2025 AGENCY ETHICS PROGRAM QUESTIONNAIRE

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https://intpriaps02.oge.gov/Q25/Questionnaire/ethicsqprod.nsf/0/E6DFD30A460187D085258D7600616A35?OpenDocument

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 (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 agency programs as well as the overall executive branch ethics program, and to make informed decisions about resource allocation 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 2, 2026. (5 C.F.R. § 2638.207(a)).

PART 2. INSTRUCTIONS

Your response to this questionnaire should reflect the 2025 calendar year (i.e., 1/1/2025 through 12/31/2025), 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 2024 report. To safeguard privacy, please avoid the use of Personally Identifiable Information (PII) in your responses. After OGE has reviewed your questionnaire submission, you may be contacted for follow-up.

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PART 3. DEFINITIONS

Agency Head: For purposes of this questionnaire, the term "agency head" means the head of an agency. In the case of a department, it means the Secretary of the department. In the case of a board or commission, it means the Chair of the board or commission.

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.

Agency Employees: For purposes of this questionnaire, the term “agency employees” means any officer or employee of an agency, including a special Government employee. It 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

  • Defense Information Systems Agency

2. Employees

  • Number of full-time agency employees as of December 31, 2025
6291

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

a. Vacant (as of December 31, 2025)?
No

b. Time in current DAEO position
1 - 4 years

c. Total years performing ethics duties
10 or more years

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

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

f. Number of reporting levels between the DAEO and the agency head.
1

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

a. Vacant (as of December 31, 2025)?
No

b. Time in current ADAEO position
Less than 1 year

c. Total years performing ethics duties
5 - 9 years

d. Percent of time spent on ethics
51-75%

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

5. Report the number of employees, including the DAEO and ADAEO, who performed ethics program duties in 2025 (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
0
0
b. Outside the D.C. Metro area
18
6
2
1
1
28
TOTAL
18
6
2
1
1
28

* FTE = Full Time Equivalent

Example: The table below provides an example of an agency with 13 employees that performed ethics
program duties in 2025.

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)



  • Describe the IT support (optional):

  • Describe the administrative support (optional):

  • Describe the substantive support (optional):

  • Describe the other support:

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

  • Provide the name(s) of the federal agency or entity:
    1. Department of War Standards of Conduct Office (SOCO).
    2. Army Office of General Counsel (OGC).
    3. Air Force OGC.

  • Describe the services or support received:
    1. SOCO provided Department-wide guidance at monthly coordination meetings for Department ethics practitioners, and we consulted with SOCO several times during the year on difficult or novel ethics questions.
    2. Army is the executive agent for the Department's use of the Financial Disclosure Management (FDM) System, and the Army OGC provided user support to us throughout the year.
    3. Army and Air Force OGC POCs provided assistance in the assignment and completion the Office of Government Ethics (OGE) Form 278 Public Financial Disclosure Reports.

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

  • Provide the name(s) of the board, commission, or agency:
    SOCO

  • Describe the services or support provided:
    The Ethics Program provided a GS14 detailee to SOCO for three months.

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

  • Select type of resources

    Human Capital, Technology

  • Describe the other resources:

10. Did the agency head meet with the ethics staff to discuss the strengths and weaknesses of the ethics program in 2025?

  • Select Yes, No, or Not Applicable
Yes

  • Explain why not applicable:

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 2025 (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

12. What kind of changes resulted from the evaluation?

    Programmatic changes. Describe the programmatic changes.



