2025 AGENCY ETHICS PROGRAM QUESTIONNAIRE

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https://intpriaps02.oge.gov/Q25/Questionnaire/ethicsqprod.nsf/0/BD1B3CCB48B9546485258D94005A6265?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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If you have any further questions, please contact Nicole Stein at nstein@oge.gov

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

  • Department of Health and Human Services

2. Employees

  • Number of full-time agency employees as of December 31, 2025
74640

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

a. Vacant (as of December 31, 2025)?
Yes (skip to #4a)

b. Time in current DAEO position

c. Total years performing ethics duties

d. Percent of time spent on ethics

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

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

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

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

b. Time in current ADAEO position
1 - 4 years

c. Total years performing ethics duties
10 or more years

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

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

5. 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
103
38
7
4
139
291
b. Outside the D.C. Metro area
40
2
0
2
47
91
TOTAL
143
40
7
6
186
382

* 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

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.)

  • 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
No

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

  • Describe the services or support received:

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

  • Select Yes or No
Yes

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

  • Describe the services or support provided:
    HHS has operated under an MOU with the Department of Education (ED) to assist with shepherding Presidential nominees through that process. We have also provided training and support to ED’s new ethics team after ED’s former ethics team was placed on admin leave subject to RIF actions.

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

  • Select type of resources

    Human Capital, Technology
    Other (specify below)

  • Describe the other resources:
    Due to RIF actions and other employee departures, many ethics teams throughout the Department are operating with fewer staff, including staff who are new to working with the ethics program. Thus, many teams report not just that they could benefit from more staff, but specifically staff with prior ethics experience. They also report a need for technology solutions that could make up for the loss in support staff. Finally, they report that additional funding could help them with the first two needs.

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., Policy changes. Describe the policy changes.



  • Describe the programmatic; the policy changes; why no changes resulted; or why not applicable:
    One program has implemented a clearance process before expert/consultant SGEs are onboarded, increased communications with all filers, and has worked to increase presence and visibility at meetings and briefings. One program improved overall processes and procedures and developed an integrated case management system. One program improved tracking methods for IET and AET. One other program's evaluation has not been completed.

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

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
12
    i. How many new agency leaders received their briefing within 15 days of their appointment?
11
    ii. How many of those leaders received their briefing beyond the 15-day requirement?
1
    iii. How many new agency leaders have yet to receive their briefing as of today?
0

    If applicable, explain why some of the leaders received their briefing beyond the 15-day requirement or have yet to receive their briefing.
    The Assistant Secretary for Legislation (ASL) originally scheduled his initial ethics briefing within the required 15 days however, on the day scheduled for his briefing, the Senate was voting on the One Big Beautiful Bill Act. Because that bill had many provisions that directly impacted HHS, it was essential for the ASL to be focused on that. The DAEO granted an extension for his initial ethics briefing, and he received his initial ethics briefing the following week.

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
2132
    i. How many of those employees received IET within the 3-month requirement?
1754
    ii. How many of those employees received IET beyond the 3-month requirement?
306
    iii. How many of those employee have not received IET as of today?
72

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.
    Primary reasons include technological problems accessing the HHS Learning Management System, confusion between IET and AET requirements, employees on extended leave (other than administrative leave), inability to track due to personnel actions affecting members of ethics teams, administrative oversight, lack of timely communication from HR, and employee noncompliance.

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

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

  • Please Explain why not all offices:

19. Did the head of the agency complete either initial ethics training and/or annual ethics training in 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)
2
2

    b. All other public filers (OGE Form 278e)
1251
1182

    c. Confidential filers (OGE Form 450 and OGE-approved alternative confidential financial disclosure forms)
29950
29192

    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.)
28
28

TOTAL
31231
30404

  • If applicable, explain discrepancies between the number of employees who were required to receive training and the number of employees who received training:
    Primary reason is employees on extended medical, family, military, or administrative leave. Other reasons include technological problems accessing the HHS Learning Management System, confusion between IET and AET requirements, inability to track due to personnel actions, and employee noncompliance.

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

    My agency established additional training requirements for employees performing ethics duties described in 5 C.F.R. § 2638.104-105 (ethics and human resources officials). Describe the additional training requirements:, 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:
    New Deputy Ethics Counselors (DECs) and Ethics Coordinators (ECs) are required to complete an orientation training with Ethics Division attorneys. Most components require all employees to complete annual ethics training. At the time the data was compiled, 32,390 non-covered employees completed AET. Some components require new employees to attend an ethics orientation, in addition to completing HHS’s IET. The Ethics Division provides many optional trainings throughout the year including a training series for new ethics officials, financial disclosure reviewer trainings, a new supervisor training, topical trainings open to all HHS employees, and, on request, topical trainings to individual components.

