U.S. Office of Government Ethics 1201 New York Avenue, NW Suite 500 Washington, DC 20005-3917 May 2, 2005 DO-05-011 MEMORANDUM TO: Designated Agency Ethics Officials FROM: Marilyn L. Glynn Acting Director SUBJECT: Rotational Assignment Program The U.S. Office of Government Ethics (OGE) is pleased to announce a program for temporary rotational assignments within the executive branch ethics program. This memorandum describes the purpose of the Rotational Assignment Program (RAP) and provides guidelines for its administration. PURPOSE The purpose of the RAP is to strengthen the executive branch ethics program by providing professional development opportunities for executive branch employees who work in the ethics program, as well as for OGE employees who have substantive ethics program duties. Participating employees have an opportunity to strengthen existing competencies and acquire new skills by serving in a temporary rotational assignment in a host agency. Such assignments provide an opportunity for individual professional growth and enhance the overall professional development of the executive branch ethics workforce. The RAP provides the framework for making available these assignments to highly qualified and highly motivated participants who can make a significant contribution to the ethics program. ASSIGNMENTS AT OGE A rotational assignment on the staff of OGE will provide an opportunity for a participating agency employee to gain an executive branch-wide perspective on ethics policy and the oversight of the executive branch ethics program. Depending on the OGE office where the assignment is located, an agency employee will have an opportunity to gain a better understanding of how OGE approaches legal issues, what executive branch-wide considerations are involved in setting ethics policy, how OGE prepares for an agency program review, how OGE assesses ethics training needs and develops ethics training products, how OGE provides services and support of agency ethics programs, how OGE fulfills its role in the nominee process, how OGE monitors proposed legislation that impacts the ethics program, and how OGE provides international technical assistance in connection with anti-corruption initiatives. This experience will enable a participating employee to bring back knowledge and expertise that will contribute to the agency’s ethics program and advance the employee’s own professional development. The experience will also strengthen working relationships between OGE and the particular agency. Rotational assignments at OGE generally will be administered in the following way. Announcement Periodically, OGE will announce the availability of a temporary assignment on its staff through the OGE list serve, the OGE website or other means. The announcement will describe the anticipated duties of the assignment and the office or offices where the assignment will be located. Assignments may be in any of the three divisions of the Office of Agency Programs, Office of General Counsel & Legal Policy, or the Office of Government Relations & Special Projects. The announcement will indicate the duration of the particular assignment, which in any event will not exceed 120 days unless special arrangements are made, and will state generally the time period in which the assignment will occur. Agency nomination of candidates Interested agencies may submit the names of agency employees who currently serve in a permanent position that has full- or part-time ethics program duties as candidates for the assignment. It is not necessary that the candidate hold a full-time position at the employing agency. Nominations must be submitted by an appropriate agency official. Usually, this will be the Designated Agency Ethics Official (DAEO) or the Alternate DAEO. Interested agency employees may not apply directly for an assignment. Agencies may submit the names of any employee who works in their ethics program, including employees located at regional offices. In such cases, however, the agency is responsible for any temporary lodging, travel, per diem or related expenses incurred. Agencies will, of course, follow their own procedures and utilize their own criteria for identifying and selecting candidates. Agencies, however, are expected to nominate high performers with a demonstrated commitment to the ethics program. Agencies nominate a candidate by submitting a letter of nomination directly to the head of the OGE office where the assignment will be located. There is no particular format to follow in the letter but it may address such factors as the experience and qualifications of the nominee, the value of the assignment in terms of the nominee’s professional development and agency ethics program needs, any accomplishments of the nominee, and any other information supporting the nomination. Selection and notification The head of the OGE office where the assignment will be located will conduct interviews of candidates, where appropriate, and will make the selection decision. The head of the OGE office also will provide an informal notification to the agency of the selection decision. Formalities and processing A written notification to the agency and the selected candidate will be sent by OGE’s Administration Division. The Administration Division will be responsible for handling the personnel aspects