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 Air Force

2. Employees

  • Number of full-time agency employees as of December 31, 2024
481478

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
5 - 9 years

c. Total years performing ethics duties
10 or more years

d. Percent of time spent on ethics
0-25%

e. Is the 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
8
10
7
6
12
43
b. Outside the D.C. Metro area
531
498
123
51
36
1239
TOTAL
539
508
130
57
48
1282

* 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.)
Substantive ethics support (e.g., providing training, initial review of financial disclosures, drafting advice for further review, etc.)

  • Please describe IT support (optional)

  • Please describe administrative support (optional)

  • Please describe substantive support (optional)

  • 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:
    Joint Personnel Recovery Agency, DoD Standards of Conduct Office

  • Describe the services or support received:
    Advisory support

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:
    1-Defense Health Agency, 2-Joint Personnel Recovery Agency, 3-DoD Joint Strike Fighter Program (program run by Dept of the Navy), Dept of the Army and Dept of the Navy personnel assigned to one Air Force base

  • Describe the services or support provided:
    1-Defense Health Agency – ethics advice provided to Medical Group commanders with G-Series orders on installations of major command.
    2-Joint Personnel Recovery Agency – ethics reviews
    3-DoD Joint Strike Fighter Program (program run by Dept of the Navy), Dept of the Army and Dept of the Navy personnel assigned to one Air Force base – all ethics matters including financial disclosure and post-government employment advice.

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
    online training resources

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 DoD IG conducted an audit of the public financial disclosure programs of the Department of the Air and the other military services.

12. What kind of changes resulted from the evaluation?

    Programmatic changes (please describe), Policy changes (please describe)



  • Please Describe: (Please describe programmatic or policy changes; Specify why no changes resulted; Specify why recommendations still being considered; Specify why not applicable)
    The following responses were provided by multiple installations.
    Programmatic changes: 1-One installation legal office implemented a Plan of Action and Milestones (POAM) to identify and manage all ethics deadlines based on the inspection of the ethics program by the Air Force Judge Advocate General’s Office. This allowed it to better track all ethics requirements and ensure steps were accomplished prior to deadlines. That office also set up additional procedures with Civilian Personnel Office (CPO) and Newcomer Training Moderator to identify OGE 450 filers & new civilians, which was lacking in previous years. Another installation legal office revamped its initial ethics training program to make it interactive IAW 5 CFR 2638.304. That installation is no longer giving a live presentation to new employees. Instead, it created a new ethics training presentation in PowerPoint, with the necessary vignettes, and emailed it to the local CPO for dissemination and training tracking. They also provided training materials including the contact information for the legal office for questions. 2-One installation implemented the new training requirement for ethics officials that is set forth in the revised Joint Ethics Regulation (May 2024).
    Policy changes: 1-One installation in a major command underwent an inspection by the agency. A policy memo was updated to appropriately reflect requirement of a separate delegation for post-government employment advice. 2-One installation had a staff assistance visit from the Air Force Judge Advocate General's Office. A review of its ethics program led to minor policy changes and improvements for several programs. One example is that the installation received clarification and guidance regarding gifts to the agency and dealing with non-Federal entities.
    No changes: 1-Several installations in three major commands underwent inspections by the Air Force Judge Advocate General’s Office, and their ethics programs were found to be compliant. No changes resulted. 2-The DoD IG was satisfied with the timeliness of the submission, review, and certification of the OGE Form 278s in the Department of the Air Force.
    Evaluation not complete: The DoD IG is continuing to work on the portion of their audit involving conflict of interest analysis of the 278s.

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
    Q6. Most Air Force ethics offices did not have contractor support, but a few did.
    Q9. A few of one major command’s subordinate installations reported a need for additional personnel within their offices. Several offices experienced personnel shortages due to retirements, resignations, and permanent change of station moves. Several offices reported a need for better technology so that an OGE Form 450 filer’s completed initial or annual ethics training in SharePoint could be recorded directly in FDM.
    Q11. The inspection team from the Air Force Judge Advocate General’s Office (AF/JAI) inspected some bases as part of the team’s routine inspections in CY 2024. The recommendations listed in response to Question 12 are for those legal offices that underwent inspections.
    Q12. AF/JAI inspections identified issues with some ethics appointment letters at one base. The problems were corrected. Additionally, changes were implemented to address training and program accounting within a base Civilian Personnel Office and the Financial Disclosure Management (FDM) program.