  • Describe the programmatic; the policy changes; why no changes resulted; or why not applicable:
    (1) The Chief Ethics Officer began receiving bi-weekly updates on personnel actions for public financial disclosure filers, which facilitates the timely identification of new and departing filers. The Ethics Program also continues to sync monthly with the SES Program Manager to obtain additional visibility into impending personnel moves.
    (2) The Ethics Program streamlined the management of confidential financial disclosure filers in FDM by auditing our list of FDM POCs across the Agency, requesting organizations appoint replacement POCs for those who departed in CY25, and providing updated training on FDM to all POCs. This initiative was critical to maintaining accurate filer information after the loss of approximately 10% of the Agency’s workforce through the Deferred Resignation Program (DRP) and Voluntary Early Retirement Authority/Voluntary Separation Incentive Payments (VERA/VSIP), including the Ethics Program manager who had primary responsibility for the management of FDM.
    (3) To improve our data management capabilities (e.g., tracking requests for ethics advice, advice rendered by ethics officials, and compliance metrics), the Ethics Program planned to begin beta testing for FDM ETHOS, an ethics disclosure/compliance tool developed by SOCO. However, this initiative was paused due to the significant loss of Ethics Program personnel in CY25.

13. Of the following required written procedures, which did you have in place?
Select 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:

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

  • Additional Comments
    In CY24, the DISA General Counsel established the Chief Ethics Officer as a discrete position within DISA's OGC to provide day-to-day oversight of the Ethics Program and manage the attorneys & staff supporting the program. Unfortunately, DISA OGC overall lost 25% of its staff to DRP & VERA/VSIP with the Administrative Law & Ethics Team losing 60%, to include the Ethics Program Manager (PM), the Associate General Counsel for Administrative Law &Ethics, and a GS-12 attorney.

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)

  • Explain why not all offices (then skip to #16):

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?

  • Explain why not all offers:

  • Explain why not applicable:

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, 2025? 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, 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, 2025 (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
423
    i. How many of those employees received IET within the 3-month requirement?
334
    ii. How many of those employees received IET beyond the 3-month requirement?
0
    iii. How many of those employee have not received IET as of today?
89

Example: If an employee started at the agency on December 15, 2025, 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, 2026, the employee has not completed IET, do not count that employee in your required numbers. Instead, include the employee in your 2026 questionnaire response to be filed in 2027.

  • If applicable, explain why some employees received IET beyond the 3-month requirement or have yet to receive IET.
    Notification of training requirements among service members is not as streamlined as it is for the civilian workforce, especially outside of Headquarters. Additionally, tracking IET completion at field offices has historically been decentralized and reported out only at the end of the CY. CY25 was particularly challenging because the Agency, overall, lost approximately 10% of its workforce and experienced a hiring freeze. This loss of personnel affected New Employee Orientation (NEO) and the ability to properly track and/or follow up. The Ethics Program and DISA leadership are working to centralize IET tracking to improve the rate of completion.

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 2025?

  • Select One
Yes

  • Explain why not or why 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)
0
0

    b. All other public filers (OGE Form 278e)
28
28

    c. Confidential filers (OGE Form 450 and OGE-approved alternative confidential financial disclosure forms)
2101
2101

    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.)
3162
3162

TOTAL
5291
5291

  • If applicable, explain discrepancies between the number of employees who were required to receive training and the number of employees who received training:

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

    My agency established additional training requirements for other groups of employees, beyond those described in 5 C.F.R. § 2638.303-308 (notices to new employees and supervisors, initial ethics training, ethics briefings, annual ethics training). Describe the additional training requirements:

  • Describe the additional training requirements / procedures:
    All employees, not just Confidential Financial Disclosure filers, complete "Annual Ethics Training" and "Working with Contractors: Common Legal & Ethical Issues." The Ethics Program also holds additional live trainings and question/answer sessions through DISA's quarterly Symposium for Employee Engagement & Development (SEED). In CY25, SEED Training was provided on the following topics: "Hot Topics in Ethics," "Post Government Employment," & "450s & Conflicts of Interest." Finally, the Ethics Program published ethics articles on the internal agency website to further educate the workforce and keep ethics topics front of mind.

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):


Discussed upcoming work and agency priorities with senior staff, Talked to employees about the ethics concerns they encounter in the workplace.

  • Describe:

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, Held discussions with agency leaders and employees to evaluate whether the training and communications they received have supported them in managing ethics risks.