of the assignment from OGE’s perspective. Prior to the agency employee commencing the assignment, the agency and OGE will complete a memorandum of agreement governing the assignment as discussed below. AGENCY ASSIGNMENTS FOR OGE EMPLOYEES A rotational assignment on the ethics staff of an agency will enable an OGE employee to gain a better understanding of the day-to-day management of an agency ethics program. It will provide first-hand experience grounded in the concrete circumstances of a specific agency of the challenges and demands of conducting ethics training, providing and memorializing ethics advice, and working directly with financial disclosure filers. It will also provide an opportunity to experience different management systems and different organizational cultures and gain an greater appreciation for the relationship of the ethics program to a specific agency mission. OGE employees will bring back to their work at OGE a better understanding of the needs and outlook of agencies. The experience will also strengthen working relationships between the ethics staffs of OGE and the agency. The following are some suggestions for agencies that are interested in having an OGE employee participate in a rotational assignment at their agency. Availability of agency assignments Depending on the type of assignment that is available, agencies should contact the General Counsel or a Deputy Director of OGE to let them know when a rotational assignment is available in their agency. OGE managers may also inquire from time to time regarding the availability of an assignment at an agency. OGE selection process OGE will carefully evaluate the training, experience, accomplishments and performance of members of the OGE staff who are interested in an agency assignment. OGE will select and forward for agency consideration only those candidates who are strong performers at OGE. Agency decision The decision to accept an OGE employee candidate to participate in an agency assignment is, of course, completely within the discretion of the agency. An agency should notify the head of the office at OGE that will be providing the OGE employee of its decision. MEMORANDUM OF AGREEMENT The rotational assignment, whether at OGE or at an agency, should be governed by a written agreement. The specific terms for any particular assignment would be determined by the mutual agreement of OGE and the agency. However, it is expected that the agreement would provide for the following: * a description of the work or project involved in the assignment; * the objectives of the assignment and how those objectives will be achieved; * the specific location and duration of the assignment; * the name of the person who will supervise the participating employee; * the arrangement for payment of the salary and benefits of the participating employee; * the arrangement for payment of travel, per diem and other related expenses for temporary duty travel during the assignment; * the arrangement for approval of annual leave and sick leave; * the arrangement for various contingencies such as termination or extension of the assignment; * the arrangement to provide for an interim assessment of the participating employee’s work and to provide an evaluation of the rotational assignment program. Generally, it is expected that the assignments will be non-reimbursable details with the employing agency continuing to pay the salary and benefits of a participating employee, including applicable travel expenses. However, it is expected that the cost of any temporary duty travel related to host agency work activities would be paid by the host agency. ASSESSMENT AND EVALUATION The host agency would be expected to provide an interim assessment of the work performed by the participating employee during the assignment. OGE will provide such an assessment of the work of agency employees who come to OGE. OGE will also request that both the agency and the participating employee provide an evaluation of the rotational assignment program, discussing its strengths and weaknesses and recommending any improvements to the program. ONE-YEAR PILOT PROGRAM OGE received a favorable response to the proposal for rotational assignments that it presented to a group of ethics officials. OGE is now proceeding to implement this program as a one-year pilot program in order to further evaluate the level of interest and make any improvements in the program. A number of agencies have already expressed an interest in participating in the program. Now that the program is available, agencies are invited to contact OGE with expressions of interest. During this one-year pilot period the goal is to send at least 2 OGE staff members on agency assignments and to host at least 2 agency employees at OGE. Although this is a modest goal, we believe there are significant benefits that can be achieved from such rotational assignments. In addition to the benefits cited above, the Rotational Assignment Program can foster greater cohesiveness, communication, cooperation and integration of effort throughout the executive branch ethics program. Finally, although not a part of this pilot program, it is hoped that agencies would consider details of ethics staff between agencies in order to extend the benefits of sharing expertise more widely throughout the executive branch.