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
1
    i. How many new agency leaders received their briefing within 15 days of their appointment?
1
    ii. How many of those leaders received their briefing beyond the 15-day requirement?
0
    iii. How many new agency leaders have yet to receive their briefing as of today?
0

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

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
21356
    i. How many of those employees received IET within the 3-month requirement?
20627
    ii. How many of those employees received IET beyond the 3-month requirement?
96
    iii. How many of those employee have not received IET as of today?
633

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.
    1-One major command explained that shortages in both the personnel (CPO) and legal offices created communication breakdowns in ensuring accurate data was provided to the legal offices about the number of personnel who required training and the number who actually received training. Legal offices in this major command continue to work with their servicing CPOs to improve processes. 2-One major command had two installations with persons who did not receive IET within three months. One installation reported that in late January 2024 it implemented a new method for providing IET and during the process, missed 10 employees. They were able to identify and train 3 of the 10 employees later in the year when the employees were identified as OGE 450 filers. They are working to train the remaining 7 employees. The second installation in this command reported that it sent reminders to complete IET to all new employees. 2 employees completed their training beyond the 3-month requirement. 1 employee thought the Defense Acquisition University ethics training met the requirement. The other employee is a Security Forces patrol officer who worked nights. 3-A base in one major command had four filers who failed to provide completion certificates. One filer at another base experienced technical issues. One filer at a third base was deployed, and it was not discovered that he had not received training until a year-end review of the installation’s training records. 4-Some field offices in one command did not have a mechanism in place for notification when new employees were onboarded. They have discussed the issue with their human resources office. The local HROs will add their Ethics Offices to the new employee supervisor’s checklist so that they will be notified and be able to offer the training to all new hires going forward. Each local Ethics Office will receive a roster of new hires and make a training plan to provide ethics training for new hires in CY 2025. 5-Three subordinate offices in one command had filers who did not receive IET within 3 months. In one numbered air force, the Civilian Personnel Office (CPO) notifies new employees of their obligation to complete the training, and JA offers it every month, but CPO does not enforce attendance or follow up with delinquent employees. In one wing, due to leave and temporary limited manning (caused by deployment & parental leave) of JA personnel, employees who in-processed in September 2024 (total of 8 new hires and transfers) did not receive their IET during their in-processing. This issue was identified, and the employees received their IET beyond the 3-month requirement. In another wing, an uncontrolled fire and subsequent asbestos release in May 2024 at the headquarters building displaced all employees for 2-6 months. The Chief of Staff’s office in the headquarters building is responsible for scheduling and hosting the newcomer orientations at which IET is given. Due to the fire, orientations did not resume until 6 months after the fire. This resulted in 28 personnel not receiving IET. 6-The legal office for a direct reporting unit lost its incumbent admin assistant in late 2023. An effective replacement was not hired until mid-2024. This person helped track and schedule new employee ethics orientation beginning in mid-2024. The churn in personnel led to some regular new employee training sessions falling off the calendar. The unit is back on track for 2025. 7-One unit has one employee who has failed to respond to emails about training. The ethics official has notified the supervisor. 8-One major command missed employees of the numbered air force. The command has coordinated with its numbered air force, who will help provide early identification of the employees who require IET.