  • Describe:

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

  • Additional Comments
    Qs 22 & 23: The Ethics Program held trainings and provided additional guidance on targeted ethics issues of interest to the workforce. In CY25, DRP and VERA/VSIP generated an increased interest in and questions about seeking employment, outside employment, and post-Government employment. The DRP presented a unique scenario for addressing dual employment opportunities with Government contractors. In accordance with OGE's "Deferred Resignation Program and Other Extended Leave Statuses– Frequently Asked Questions" and SOCO's "ETHICS GUIDANCE FOR DO[W] EMPLOYEES PARTICIPATING IN THE OFFICE OF PERSONNEL MANAGEMENT DEFERRED RESIGNATION PROGRAM," the Chief Ethics Officer developed guidance for the DISA workforce to assist in understanding the laws, rules, and regulations that apply during the Deferred Resignation Period vs. after separation from Federal service. In CY25 the Ethics Program revised its Annual Ethics Training (AET) for Seniors for CY26. Of note, leader-led live training will be conducted in small groups of a few Seniors and their staff to provide the most relevant and useful information to the required Seniors along with their staff, who are first and/or more frequently aware of potential hurdles/pitfalls.

PART 6. ADVICE, COUNSELING, AND REMEDIES

24. From the list below, select the three topics that your employees most frequently sought guidance on in 2025. Rank 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
Post-employment restrictions

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

25. Number of notification statements of negotiation or recusal under section 17(a) of the STOCK Act submitted to the ethics office in 2025 (pursuant to 5 C.F.R. § 2635.602(a):

  • Enter total
9

26. Number of 18 U.S.C. § 208 waivers granted in 2025:

Number Granted in 2025
Number Sent to OGE
    a. 208(b)(1) waivers
0
0
    b. 208(b)(3) waivers
0
0

  • If applicable, explain discrepancies between the number of waivers granted and the number provided to OGE.

27. Number of Legal Expense Fund documents filed in 2025 (pursuant to 5 C.F.R. § 2635.1007):

Number Filed in 2025
Number Sent to OGE
    a. Trust Documents
0
0
    b. Quarterly Reports
0
0
    c. Termination Report
0
0

  • If applicable, explain discrepancies between the number of documents filed and the number provided to OGE.

ADDITIONAL COMMENTS FOR PART 6. 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:

    • If "never" or "in some cases", explain:

    b. Confidential Filers
In Most Cases

    • If not applicable, specify why:

    • If "never" or "in some cases", explain:

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 All Cases

    • If not applicable, specify why:

    • If "never" or "in some cases", explain:

30. Were all public and confidential financial reports, in calendar year 2025, filed using an electronic filing system?

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

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

  • Select all that apply

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

  • Select one
INTEGRITY and Other

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

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

34. Indicate your agency's fiscal year 2025 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 fiscal year 2025
0
0

b. Amount paid to a federal agency in fiscal year 2025
0
0

c. Amount for all internal costs associated with operating an e-filing system (e.g., FTE, overhead, etc.) in fiscal year 2025Don’t know/don’t track
Don’t know/don’t track

  • Please explain "Don’t know/don’t track" answer above
    FDM is an Army program (run on DISA systems) for all of DoW (and some other agencies), and we do not pay a fee for using it.

35. Indicate the number of filers who filed electronically in fiscal year 2025. Number of financial disclosure filers, not reports, who filed electronically in fiscal year 2025.

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

    b. confidential financial disclosure filers
2136

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

  • Additional Comments


PART 8. PUBLIC FINANCIAL DISCLOSURE

36. Report the number of public financial disclosure reports (OGE Form 278e) required to be filed by December 31, 2025, excluding SGEs, and the number of reports actually filed (i.e., received) by December 31, 2025.

