Ethics Guidance

U.S. Office of Government Ethics
1201 New York Avenue, NW.
Suite 500
Washington, DC 20005

202.482.9300

USA.govE.govRegulations.gov
OGE Logo and Address:  U.S. Office of Government Ethics, 1201 New York Ave., NW, Suite 500, Washington, DC  20005-3917

November 29, 1994 DO-94-043

MEMORANDUM

TO: Designated Agency Ethics Officials, General Counsels and Inspectors General

FROM: Stephen D. Potts Director

SUBJECT: Program Plan of Agency Reviews for Calendar Year 1995


Attached for your information is the program plan of agency ethics reviews scheduled by the Office of Government Ethics (OGE) for calendar year 1995. This is to alert you to our objectives for this year, to the elements we will be reviewing, and to afford you the opportunity to meet with OGE staff to discuss this review before it occurs. It also allows you time to make revisions to your program prior to our review. The program plan may be of some assistance as you address budget issues within your agency.

Our focus this year will be on looking at how well new components of the program are being administered, including the standards of conduct, the confidential financial disclosure system, the GSA travel reimbursement program and issues relating to agency fund-raising practices. We will examine what problems, if any, agencies are having in implementing their training plans. We will also focus on separate gift-acceptance authorities given to agencies by various statutes.

We will attempt as much as possible to follow the schedule set forth in the attachment. However, as past experience has shown, the schedule may slip due to complex issues that occur during reviews, staffing problems, or higher priority work within OGE. If reviews from the first quarter are cancelled, we will pull up agencies from later quarters and review them earlier than anticipated. Several agencies that we were not able to review in 1994 are again included in this plan for 1995.

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Designated Agency Ethics Officials, General Counsels and Inspectors General Page 2


OGE also will perform two single issue reviews in 1995. The first review will examine the system by which agencies inform OGE of referrals to the Department of Justice of violations of the criminal conflict-of-interest statutes. As part of this review we will look at agency systems for taking administrative action when the Department of Justice declines prosecution on such cases. We will also perform a single issue review of the ethics agreement system for Presidential appointees confirmed by the Senate.

Our usual practice once a review has been completed is to send a report to the Designated Agency Ethics Official (DAEO) with recommendations for improving the program. We ask the DAEO to respond to our recommendations within 60 days as to the actions he or she has taken or plans to take. We also send a copy of the report to the agency head with a transmittal letter. In this letter we will highlight our major concerns about the program, if any, especially if we believe more support or staffing is needed for the program.

We do not routinely send our reports to Congress, although about twice a year a Congressional committee will ask for a copy of a report for an agency under its jurisdiction. These requests are granted and the agency DAEO is informed that we have received such a request. Past experience has shown that these requests normally are made a year or more after the review has been finished.

We do not send copies of our reports to the news media, nor issue press releases concerning the reports. Periodically we do release reports to the news media in response to Freedom of Information Act requests.

The agency DAEO will be contacted by phone approximately one month prior to our entrance into the agency. Should there be a serious reason as to why you cannot receive us at that time, please call Ed Pratt, Chief, Program Review Division, at (202) 523-5757, ext. 1115, to discuss rescheduling. Should you wish more information about the review process, or wish to discuss your agency's program prior to the review, please call the audit manager listed in the attached program plan who is responsible for your agency. Irvin Williams (ext. 1150) and Gerald Chaffinch (ext. 1157) may also be reached at the number listed above. Should you wish, they will schedule a time to meet with you to discuss our review procedures, our expectations, and any concerns you may have.

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Designated Agency Ethics Officials, General Counsels and Inspectors General Page 3


In the past we have found the review process to operate very smoothly. In many instances agencies use our report to get more support, staffing and funding for the ethics program. Please alert us to problems you may have in this regard, as such problems will be brought to the attention of the agency head.

We hope that this answers some of your questions concerning our program review process. Should you have any questions or need assistance other than that listed above, please call Jack Covaleski, Associate Director for Program Assistance and Review, at 202-523-5757, ext. 1120.


