Model Guidance for Reviewing the Ethics Prgram in the Field

MODEL GUIDANCE FOR REVIEWING THE ETHICS PROGRAM IN THE FIELD

Confidential Financial Disclosure System

  1. Does the office have a list of employees/positions required to file Confidential Disclosure Reports (OGE 450s) or Conflict of Interest Certifications (CIC)?

  2. How are filers of the OGE Form 450 and the CIC identified?

  3. Is there a system for notifying employees who enter covered positions that they must file a Form 450 or a CIC?

  4. Who collects the CICs and/or makes sure they are filed properly?

  5. Were new entrant and annual Form 450s for the preceding filing period filed on time? (Unless an extension is granted, an employee must file a report within 30 days of entering a covered position and annually by October 31.)

  6. If a report was not filed on time, is there a note on the form that an extension was granted?

  7. Were Form 450s reviewed within 60 days of filing?

  8. Are Form 450s and CICs retained for six years?

  9. Are Form 450s and CICs filed in a secure place?

  10. Are Form 450s transferred to another office if an employee is transferred?

  11. Is one person responsible for administering the financial disclosure system in the office?

  12. Have any conflicts been identified in reviewing the Form 450s? If so, how were they resolved?

    (Reviewers should review a random sample of at least 10% of Form 450s filed and check a sample of CICs completed against case or contract assignments.)

 

Public Financial Disclosure System

  1. Does the office have a list of employees/positions required to file public financial disclosure reports (SF 278s)?

  2. Is there a system for notifying employees who enter covered positions that they must file an SF 278?

  3. Were new entrant, termination and annual SF 278s for the preceding calendar year filed on time? (Unless an extension is granted, an employee must file a report within 30 days of entering or leaving a covered position and annually by May 15.)

  4. If a report was not filed on time, is there a note on the form that an extension was granted?

  5. Were SF 278s reviewed within 60 days of filing?

  6. Are SF 278s retained for six years?

  7. Are SF 278s filed in a secure place?

  8. Are SF 278s transferred to another office if an employee is transferred?

  9. Is one person responsible for administering the financial disclosure system in the office?

  10. Have any conflicts been identified in reviewing the SF 278s? If so, how were they resolved?

    (Reviewers should review a random sample of SF 278s filed.)

 

Ethics Training

  1. Are new-entrant employees provided the standards of conduct and/or given ethics training or other materials to review within 90 days?

  2. Are employees who file SF 278s receiving annual verbal briefings?

  3. Are employees who file Form 450s or CICs receiving verbal briefings every third year and written materials to review in the intervening years?

  4. Is a qualified instructor providing the training?

    (Reviewers should review materials used, dates and length of training sessions and attendance lists.)

 

Miscellaneous Issues

  1. Have any employees received travel reimbursement from a non-federal source? If so, was prior approval granted in writing?

  2. Are employees informed of the need to obtain prior written approval for certain types of outside employment? (All employees must obtain approval to practice law or engage in employment that relates to the work of the employee's component. Employees in some components may be required to request approval for other outside employment.)

  3. Are requests to engage in outside employment reviewed by the office for conflict before sending to headquarters?

  4. Does the office distribute ethics information received from the component ethics official ?

  5. Has the office issued any written opinions to current or former employees?

  6. Do employees planning to leave government receive information on the post-employment restrictions?

Updated September 4, 2014