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)
786
783

    c. Confidential filers (OGE Form 450 and OGE-approved alternative confidential financial disclosure forms)
28414
27361

    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
29201
28145

  • If applicable, please explain discrepancies between the number of employees who were required to receive training and the number of employees who received training:
    1-One MAJCOM provided the following reasons explaining why some of their filers did not complete annual training: a) filers are on extended medical, maternity or paternity leave and expected to complete the training when they return. b) filers ignored numerous reminders to complete the training and have been referred to their supervisors for administrative action as appropriate. c) filers departed their organizations without completing the training and were no longer Confidential Financial Disclosure Report filers.
    2-One command believes that some filers left the command before receiving training, but the training assignment was not removed, so the filers appeared delinquent on the spreadsheet.
    Continued in Additional Comments

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.
Other (please specify)

  • Please explain other:
    One MAJCOM used Public Affairs platform to increase awareness of key seasonal topics like gifts, fundraising, and political activities. Discussed common issues with Commander and CPO and sent reminders of ethics requirements during relevant times.

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
Other (please specify)

  • Please explain other:
    One MAJCOM used SAF/GC ethics training and found the SAF/GC training to be effective.

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

  • Additional Comments
    Q20. (continued) 3-One MAJCOM had 25 confidential filers out of a total of 539 who did not receive AET. Most of these filers were assigned to a base that used FDM to track AET. FDM includes all confidential filers listed with the organization at any point in time during the year as requiring training, even if they leave before the annual training is due and without completing the training. The office does not typically push annual training until October-November due to the majority of personnel changes occurring over the summer months. Filers who have left the installation are included in the overall numbers for those who require training by that organization. Other filers missed training due to deployments or family leave which had the member off-station and not performing covered duties for an extended period of time that included the reporting period.
    4-One ethics office in a MAJCOM is responsible for providing annual training for a large number of tenant unit OGE Form 450 filers on the base. The office sent instructions and multiple reminders to all base filers regarding AET. Another base reported that it sent multiple reminders to the confidential filers who had not yet completed AET. The legal office then notified supervisors. Of the 11 confidential filers who have not received training, one is on maternity leave, two are no longer employed by the AF, and the others/their supervisors have not responded to the legal office’s requests.
    5-Confidential filers left the agency prior to the time that AET was scheduled. The duties of other confidential filers changed after filing and they were no longer required to receive AET.
    6-One MAJCOM had 2 confidential filers out of a total of 624 filers who did not receive AET in CY 2024. The ethics office for the wing was working to provide training in the first week of CY 2025.
    7-One ethics office reported that one filer was gone on temporary duty for an extended period of time ethics office was not able to provide training to this individual.
    8-Six confidential filers (out of total of 55) in one command did not respond to repeated requests to complete training.
    9-One ethics office stated that 10 of its 111 filers did not receive AET because they were transferred to another installation or they did not respond to repeated communications about the training.
    10-One major command noted that the discrepancy between the number of confidential filers required to be trained and the number of confidential filers actually trained was due to delayed identification of filers and inconsistent annual training records. The command will increase coordination with the Civilian Personnel Office to mitigate a recurrence.
    11-One major command noted one confidential filer out of its 363 filers did not get AET on time after several contacts by the ethics official. The individual’s commander has been notified of the situation and will ensure the person receives training.
    Q17. One major command explained that two of the individuals who did not receive IET within three months rescheduled multiple times. The base CPO is working to train the individuals or hold them accountable pending a review of their position description statements. Four of the individuals worked remotely and missed in-person initial ethics briefings. These individuals were discovered during an internal audit of training sign-in sheets and immediately trained remotely after the 3-month requirement. Three new hires were identified too late to complete training within CY 2024.
    Q20. One major command explained that some employees resigned their positions or moved prior to completing training and were not updated in FDM as leaving the organization. In most cases, subordinate bases keep paper or excel sign-in sheets to record actual trainings, but the bases have been inconsistent in updating those individuals in FDM. In two specific instances, one filer continues to have ongoing login issues while the other has been undergoing long-term hospitalization. Another employee began maternity leave prior to receiving her training and has received an exception. The major command is requiring its base legal offices to record the ethics training in FDM. Additionally, the major command will implement periodic progress reports of FDM for subordinate units. The current list of filers is being reviewed, and filers no longer a part of the organization will be removed.
    Q20. The employees that the Department listed in section d last year are not included in the numbers reported in section c this year. Last year the ethics official for the major command misunderstood the question and reported 76 employees who were required by the head of certain command directorates, not the head of the agency, to receive annual ethics training. These individuals are neither public nor confidential financial disclosure filers.