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 Describe:

  • Describe:
    Programs worked with Ethics Division to understand and manage the risks that arose while many employees were on administrative leave and developed standard guidance messages for those employees. Some programs met with individual employees to discuss risks in specific situations. One component does a quarterly risk assessment. The Ethics Division sent risk management communications to our ethics officials, including about employees on administrative leave, gambling in the workplace, and a lapse in appropriations.

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

  • Describe:

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

  • Additional Comments

PART 6. ADVICE, COUNSELING, AND REMEDIES

24. From the list below, select the three topics that your employees most frequently sought guidance on in 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
Outside employment/activities
  • 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 2025 (pursuant to 5 C.F.R. § 2635.602(a):

  • Enter total
299

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
4
4
    b. 208(b)(3) waivers
102
161

  • If applicable, explain discrepancies between the number of waivers granted and the number provided to OGE.
    Waivers at NIH are submitted to OGE on a quarterly basis. Consistent with reporting in previous years, NIH data for the “Number Sent to OGE” reflects waivers sent in Q4 of FY24 and Q1-Q3 of FY25.

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 Most 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
No

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

  • Select all that apply
450 (pdf), 450 (excel), 278e (pdf), 278e (excel), 278-T (pdf), 278-T (excel)

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

  • Provide the name of the other system:
    1. HHS Electronic Financial Disclosure System (EFDS) 2. NIH: NIH Enterprise Ethics System (NEES) 3. CDC: Ethics Program Activity Tracking System (EPATS) and 4. CMS: CMS Administrative Technology Solutions (CATS)

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 2025Don’t know/don’t track

1897700

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
    Our components who use legacy filing systems do not break out costs for various system components (i.e. public or confidential financial disclosure reports) nor by where the costs are going. Thus, all costs are reported as a lump sum paid to a non-federal vendor.

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)
607

    b. confidential financial disclosure filers
35837

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
83
18
148
128
377
Filed
0
83
18
148
128
377
b. AnnualRequired
0
0
422
0
831
1253
Filed
0
0
419
0
825
1244
c. TerminationRequired
14
90
90
94
170
458
Filed
14
90
86
94
153
437
d. Combination1Required
0
0
34
0
64
98
Filed
0
0
33
0
61
94
    Total
Required
14
173
564
242
1193
2186
Filed
14
173
556
242
1167
2152

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.
    Filer noncompliance. In one component, many ethics officials were subject to personnel actions and were thus unavailable to track filing compliance. In addition, HR staff were similarly subject to personnel actions and were unavailable to notify ethics officials when there were changes to filers’ status. Components are working to collect missing reports.

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
80
16
140
99
335
ii. Of those certified or closed in 2025, how many were initially reviewed within 60 days?
0
80
15
140
96
331
iii. Of those certified or closed in 2025, how many were certified or closed within 60 days?
0
63
12
123
66
264
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
404
0
709
1113
ii. Of those certified or closed in 2025, how many were initially reviewed within 60 days?
0
0
389
0
679
1068
iii. Of those certified or closed in 2025, how many were certified or closed within 60 days?
0
0
358
0
566
924
c. Termination
PAS2
Non-Career SES3
Career SES3
Schedule C
Other4
TOTAL
i. How many reports did your agency certify or close in 2025?
14
90
76
96
116
392
ii. Of those certified or closed in 2025, how many were initially reviewed within 60 days?
14
90
73
95
113
385
iii. Of those certified or closed in 2025, how many were certified or closed within 60 days?
13
74
65
85
102
339
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
33
0
56
89
ii. Of those certified or closed in 2025, how many were initially reviewed within 60 days?
0
0
33
0
53
86
iii. Of those certified or closed in 2025, how many were certified or closed within 60 days?
0
0
30
0
41
71
    Total
i. How many reports did your agency certify or close in 2025?
14
170
529
236
980
1929
ii. Of those certified or closed in 2025, how many were initially reviewed within 60 days?
14
170
510
235
941
1870
iii. Of those certified or closed in 2025, how many were certified or closed within 60 days?
13
137
465
208
775
1598

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.
    In many components, all ethics officials were placed on administrative leave, and the components did not select alternate employees to fill ethics roles until more than 60 days after reports were filed. Those alternate employees did not have experience and took time learning how to review financial disclosure reports.

