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Don’t Overlook Oversight

July 26, 2023

Chip Christopher, Deputy Director of Compliance

Every day, thousands of officials and support staff are hard at work across more than 140 agencies implementing ethics practices and policies. These officials advise employees, review disclosures, manage risk, and train federal employees. They are trusted advisors, effective managers, and capable administrators. Their efforts in service of the executive branch ethics program are vital to the trust between the American people and their government.

But, this large and decentralized program is not immune from risk. The health of the entire ethics program is affected by the strength of each agency’s program. So, who ensures that weaknesses at the agency level don’t cause failure? A primary answer is the Office of Government Ethics (OGE). OGE keeps an eye on the health of the executive branch ethics program in a number of ways.

Some of the most intensive oversight mechanisms are formal “plenary” reviews of executive branch ethics programs. OGE reviewers carefully examine agency policies and procedures and discuss with ethics officials the administration of their programs. They check for lapses in compliance, timeliness in meeting requirements, and prevalence of programmatic risk. These reviews function as a full work-up of an agency’s ethics program. OGE probes for weaknesses and, when it finds them, issues formal recommendations to help agencies improve. When recommendations are made, OGE then conducts follow-up reviews to ensure that action has been taken to address the identified weaknesses.

OGE also conducts less intensive reviews called inspections. Inspections focus on key compliance criteria and allow OGE to quickly and efficiently assess the health of ethics programs. When inspections identify deficiencies, OGE issues formal recommendations and follows up just like during a plenary review.

Finally, OGE requires every agency to submit to an annual check-up. In the Annual Agency Ethics Program Questionnaire agencies are required to self-report to OGE across a broad range of compliance metrics. OGE learns about timeliness of trainings and filings, prevalence of good practices, advice and enforcement, and a whole host of other data. OGE reviews each agency’s submission, compares it to the previous year’s report, and looks for anomalies that might suggest systemic problems. When OGE finds issues, we follow up and may even decide a more substantial review is in order to find out what is going on.

Oversight of the executive branch ethics program is vital to the program’s success. OGE uses a variety of tools to ensure agency ethics programs are performing well. As with much of our work, the results are made public so the American people can see for themselves how their government is doing. We encourage you to take a look.