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

  • 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
25

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
    Q24. The topic of gift acceptance received the highest number of first place responses from the field ethics offices, but it also received the highest number of third place responses. I was not sure if I should rate gift acceptance as both 1 and 3. After removing gift acceptance from consideration for third place, the topic of financial disclosure reporting was in third place.

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 Some Cases (specify why, below)

    • If not applicable, specify why.
      NA

    • If "never" or "in some cases", please explain further:
      Several ethics offices stated that their civilian personnel office notified them of the appointments in all or most cases. Several other ethics offices stated that their CPO never notified them or that this question was not applicable to them. Selecting “in some cases” was the best compromise answer. The following are explanations from different Air Force ethics offices. 1) One major command stated that although the personnel offices notify ethics officials of appointments, ethics officials are also notified of appointments of public filers by SAF/GCA and of confidential filers by supervisors. 2) One major command has a small number of filing positions, and the individuals are prominent. The ethics office tracks the appointments. 3) On several installations in one major command, supervisors, unit POCs for financial disclosure, and the employees themselves notify the ethics office of appointment to filing positions. Other bases within the same major command used other methods to notify filers: a) ethics office developed its own successful tracking system for identifying required filers, b) HR office granted ethics office access to an HR system so that ethics office can generate its own lists of appointments. Ethics offices in other bases in this major command are working with their personnel offices to receive notification of new confidential filers. One base has a larger number of tenant units who are transferred internally to positions requiring confidential filing. These individuals are not processed through the personnel office. 4) One major command coordinates directly with senior leadership to determine who files, and unit training managers notify the ethics offices. 5) One major command stated that CPOs at some of its installation had new personnel who were not aware of the requirement. These CPOs are now aware of the requirement, and the legal office has been added to the CPO distribution list and Teams channel, where they can learn of appointments.

    b. Confidential Filers
In Some Cases (specify why, below)

    • If not applicable, specify why.
      NA

    • If "never" or "in some cases", please explain further:
      See explanations for public filers. The same explanations apply to the confidential filers.

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 Some Cases (specify why, below)

    • If not applicable, specify why.
      NA

    • If "never" or "in some cases", please explain further:
      Several ethics offices stated that their civilian personnel office notified them of the terminations in all or most cases. Several other ethics offices stated that their CPO never notified them or that this question was not applicable to their office. Selecting “in some cases” was the best compromise answer. The following are explanations from different Air Force ethics offices. 1) One major command stated that its public filers have a direct working relationship with their servicing ethics counselors and the filers provide the ethics counselors with timely notice of their intent to separate from Federal service. 2) One major command stated that their HR office forwards rosters of gains and losses monthly. 3) One major command has a small number of filing positions, and the individuals are prominent. The ethics office tracks the retirements. 4) One ethics office in a major command worked with trained POCs on the base to develop its own tracking system for identifying retiring filers. 5) Some organizations stated that their CPOs had no mechanism to track appointments or terminations. Instead, the ethics office works with supervisors to track filers. 6) Notifications of retirements to the ethics office were delayed due to turnover in the CPO office.

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), 278-T (pdf)

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

  • Select one
INTEGRITY and Other (specify)

  • Specify Other
    Army’s Financial Disclosure Management System (FDM)

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

  • Check all that apply
Confidential Financial Disclosure (OGE Form 450 or OGE-approved alternative form)

  • Provide the name of the other system:
    Army’s Financial Disclosure Management System (FDM)

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		Don’t know/don’t track

b. Amount paid to a federal agency in FY 2024
0		Don’t know/don’t track

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

  • Please explain "Don’t know/don’t track" answer above
    Expenses for the Army’s Financial Disclosure Management System are tracked and reported by the Army.