  • 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, Remedial action was being taken
    Other

  • Describe:
    In all components, significant numbers of employees were subject to personnel actions, and ethics officials had many competing workload priorities after functions were redistributed. In many components, all ethics officials were placed on administrative leave, and the components did not select alternate employees to fill ethics roles until more than 60 days after reports were filed. Those alternate employees did not have experience and took time learning how to review financial disclosure reports. Lastly, some certifications were delayed due to the 43-day furlough.

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

    • Periodic Transaction Reports Filed
1396
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
310
9
1
    b. Number of OGE Form 278-T Reports
92
24
1

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
103

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

  • Enter total
211

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
35293
OGE Form 450
35223
OGE-approved alternate form
0
Total
35293
35223

    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.
    Filer noncompliance. Administrative oversight when existing employees were promoted into filing positions. In many components, most or all ethics officials were placed on administrative leave and were thus unavailable to track filing compliance. Administrative oversights that have been identified are being remedied.

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
34929
29008
26270

  • If applicable, explain why some reports were reviewed more than 60 days after submission:
    In many components, all ethics officials were placed on administrative leave, and the components did not select alternate employees to fill ethics roles until more than 60 days after reports were filed. Those alternate employees did not have experience and took time learning how to review financial disclosure reports. Other reasons include seeking additional information filers, seeking remedial action, competing workload priorities, and the 43-day furlough.

  • 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, Remedial action was being taken
    Other

  • Describe:
    In all components, significant numbers of employees were subject to personnel actions, and ethics officials had many competing workload priorities after functions were redistributed. In many components, all ethics officials were placed on administrative leave, and the components did not select alternate employees to fill ethics roles until more than 60 days after reports were filed. Those alternate employees did not have experience and took time learning how to review financial disclosure reports. Lastly, some certifications were delayed due to the 43-day furlough.

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

  • Enter number
1982

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

  • Additional Comments

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
4

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

    i. Subpart A (General Provisions)
1

    ii. Subpart B (Gifts from Outside Sources)
0

    iii. Subpart C (Gifts between Employees)
0

    iv. Subpart D (Conflicting Financial Interests)
3

    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
0

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
2

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

    i. 18 U.S.C. § 203 (Compensation in Matters Affecting the Government)
0

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

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

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

    v. 5 U.S.C. § 13106 (Failure to File)
0

    vi. 18 U.S.C. § 1001 (Filing False Public Financial Disclosures)
0

    vii. 5 U.S.C. § 13143 (Outside Earned Income)
2

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

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
3

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?
2

    ii. How many of those referrals were declined for prosecution?
1

    iii. How many of those referrals were pending DOJ’s decision as of December 31, 2025?
0

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?
0

    ii. Of the cases referred to DOJ, how many resulted in a determination not to take disciplinary or corrective action?
1

    iii. Of the cases referred to DOJ, how many are pending a determination as to whether disciplinary or corrective action will be taken?
0

    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?
2

    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 pursuant to 5 C.F.R. § 2638.206(a)?

  • Select answer
Yes

  • 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
6286

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
2348

    i. How many of those SGEs received IET before or at the beginning of the first meeting?
917

    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?
1431

    If applicable, explain why some SGEs received IET after the first meeting or have yet to receive IET:
      Most committees did not meet in 2025, so did not require SGEs to complete training. SGEs who did not complete training did not participate in any government matters.

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)
798
750
0
0
b. Advisory Committee Members (non-FACA)
26
26
0
0
c. Experts/Consultants
21
21
0
0
d. Board Members
0
0
0
0
e. Commissioners
0
0
0
0
f. Other
128
128
0
0
TOTAL
973
925
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:
    Most committees did not meet in 2025. SGEs who did not complete financial disclosures did not participate in any government matters.

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?
902
0
b. Of those certified or closed in 2025, how many were initially reviewed within 60 days?
900
0
c. Of those certified or closed in 2025, how many were certified or closed within 60 days?
899
0

  • If applicable, explain why some reports were reviewed more than 60 days after submission.
    One committee management office was terminated, and reviews were delayed while functions were transferred to another office. One component’s meetings were put on hold and ethics officials were instructed not to perform any further work on committee members’ financial disclosures. One component’s SGEs were deployed in disaster responses and were delayed in responding to questions from ethics officials.

  • 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:

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

  • Enter number
4932

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
11

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

  • Additional Comments
    Q54: Exempt SGEs are primarily employed through the National Disaster Medical System (NDMS) to respond to major disasters or provide per diem nursing services at the NIH Clinical Center.

ADDITIONAL QUESTIONNAIRE COMMENTS:

  • Additional Comments

      OGE Form 450A
0
hidden element

By POC
Submitted by POC (See above)

Date
02/09/2026