OGE Form 278e Reports
PAS2
Non-Career SES3
Career SES3
Schedule C
Other4
TOTAL
a. New EntrantRequired
0
0
0
0
4
4
Filed
0
0
0
0
4
4
b. AnnualRequired
0
0
19
0
6
25
Filed
0
0
19
0
5
24
c. TerminationRequired
0
0
4
0
3
7
Filed
0
0
4
0
2
6
d. Combination1Required
0
0
0
0
1
1
Filed
0
0
0
0
1
1
    Total
Required
0
0
23
0
14
37
Filed
0
0
23
0
12
35

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, 2025, 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, 2026, 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 2026 questionnaire response to be filed in 2027.

  • If applicable, explain discrepancies between the number of reports required to be filed and the actual number of reports filed.
    Q36.b.&c.: The Annual & Termination Report not filed timely are from the same filer, a servicemember. In light of his retirement (29 May 2025), the Ethics Program requested the Air Force issue the filer a combination report however, they declined and the filer was issued both an Annual & Termination for filing in 2025. Prior to his retirement, numerous attempts were made to contact the filer. After retirement, the Ethics Program had no contact information for or contact with the filer until he got in touch with the Ethics Program, in the Fall of CY25, to request post-Government employment advice. At that point, the filer was without a CAC and the Ethics Program assisted in getting him set up in Login.gov using his personal email address and coordinated with Integrity to make that update and merge the reports. Reports were filed on 20 & 21 January 2026. The Ethics Program will coordinate with the Air Force on the assessment of any fines.

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 2025?
0
0
0
0
4
4
ii. Of those certified or closed in 2025, how many were initially reviewed within 60 days?
0
0
0
0
3
3
iii. Of those certified or closed in 2025, how many were certified or closed within 60 days?
0
0
0
0
3
3
b. Annual
PAS2
Non-Career SES3
Career SES3
Schedule C
Other4
TOTAL
i. How many reports did your agency certify or close in 2025?
0
0
17
0
8
25
ii. Of those certified or closed in 2025, how many were initially reviewed within 60 days?
0
0
4
0
3
7
iii. Of those certified or closed in 2025, how many were certified or closed within 60 days?
0
0
4
0
2
6
c. Termination
PAS2
Non-Career SES3
Career SES3
Schedule C
Other4
TOTAL
i. How many reports did your agency certify or close in 2025?
0
0
3
0
4
7
ii. Of those certified or closed in 2025, how many were initially reviewed within 60 days?
0
0
3
0
4
7
iii. Of those certified or closed in 2025, how many were certified or closed within 60 days?
0
0
2
0
3
5
d. Combination
PAS2
Non-Career SES3
Career SES3
Schedule C
Other4
TOTAL
i. How many reports did your agency certify or close in 2025?
0
0
1
0
0
1
ii. Of those certified or closed in 2025, how many were initially reviewed within 60 days?
0
0
1
0
0
1
iii. Of those certified or closed in 2025, how many were certified or closed within 60 days?
0
0
1
0
0
1
    Total
i. How many reports did your agency certify or close in 2025?
0
0
21
0
16
37
ii. Of those certified or closed in 2025, how many were initially reviewed within 60 days?
0
0
8
0
10
18
iii. Of those certified or closed in 2025, how many were certified or closed within 60 days?
0
0
7
0
8
15

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, explain why some reports were reviewed more than 60 days after submission.
    DISA OGC overall lost 25% of its staff to DRP & VERA/VSIP with the Administrative Law & Ethics Team losing 60%, to include the Ethics Program Manager (PM), the Associate General Counsel for Administrative Law & Ethics, and a GS-12 attorney. The prior Program Manager and the prior Associate General Counsel handled all aspects of OGE 278 Public Financial Disclosures, to include the technical and legal compliance. Additionally, there were more OGE 278 reports in CY25 than in the prior year (with more personnel changes among SESes) with fewer personnel to manage them. Q37c.: The Career SES termination report not certified in 60 days was a public filer who was on medical leave without pay, pending disability retirement related to a cognitive impairment, and obtaining information/clarification was a challenge.