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
28998

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

  • Additional Comments
    Q28a. (Continued) 6) The legal offices of two organizations use the initial ethics training that they provide to incoming personnel to discuss the confidential filing requirement and direct attendees to confirm their filing status with their supervisors. Additional comments:
    Q28. One major command stated that in many cases the Human Resources Office does not notify unit ethics officials within the command of new filers or departing filers for both public and confidential filers. In some subordinate units, this notification does occur. However, in many cases, the supervisor of the filer notifies the ethics official of the filing status, or the ethics counselor reaches out to the Human Resources Office for updates on new or departing filers.
    Q29. In all cases of public disclosure 278 filers, the SAF/GC office has notified the MAJCOM Senior Ethics Counselor of filing status, for both new and termination reports within the timeline. Many of MAJCOM’s subordinate units do not have 278 filers.
    Q30-31. The overwhelming majority of reports (public and confidential) were filed electronically. There were a few situations in which filers submitted paper reports. SGEs filed paper OGE Form 450s because they did not have a CAC card. The issue has been remedied for the FDM e-filing system because SGEs will now be able to login using LOGIN.GOV. SGEs will be able to file electronically in the next filing cycle. A public filer used the PDF version of the OGE Form 278-T because he was overseas and did not want to access a government system from a foreign country.
    Q34. Expenses for the Army’s Financial Disclosure Management System are tracked and reported by the Army.
    Q35. The number of confidential filers who filed electronically is slightly up over last year. Due to a reorganization in the Department, numerous employees were moved to new divisions, and the new supervisors decided that the employees needed to file the OGE Form 450.


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
17
3
116
137
Filed
0
1
15
3
109
128
b. AnnualRequired
6
3
181
8
524
722
Filed
6
3
181
8
524
722
c. TerminationRequired
0
0
17
2
81
100
Filed
0
0
17
2
79
98
d. Combination1Required
1
0
6
0
17
24
Filed
1
0
6
0
15
22
    Total
Required
7
4
221
13
738
983
Filed
7
4
219
13
727
970

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.
    A few filers failed to respond to requests to file. The ethics offices are continuing attempts to contact the filers and their supervisors.

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
12
3
89
105
ii. Of those certified or closed in 2024, how many were initially reviewed within 60 days?
0
1
12
3
84
100
iii. Of those certified or closed in 2024, how many were certified or closed within 60 days?
0
1
12
3
77
93
b. Annual
PAS2
Non-Career SES3
Career SES3
Schedule C
Other4
TOTAL
i. How many reports did your agency certify or close in 2024?
6
3
174
8
516
707
ii. Of those certified or closed in 2024, how many were initially reviewed within 60 days?
6
3
171
8
477
665
iii. Of those certified or closed in 2024, how many were certified or closed within 60 days?
6
3
168
8
434
619
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
0
15
2
78
95
ii. Of those certified or closed in 2024, how many were initially reviewed within 60 days?
0
0
14
2
75
91
iii. Of those certified or closed in 2024, how many were certified or closed within 60 days?
0
0
14
2
70
86
d. Combination
PAS2
Non-Career SES3
Career SES3
Schedule C
Other4
TOTAL
i. How many reports did your agency certify or close in 2024?
1
0
6
0
15
22
ii. Of those certified or closed in 2024, how many were initially reviewed within 60 days?
1
0
6
0
15
22
iii. Of those certified or closed in 2024, how many were certified or closed within 60 days?
1
0
6
0
13
20
    Total
i. How many reports did your agency certify or close in 2024?
7
4
207
13
698
929
ii. Of those certified or closed in 2024, how many were initially reviewed within 60 days?
7
4
203
13
651
878
iii. Of those certified or closed in 2024, how many were certified or closed within 60 days?
7
4
200
13
594
818

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.
    The following responses were provided by different major commands. 1) Supervisor absences/unawareness of the need to review and sign the report in Integrity.gov within 60 days delayed the initial review by the Ethics Official in several cases. Six subordinate offices had personnel shortages and failed to notify the Certifying Official that their Ethics Officials were not available to conduct the initial review. Significant health issues of two ethics officials and the sudden death of one senior ethics official caused a delay in review at two offices. Nearly all the major command legal offices remain undermanned and overtasked with other missions, and the long delays in the Air Force hiring process only exacerbate the problems. 2) The technical review for two reports was not done within the 60-day timeline due to an administrative error. The major command’s Senior Ethics Counselor will ensure 100% of all 278 reports receive the review within the appropriate timeline.