Attachment

_______________________________________________________________________

OFFICE OF GOVERNMENT ETHICS



1995 PROGRAM PLAN OF AGENCY REVIEWS _______________________________________________________________________


PROGRAM REVIEW SCHEDULE JANUARY - MARCH 1995


AUDIT MANAGER - IRVIN WILLIAMS

1. U.S Agency for International Development

2. Department of the Interior --Office of the Secretary --National Park Service --National Biological Survey

3. Reviews in the Chicago Region --Railroad Retirement Board --Rock Island Arsenal (Rock Island, IL)

4. Nuclear Waste Technical Review Board

5. Letterkenny Army Depot (Chambersburg, PA)





AUDIT MANAGER - GERALD CHAFFINCH

1. Department of State

2. Consumer Product Safety Commission --include New York and Chicago Regional Offices

3. On-Site Inspection Agency (DOD)

4. National Oceanic and Atmospheric Administration

5. Pearl Harbor Naval Shipyard (Honolulu, HI)


SINGLE ISSUE REVIEWS

1. Review to examine the system by which agencies inform OGE of referrals to the Department of Justice of violations of the criminal conflict-of-interest statutes. As part of this review we will look at agency systems for taking administrative action when the Department of Justice declines prosecution on such cases. (Review to be performed by the Program Review Division)

2. Review of the ethics agreement system for Presidential appointees confirmed by the Senate. (Review to be performed by the Program Assistance Division.)

_______________________________________________________________________ PROGRAM REVIEW SCHEDULE APRIL - JUNE 1995




AUDIT MANAGER - IRVIN WILLIAMS

1. Drug Enforcement Administration --Include one regional office to be named

2. Immigration and Naturalization Service --Include one regional office to be named

3. Navy Weapons Support Center (Crane, IN)

4. McClellan Air Force Base (Sacramento, CA)

5. Advisory Commission on Intergovernmental Relations

6. Appalachian Regional Commission





AUDIT MANAGER - GERALD CHAFFINCH

1. U.S. Enrichment Corporation

2. Federal Transit Administration (Transportation) --Include Denver Regional Office

3. Naval Resale and Services Support Office (New York)

4. Fort Benning (Columbus, GA)

5. Federal Trade Commission 6. Bureau of Labor Statistics (Labor) --Include Atlanta and Boston Regional Offices _______________________________________________________________________

PROGRAM REVIEW SCHEDULE JULY - SEPTEMBER 1995




AUDIT MANAGER - IRVIN WILLIAMS

1. Department of Commerce --Office of Technology Policy --National Institute of Standards and Technology

2. Trade and Development Agency

3. Office of Navajo and Hopi Indian Relocation (Flagstaff, AZ)

4. Joint Chiefs of Staff (including Joint Staff) (DOD)

5. National Security Agency

6. Naval Investigative Service





AUDIT MANAGER - GERALD CHAFFINCH

1. Office of the Comptroller of the Currency --Include Dallas Regional Office

2. Foreign Claims Settlement Commission (Justice)

3. Naval Air Station (Pensacola, FL)

4. Food and Consumer Service (Agriculture)

5. Fort Bragg (Fayetteville, NC)

6. Federal Mediation and Conciliation Service

_______________________________________________________________________

PROGRAM REVIEW SCHEDULE OCTOBER - DECEMBER 1995




AUDIT MANAGER - IRVIN WILLIAMS

1. St. Lawrence Seaway Development Corporation

2. Defense Base Closure Commission

3. Delaware River Basin Commission

4. Pennsylvania Avenue Development Corporation

5. Food Safety and Inspection Service (Agriculture)





AUDIT MANAGER - GERALD CHAFFINCH

1. Social Security Administration --include two regional offices to be named

2. Financial Management Service (Treasury)

3. Naval Weapons Center (China Lake, CA)

4. Board for International Broadcasting

5. Defense Legal Services Agency (DOD)