethics Training (IET) did so outside the 3-month window and an additional 8.2% did not complete the training. On the other hand, 85.3% of new entrants did receive Initial Ethics Training within their first three months and 91.8% received the training in their first year. We will continue to follow up with those who did not complete the training

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?

    Written confirmation not required because all IET was provided by an office under the DAEO's supervision

  • 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)
2
2

    b. All other public filers (OGE Form 278e)
626
657

    c. Confidential filers (OGE Form 450 and OGE-approved alternative confidential financial disclosure forms)
10358
10120

    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
10986
10779

  • If applicable, please explain discrepancies between the number of employees who were required to receive training and the number of employees who received training:
    Despite regular reminders and follow up notices, a small percentage (~1.5%) of employees did not complete the training. We will continue to follow up with those who did not complete the training. We would note that 98.1% of employees did receive the required annual ethics training.

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


    No, my agency did not establish additional training requirements

  • Please Describe

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.

  • Please explain other:

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


Conducted self-assessments to ensure that required employees are receiving training, Administered post-training evaluations to assess participants' perceptions of the training, 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

  • 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
Outside employment/activities
  • Selection 3
Conflicting financial interests

  • 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
203

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
No

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

  • Check all that apply
450 (pdf)

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

  • Select one
INTEGRITY and Other (specify)

  • Specify Other
    FDonline

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

  • Check all that apply
Public Financial Disclosure (OGE Form 278e), Periodic Transactions (OGE Form 278-T), Confidential Financial Disclosure (OGE Form 450 or OGE-approved alternative form)

  • Provide the name of the other system:
    FDonline

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
5854
530400

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

c. Amount for all internal costs associated with operating an e-filing system (e.g., FTE, overhead, etc.) in FY 2024Don’t know/don’t track
Don’t know/don’t track

  • Please explain "Don’t know/don’t track" answer above
    All USDA Office of Ethics employees are involved with the use of our e-filing systems to a certain extent but we do not track the percentage of time spent on such responsibilities.

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

    a. public financial disclosure filers (exclude filers in INTEGRITY)
127

    b. confidential financial disclosure filers
11488

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

  • Additional Comments
    PDF OGE 450s were used for two small advisory committees with difficulty accessing our electronic filing system. All other filers submitted their reports using Integrity or FDOnline.


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
48
23
9
81
Filed
0
1
48
23
9
81
b. AnnualRequired
10
38
304
175
99
626
Filed
10
38
304
175
99
626
c. TerminationRequired
1
9
36
24
16
86
Filed
1
9
36
24
16
86
d. Combination1Required
0
1
4
4
0
9
Filed
0
1
4
4
0
9
    Total
Required
11
49
392
226
124
802
Filed
11
49
392
226
124
802

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.

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
0
28
30
10
68
ii. Of those certified or closed in 2024, how many were initially reviewed within 60 days?
0
0
27
28
8
63
iii. Of those certified or closed in 2024, how many were certified or closed within 60 days?
0
0
16
22
3
41
b. Annual
PAS2
Non-Career SES3
Career SES3
Schedule C
Other4
TOTAL
i. How many reports did your agency certify or close in 2024?
10
41
288
180
93
612
ii. Of those certified or closed in 2024, how many were initially reviewed within 60 days?
10
41
269
178
93
591
iii. Of those certified or closed in 2024, how many were certified or closed within 60 days?
9
34
171
152
64
430
c. Termination
PAS2
Non-Career SES3
Career SES3
Schedule C
Other4
TOTAL
i. How many reports did your agency certify or close in 2024?
0
8
20
14
16
58
ii. Of those certified or closed in 2024, how many were initially reviewed within 60 days?
0
8
20
13
16
57
iii. Of those certified or closed in 2024, how many were certified or closed within 60 days?
0
7
16
12
16
51
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
1
4
4
0
9
ii. Of those certified or closed in 2024, how many were initially reviewed within 60 days?
0
1
4
3
0
8
iii. Of those certified or closed in 2024, how many were certified or closed within 60 days?
0
1
3
3
0
7
    Total
i. How many reports did your agency certify or close in 2024?
10
50
340
228
119
747
ii. Of those certified or closed in 2024, how many were initially reviewed within 60 days?
10
50
320
222
117
719
iii. Of those certified or closed in 2024, how many were certified or closed within 60 days?
9
42
206
189
83
529

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.
    As noted below, USDA's Office of Ethics is, proportionally, one of least resourced and smallest Ethics Office of any Cabinet-level Department. At current staffing levels, each OGE 278 financial disclosure reviewer in the Office of Ethics is responsible for reviewing an average of nearly 100 OGE-278e reports each year (not counting an even larger number of separate OGE-450 reviews), in addition to providing ethics advice and training to their clients (OE advisors perform all three functions.) This large report volume combined with a large client population (5,000 employees per one ethics advisor) and a significantly under-resourced Ethics Program makes 100% timely review of reports very challenging. With a ratio of only 1 Ethics Officer for every 5,000 USDA employees, USDA's Office of Ethics has suffered from years of under-investment and is one of the least resourced Ethics Offices of any Executive Branch Department.

  • 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

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

    • Periodic Transaction Reports Filed
460
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
150
4
0
    b. Number of OGE Form 278-T Reports
13
2
0

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
12

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

  • Enter total
101

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
12131
OGE Form 450
12091
OGE-approved alternate form
0
Total
12131
12091

    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
    These numbers reflect a successful filing rate of 99.7%. However, some employees failed to file due to transfers to other agencies, leaving government, or long term leave. A small number of employees simply failed to submit their reports despite being on duty and receiving more than 20 past due filing notices from the USDA Office of Ethics.