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

  • Specify Other
    Significant health issues of two ethics officials and the sudden death of one senior ethics official caused a delay in certification at two offices. Nearly all the major command legal offices remain undermanned and overtasked with other missions, and the long delays in the Air Force hiring process only exacerbate the problems.

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

    • Periodic Transaction Reports Filed
531
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
239
12
1
    b. Number of OGE Form 278-T Reports
106
11
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
1

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

  • Enter total
4

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

  • Additional Comments
    Q37. (Continued) 3) Some supervisors transferred or retired before signing the reports of their subordinates. HR at these installations does not notify the ethics offices that supervisors had departed.

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
28998
OGE Form 450
28802
OGE-approved alternate form
0
Total
28998
28802

    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
    The following responses were provided by different major commands. 1) During the end of 2024 review, Certifying Officials in the major command identified seven individuals who should have filed a new entrant report but had not been assigned one in a timely manner. They were assigned those new entrant reports in Jan 2025. These filers will also be required to file a 2025 annual report (covering 2024) since they served in a covered position for >60 days in 2024. Three other individuals still have their new entrant reports in draft form and were reminded of the requirement to file but had not done so prior to 31 Dec 24. 2) The discrepancy in reports filed in one major command is due to a disconnect between employees leaving the unit or the Air Force and units failing to update FDM. 3) One major command stated that in some cases filers were reassigned to other organizations before the filing deadline, but they still appear in the FDM e-filing system under this major command. Some new entrants are overdue in submitting their reports. The legal office is working with the supervisors to collect the reports. 4) The incumbent left a covered position prior to completing the filing. 5) A change of command in a unit caused the delay in the supervisor review for one report out of 71 reports. 6) The filer misunderstood the filing requirement and did not complete the report prior to departing the Air Force.

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
28054
26656
26499

  • If applicable, please explain why some reports were reviewed more than 60 days after submission:
    The following responses were provided by different major commands. 1) Some supervisors failed to complete their reviews within 60 days, despite numerous reminders by the 450 Certifying Officials. Other offices had personnel shortages and absences that delayed their initial reviews. 2) Some subordinate offices experienced a turnover of ethics counselors resulting in a delay of review of the OGE Form 450s. In other cases, reports were amended and signed by the filer, but supervisor's signature was delayed despite repeat notices and attempts to coordinate action. 3) In the majority of cases at one major command, additional information was being sought. However, at the numbered Air Force and major command levels there were also issues regarding coordination with senior officers around official duty travel schedules. 4) Other mission requirements and manpower shortages across the major command caused the delay in report reviews. 5) Personnel turnover led to some delays in the initial review. 6) There were manpower issues at the major command and some of its installations. 7) The legal office experienced a turnover of ethics officials, which slowed the reviews of the 450s. There were complex filings that required additional information. 8) Ethics staff was learning the FDM e-filing system during filing season and did not understand how to use the system to maintain visibility of the status of the reports. 9) Ethics office did not have sufficient resources to process reports. 10) The major command had new POCs and certifiers in the financial disclosure program that needed training. Some filers and supervisors were on leave or on official duty at other locations and did not acknowledge reminder emails that the ethics office sent. 11) One ethics office reported that it determined that all 59 of its OGE Form 450s were initially reviewed within 60 days but that ethics officials did not click on the “end initial review” button in the e-filing system within 60 days. 12) One ethics office had significant staffing shortages in CY 2024, which led to the delay in the initial review. Many of the reports were reviewed within 100 days. The remaining reports were reviewed more than 100 days after filing because the office encountered a technical problem with FDM and worked with the major commands to identify a solution. The reports were reviewed and certified once a solution was identified.

