December 8, 1994
DO-94-046
MEMORANDUM
TO: Designated Agency Ethics Officials, General Counsels and
Inspectors General
FROM: Stephen D. Potts
Director
SUBJECT: Financial Disclosure Preparation Software
The Office of Government Ethics (OGE) recently held a brown
bag lunch with representatives from several agencies to discuss how
computer technology could be used to streamline the financial
disclosure filing and review process. We discussed the issue of
electronic filing, the current restriction on the development and
use of electronic versions of the SF 278 and SF 450 imposed under
the General Services Administration's (GSA's) Federal Information
Resources Management Regulation (FIRMR) Bulletin B-3, and the
possible development of a stand-alone computer program for
completing, editing and printing the financial disclosure forms.
As a result of this meeting, it was agreed, that while the
concept of electronic filing has certain appeal, on the practical
side, it is at this time beyond OGE's and most other agencies'
technological capabilities. One of the most notable problems
involves the issue of "electronic signatures" and the level of
administrative controls and security required to implement a
legally sufficient electronic filing process. Nonetheless, we will
revisit the idea at a later date.
We also agreed, and have already taken action, to ask GSA and
the Office of Management and Budget to lift the restriction on the
development and use of electronic versions of the SF 278 and
SF 450. Once the restriction is lifted, the burden will be upon
each department and agency, using one of these electronic
disclosure forms, to ensure the form meets the parameters set out
in GSA's FIRMR Bulletin B-3.
Finally, we also agreed to develop a stand-alone computer
program for preparing both the public and confidential financial
disclosure reports. The software program would be available free,
and would operate in a manner similar to the commercially available
"tax preparation" type programs. The program would be designed to
guide the filer through the form and the filing requirements,
ensuring that all appropriate questions are asked and that all
appropriate sections of the form are properly completed. Our
expectation is that once the form is completed and printed using
this program, the ethics official reviewing the form would be
relieved of the tedious task of checking the forms for technical
accuracy and completeness. We believe this should save reviewers
considerable time and effort in their review process.
As part of this software development effort, we are asking all
departments and agencies to check among their various offices, to
see if anyone has already started developing a financial disclosure
preparation program along the lines described above. Obviously, we
do not want to reinvent the wheel in this area, but would like to
build upon any efforts made to date. If you know of anyone who
either has done or is in the process of doing work in this area,
please provide their names and phone numbers to Jim Parle, Chief,
Office of Information Resources Management, at 202-523-5757, ext.
213.
Also, we would like to know if your department or agency has
any GS-334-12/13 Computer Specialists that would be willing to be
detailed to this Office on a reimbursable basis for a period not to
exceed one year. If so, we would like their names and phone
numbers as well.