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

  • Describe:
    DISA OGC overall lost 25% of its staff to DRP & VERA/VSIP with the Administrative Law & Ethics Team losing 60%, to include the Ethics Program Manager (PM), the Associate General Counsel for Administrative Law & Ethics, and a GS-12 attorney. The prior Program Manager and the prior Associate General Counsel handled all aspects of OGE 278 Public Financial Disclosures, to include the technical and legal compliance. Additionally, there were more OGE 278 reports in CY25 than in the prior year (with more personnel changes among SESes) with fewer personnel to manage them.

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

    • Periodic Transaction Reports Filed
17
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. Report the number of 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
5
2
0
    b. Number of OGE Form 278-T Reports
0
1
0

40. Number of public financial disclosure filers reported in calendar year 2025 to the Attorney General for failure to file:

  • Enter total
0

41. Number of requests for public financial disclosure reports received in 2025: Count each OGE Form 201 as one request, even if it contains a request for documents for multiple individuals.

  • Enter total
0

42. Number of documents requested under the Ethics in Government Act released in calendar year 2025:

  • Enter total
0

ADDITIONAL COMMENTS FOR PART 8. 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, 2025, excluding SGEs, and the number of reports actually filed by December 31, 2025.

a. Required
b. Filed
2136
OGE Form 450
2134
OGE-approved alternate form
0
Total
2136
2134

    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, 2025, 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, 2026 the employee has not filed a new entrant report, do not count that report in your required numbers. Instead, include the report in your 2026 questionnaire response to be filed in 2027.

    If applicable, explain discrepancies between the number of reports required to be filed and the actual number of reports filed.
    The Administrative Law & Ethics Team lost 60% of its personnel, to include the Ethics Program Manager (PM), the Associate General Counsel for Administrative Law & Ethics, and a GS-12 attorney. The prior PM was the primary for tracking and following up with filers to provide suspenses and get reports completed. Additionally, there were more OGE 450 reports in CY25 than in the prior year with fewer personnel to manage them. Despite these hurdles, all but two reports were filed. Both filers' reports were assigned/due in October/November (during the Government shutdown) which necessarily caused delays. We have made repeated attempts to contact the filers and their leadership. We continue to escalate and will take action as appropriate.

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 2025?
b. Of those certified or closed in 2025, how many were initially reviewed within 60 days?
c. Of those certified or closed in 2025, how many were certified or closed within 60 days?
OGE Form 450 and OGE-approved alternative
2125
1980
1949

  • If applicable, explain why some reports were reviewed more than 60 days after submission:
    There were more OGE 450 reports in CY25 than in the prior year with fewer personnel to manage them. The Administrative Law & Ethics Team lost 60% of its personnel, to include the Ethics Program Manager (PM), the Associate General Counsel for Administrative Law & Ethics, and a GS-12 attorney. At DoW, part of the review chain requires that the filer’s supervisor review and sign the report confirming that there is no conflict of interest between reported financial interests and reporting individual's current and anticipated official duties. Supervisory review must be conducted within 14 calendar days of filer submission. It is a significant challenge tracking and ensuring supervisor compliance with that requirement to ensure timely review/certification. The prior PM, who took DRP, was the primary for tracking and following up with filers and supervisors to get reports filed and signed.

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

  • Describe:
    There were more OGE 450 reports in CY25 than in the prior year with fewer personnel to manage them. The Administrative Law & Ethics Team lost 60% of its personnel, to include the Ethics Program Manager (PM), the Associate General Counsel for Administrative Law & Ethics, and a GS-12 attorney. At DoW, part of the review chain requires that the filer’s supervisor review and sign the report confirming that there is no conflict of interest between reported financial interests and reporting individual's current and anticipated official duties. Supervisory review must be conducted within 14 calendar days of filer submission. It is a significant challenge tracking and ensuring supervisor compliance with that requirement to ensure timely review/certification. The prior PM, who took DRP, was the primary for tracking and following up with filers and supervisors to get reports filed and signed.

45. Number of OGE 450 or OGE-approved alternative forms granted filing extensions in 2025.

  • Enter number
6

ADDITIONAL COMMENTS FOR PART 9. Indicate the question number to which the comment corresponds.