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

  • Specify Other
    The following responses were provided by different major commands. 1) Some subordinate offices experienced a turnover of ethics counselors resulting in a delay of certification of the OGE Form 450s. In other cases, additional information was sought or remedial action on individual reports was required resulting in delay of certification. In some cases, supervisors caused a delay based upon their supervisory review not being signed early enough to complete. The major command’s Senior Ethics Counselor is working to reduce delay in review and certification by improving coordination with subordinate offices and by working with supervisors of filers to get reports signed, amended as necessary, and reviewed on time. 2) Supervisors failed to review in a timely manner. The filer’s supervisor changed after the report was signed by the filer and there was a delay changing the supervisor in the FDM e-filing system. 3) Personnel turnover led to some delays in certification. 4) The installation had manpower issues. The installation has since onboarded a new support staff member who will be dedicated to OGE Form 450 admin for the next reporting year, which should improve the statistics. The installation lost all of its civilian attorneys in CY 2024, but was able to hire two attorneys who will assist with the financial disclosure program. 5) Some legal offices experienced a turnover of ethics officials, which slowed the reviews of the 450s. 6) Ethics officials in some legal offices were not very familiar with the FDM e-filing system. For example, they did not know how to use the “manage exceptions” function or they could not find a report that had been filed. In addition, some supervisors could not find reports in the FDM e-filing system. As a result, some reports were open longer than usual. 7) Some supervisors did not sign the reports within 60 days, and the ethics official cannot sign until the supervisor signs the report. 8) The major command encountered technical issues with FDM.

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

  • Enter number
189

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
23

    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)
1

    vi. Subpart F (Seeking Other Employment)
8

    vii. Subpart G (Misuse of Position)
14

    viii. Subpart H (Outside Activities)
0

    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
3

    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)
1

    iv. 18 U.S.C. § 209 (Supplementation of Salary)
1

    v. 5 U.S.C. § 13106 or 18 U.S.C. § 1001 (Failure to File or Filing False Public Financial Disclosures)
1

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

    vii. 5 U.S.C. § 13144 (Outside Activities)
0

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
1

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

    i. How many of those referrals were accepted for prosecution?
0

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

    iii. How many of those referrals were pending DOJ’s decision as of December 31, 2024?
1

c. Agency Disciplinary Action Status
Of the referrals to DOJ (line a.), please note the agency disciplinary status:

    i. Of the cases referred to DOJ, how many resulted in disciplinary or corrective action?
0

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

    iii. Of the cases referred to DOJ, how many are pending a determination as to whether disciplinary or corrective action will be taken?
1

    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?
0

    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
1
0
0
2
0
3
    i. Signed the Ethics Pledge in 2024
1
0
0
2
0
3
    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
133

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
127

    i. How many of those SGEs received IET before or at the beginning of the first meeting?
117

    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?
10

    If applicable, please explain why some SGEs received IET after the first meeting or have yet to receive IET.
      Several SGEs resigned their positions prior to the first meeting and were not required to receive training. The SGEs who have not received IET did not respond to repeated requests to attend training.

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)
85
85
0
0
b. Advisory Committee Members (non-FACA)
0
0
0
0
c. Experts/Consultants
44
38
0
0
d. Board Members
0
0
0
0
e. Commissioners
0
0
0
0
f. Other
0
0
49
49
TOTAL
129
123
49
49

    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.
    a) Despite repeated requests, a few SGEs who are confidential filers remained non-compliant with the filing requirement. These SGEs were prohibited from participating as SGEs until they complied. Three of these individuals are no longer SGEs due to the change in administration, and the remainder have not been renewed until they comply. b) The SGEs who are public filers are reservists and did not serve on a board, commission, or committee.

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?
116
44
b. Of those certified or closed in 2024, how many were initially reviewed within 60 days?
116
41
c. Of those certified or closed in 2024, how many were certified or closed within 60 days?
112
39

  • If applicable, please explain why some reports were reviewed more than 60 days after submission.
    Public filers – ethics officials were waiting for additional information from filers.

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

  • Specify Other
    NA

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
25
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
    Part 10, Q48. The referral made to DOJ was to the DOJ Anti-Trust division. No conflict of interest statute was listed on the OGE Form 202. The Department of the Air Force is including this referral for completeness, but the case may not involve a violation of the conflict of interest statutes.