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
11677
10776
10421

  • If applicable, please explain why some reports were reviewed more than 60 days after submission:
    At current staffing levels, after a 20% budget cut in FY2024, each financial disclosure reviewer in the Office of Ethics is responsible for reviewing an average of nearly nine hundred (900) OGE-450 reports each year, in addition to providing ethics advice and training to their clients (OE advisors perform all three functions.) This very large report volume combined with a very large client population (5,000 employees per advisor) makes 100% timely review of reports very challenging. With a ratio of only 1 Ethics Officer for every 5,000 USDA employees, USDA's Office of Ethics is one of the least resourced Ethics Offices of any Executive Branch Department. Despite those challenges 96.7% of 450 reports submitted in 2024 were certified, and 92.3 of those were reviewed within 60 days.

  • 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
185

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
1

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

    i. Subpart A (General Provisions)
0

    ii. Subpart B (Gifts from Outside Sources)
0

    iii. Subpart C (Gifts between Employees)
0

    iv. Subpart D (Conflicting Financial Interests)
0

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

    vi. Subpart F (Seeking Other Employment)
0

    vii. Subpart G (Misuse of Position)
0

    viii. Subpart H (Outside Activities)
1

    ix. Subpart J (Legal Expense Funds)
0

    x. Agency's supplemental Standards of Conduct
0

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
1

    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)
0

    ii. 18 U.S.C. § 205 (Claims Against and Matters Affecting the Government)
0

    iii. 18 U.S.C. § 208 (Acts Affecting a Personal Financial Interest)
0

    iv. 18 U.S.C. § 209 (Supplementation of Salary)
0

    v. 5 U.S.C. § 13106 or 18 U.S.C. § 1001 (Failure to File or Filing False Public Financial Disclosures)
0

    vi. 5 U.S.C. § 13143 (Outside Earned Income)
0

    vii. 5 U.S.C. § 13144 (Outside Activities)
1

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
8

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

    i. How many of those referrals were accepted for prosecution?
1

    ii. How many of those referrals were declined for prosecution?
4

    iii. How many of those referrals were pending DOJ’s decision as of December 31, 2024?
3

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?
1

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

    iii. Of the cases referred to DOJ, how many are pending a determination as to whether disciplinary or corrective action will be taken?
4

    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?
3

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

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

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
Yes

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
23
2
0
25
    i. Signed the Ethics Pledge in 2024
0
0
23
2
0
25
    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?
0

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

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
356

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
356

    i. How many of those SGEs received IET before or at the beginning of the first meeting?
356

    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)
47
34
0
0
b. Advisory Committee Members (non-FACA)
226
216
0
0
c. Experts/Consultants
82
82
0
0
d. Board Members
0
0
0
0
e. Commissioners
0
0
0
0
f. Other
0
0
0
0
TOTAL
355
332
0
0

    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.
    Despite repeated filing notices and follow ups from Office of Ethics leadership, some SGEs failed to complete their OGE 450 reports as required.

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?
317
0
b. Of those certified or closed in 2024, how many were initially reviewed within 60 days?
296
0
c. Of those certified or closed in 2024, how many were certified or closed within 60 days?
290
0

  • If applicable, please explain why some reports were reviewed more than 60 days after submission.
    At current staffing levels, each financial disclosure reviewer in the Office of Ethics is responsible for reviewing an average of nearly nine hundred (900) OGE-450 reports each year, in addition to providing ethics advice and training to their clients (OE advisors perform all three functions.) This very large report volume combined with a very large client population (5,000 employees per advisor) makes 100% timely review of reports very challenging. With a ratio of only 1 Ethics Officer for every 5,000 USDA employees, USDA's Office of Ethics is one of the least resourced Ethics Offices of any Executive Branch Department. Handling ethics programmatic duties for SGEs who serve on a part-time basis is extremely labor-intensive and, to be done correctly, requires resources that USDA OE does not possess.

  • 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

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

  • Enter number
0

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

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

      b. Number of OGE Form 450 or OGE-Approved Alternative Forms
1

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

  • Additional Comments

ADDITIONAL QUESTIONNAIRE COMMENTS:

  • Additional Comments
    As the sole Ethics Office within USDA, the Office of Ethics has a total staff of only 21 employees servicing all of USDA’s 100,000 employees. This means that, proportionally, USDA has only 1 Ethics Advisor servicing 5,000 USDA employees. This long-standing under-investment in USDA’s Ethics Program was exacerbated in Congress’ FY 2024 enacted budget. The FY 2024 budget imposed a 20% cut to the Office of Ethics’ (OE) already small budget (OE’s budget was $5.556 million in FY 2023 and was cut to $4.5 million for FY 2024). This 20% reduction in funding doesn’t include the cumulative effects of separate 4% and 2% government-wide salary pay increases for Federal employees in CYs 2024 and 2025, The combined effect of the steep budget cut and salary pay increases means that USDA’s Office of Ethics is currently under an effective budget cut of 26%. Moreover, for the FY’25 budget, although the full year budget is not yet known, the Congressional markups which were released during the summer of 2024 portend serious concerns for the continued sustainability of USDA’s centralized Ethics Program. The House’s markup would reduce OE’s budget by a further 8%, down to $4.136 million, for a 34% total cut. The Senate markup would continue the 26% reduction and keep OE at the $4.5 million mark for FY2025. Both of these budget reductions threaten the continued sustainability of USDA’s Department-wide Ethics Program. Without additional funding in the FY’25 budget the Office of Ethics cannot afford its current staff, even under the Senate’s $4.5 million mark up. Simply put, the significant budget cuts to USDA’s Ethics Program place in peril an already significantly understaffed Ethics Program that services 100,000 USDA employees across the country.