  • Additional Comments
    N/A

PART 10. ENFORCEMENT OF STANDARDS OF CONDUCT AND CRIMINAL AND CIVIL STATUTES

46. Report the number of disciplinary actions taken in 2025 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
27

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

    i. Subpart A (General Provisions)
27

    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)
0

    ix. Subpart J (Legal Expense Funds)
0

    x. Agency's supplemental Standards of Conduct
27

47. Report the number of disciplinary actions taken in 2025 based wholly or in part upon violations of the criminal conflict of interest statutes (18 U.S.C. §§ 203, 205, 208, and 209), failure to file or filing false public financial disclosures (5 U.S.C. § 13106 or 18 U.S.C. § 1001), a civil matter involving outside earned income (5 U.S.C. § 13143), or outside activities (5 U.S.C. § 13144). For purposes of this question, disciplinary actions include removals, demotions, suspensions, and written reprimands or their equivalents.

a. Disciplinary actions taken based on violation of ethics laws
0

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

    i. 18 U.S.C. § 203 (Compensation in Matters Affecting the Government)

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

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

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

    v. 5 U.S.C. § 13106 (Failure to File)

    vi. 18 U.S.C. § 1001 (Filing False Public Financial Disclosures)

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

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

48. Report the number of referrals made in 2025 to the Department of Justice (DOJ) of potential violations of the conflict of interest statutes (18 U.S.C. §§ 203,205, 207, 208, 209), failure to file or filing false public financial disclosures (5 U.S.C. § 13106 or 18 U.S.C. § 1001), a civil matter involving outside earned income (5 U.S.C. § 13143), or outside activities (5 U.S.C. § 13144).

a. Referrals to Department of Justice
0

b. DOJ Referrals Status
Of the referrals to DOJ (line a.), provide the status of each referral:

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

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

    iii. How many of those referrals were pending DOJ’s decision as of December 31, 2025?

c. Agency Disciplinary Action Status
Of the referrals to DOJ (line a.), provide the status of any associated agency disciplinary action:

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

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

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

    iv. Of the cases referred to DOJ, how many of those referrals involved employees who left the agency before the agency determined whether or not to take disciplinary action?

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

49. Did your agency notify OGE of all referral(s) and disposition(s) of the referral(s) via OGE Form 202 pursuant to 5 C.F.R. § 2638.206(a)?

  • Select answer
Not applicable because no covered referrals were made to DOJ

  • Explain why not:

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

  • Additional Comments

PART 11. SPECIAL GOVERNMENT EMPLOYEES (SGEs)

50. How many special Government employees (SGEs) did your agency have, in total, during calendar year 2025? (If zero, skip to Additional Comments for this Part.)

  • Enter number
0

51. 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, 2025 (5 C.F.R. § 2638.304(b)(2))?

Total number
0

    i. How many of those SGEs received IET before or at the beginning of the first meeting?
0

    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, explain why some SGEs received IET after the first meeting or have yet to receive IET:

52. Report the number of SGE public and confidential financial disclosure reports required to be filed by December 31, 2025 and the number of reports actually filed by December 31, 2025.

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

    Example for new entrant and termination reports: If an employee joined (or departed) the agency on December 15, 2025, 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 2026 questionnaire response to be filed in 2027.

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

53. Report 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 2025?
0
0
b. Of those certified or closed in 2025, how many were initially reviewed within 60 days?
0
0
c. Of those certified or closed in 2025, how many were certified or closed within 60 days?
0
0

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

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

  • Describe:

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

  • Enter number
0

55. Number of 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 Reports or OGE-Approved Alternative Forms
0

ADDITIONAL COMMENTS FOR PART 11. Indicate the question number to which the comment corresponds.

  • Additional Comments
    N/A

ADDITIONAL QUESTIONNAIRE COMMENTS:

  • Additional Comments
    N/A

      OGE Form 450A
0
hidden element

By POC
Submitted by POC (See above)

Date
02/23/2026