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Pre-Employment Clearance for 278 Filer Positions

Ethics Topics | Pre-Employment Clearance for 278 Filer Positions

Procedure for Pre-Employment Ethics Orientation and Conflict of Interest Resolution for SF 278 Filers

On October 1, 2004, the Secretary of the Department of Health and Human Services (HHS) distributed a memo emphasizing the importance of ethical conduct and integrity for all HHS employees. To further that effort, a memo establishing a new requirement that candidates for positions subject to filing the Public Financial Disclosure Report (SF 278) must complete four steps prior to entering on duty. The selected individual must have:

  1. Filed a completed new entrant form SF 278 with the HHS Office of the General Counsel, Ethics Division (OGC/ED);
  2. Executed an ethics agreement, where appropriate, that is satisfactory to the Designated Agency Ethics Official (DAEO), or his designee;
  3. Received an initial ethics orientation or similar briefing from the DAEO's office, in person, by telephone, or other means; and
  4. Received a final ethics clearance from the DAEO or his designee.

The following procedures and sample documents implement these requirements at the National Institutes of Health (NIH): (all documents are in Acrobat pdf format)

Addenda Mentioned in the Above Procedures:

For assistance and additional information, contact your IC's Deputy Ethics Counselor or Ethics Coordinator.


*NOTE: You must have the free Acrobat Reader software on your computer to review and print these forms or documents in pdf format. If you do not have the Reader software, you may download it below. Note that after you download the file, you must also install it. Please carefully read the instructions on the download screen and complete both steps.

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Updated: 8/31/07