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 24, 1993 DO-93-034

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 1994


Attached for your information is the program plan of agency ethics reviews scheduled by the Office of Government Ethics (OGE) for calendar year 1994. We have also attached the audit guidelines used by OGE staff in performing these reviews. 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.

The plan lists reviews for 2 departments, 13 separate agencies within 7 departments, and 17 independent agencies. It also includes 15 regional offices and 17 military installations. We also will perform a single issue review in 10 agencies to analyze how agencies are making determinations as to what positions are required to file confidential financial disclosure statements. It appears that the number of positions being required to file under the new system has grown dramatically, when we expected fewer positions would have to file. We will report the results of this review to you and hopefully be able to give further guidance.

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, and the GSA travel reimbursement program. We will also examine what problems, if any, agencies are having in implementing their training plans. With proposed budget cuts a possibility for fiscal year 1995 for many agencies, we will emphasize in letters to agency heads the importance of maintaining the staffing and support for the ethics program.


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


We will attempt as much as possible to stick to this schedule. However, as past experience has shown, the schedule may slip due to problems that occur during reviews, staffing problems, or higher priority work within OGE. If for some reason reviews from the first quarter are cancelled, we will pull up agencies from later quarters and review them earlier than is in the plan.

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 the 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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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.

Attachments

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PROGRAM REVIEW SCHEDULE JANUARY - MARCH 1994


AUDIT MANAGER - IRVIN WILLIAMS

1. Internal Revenue Service (Treasury) --Include regional offices in New York and Philadelphia

2. Tennessee Valley Authority (Oak Ridge, TN)

3. Army Missile Command (Redstone Arsenal, Alabama)

4. Federal Deposit Insurance Corporation --Include Resolution Trust Corporation

5. Department of Health and Human Services

6. Hill Air Force Base (Clearfield, UT)



AUDIT MANAGER - GERALD CHAFFINCH

1. Federal Aviation Administration (Transportation) --Include regional offices in Kansas City, MO and Des Plaines, IL

2. Centers for Disease Control (Atlanta, GA)

3. U.S. Coast Guard (Transportation)

4. Air University Command (Maxwell AFB, AL)

5. Securities and Exchange Commission --Include regional offices in New York and Chicago

6. White Sands Missile Range (White Sands, NM)

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PROGRAM REVIEW SCHEDULE APRIL - JUNE 1994


AUDIT MANAGER - IRVIN WILLIAMS

1. Single Issue Audit: Agency Determinations as to Positions Required to File Confidential Financial Disclosure Reports

2. Defense Intelligence Agency

3. Patent and Trademark Office (Commerce)

4. Fort Huachuca (Sierra Vista, AZ)

5. Central Intelligence Agency

6. National Security Agency

7. Federal Bureau of Investigation (Justice) --Include field offices in Washington, DC and New York


AUDIT MANAGER - GERALD CHAFFINCH

1. Army / Air Force Exchange System (Dallas, TX)

2. Federal Election Commission

3. Department of State

4. National Defense University (Ft. McNair)

5. U.S. Information Agency

6. Consumer Product Safety Commission --Include regional offices in New York and Chicago

7. Puget Sound Naval Shipyard (Bremerton, WA)

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PROGRAM REVIEW SCHEDULE JULY - SEPTEMBER 1994


AUDIT MANAGER - IRVIN WILLIAMS

1. Peace Corps

2. Letterkenny Army Depot (Chambersburg, PA)

3. Robins Air Force Base (Warner Robins, GA)

4. Federal Energy Regulatory Commission (Energy)

5. Fort Detrick (Frederick, MD)

6. Rock Island Arsenal (Rock Island, IL)



AUDIT MANAGER - GERALD CHAFFINCH

1. Commodity Futures Trading Administration --Include regional offices in Chicago and Kansas City

2. Naval Air Station (Pensacola, FL)

3. National Oceanic and Atmospheric Administration (Commerce) --Include the regional office in Seattle

4. Navy Weapons Support Center (Crane, Indiana)

5. Federal Mediation and Conciliation Service

6. Railroad Retirement Board (Chicago, IL)

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PROGRAM REVIEW SCHEDULE OCTOBER - DECEMBER 1994


AUDIT MANAGER - IRVIN WILLIAMS

1. Federal Emergency Management Agency

2. U.S. Postal Service

3. Small Business Administration --Include regional offices in Dallas and Atlanta

4. Comptroller of the Currency (Treasury)

5. U.S. Army Engineering Center (Ft. Belvoir, VA)

6. Interstate Commerce Commission



AUDIT MANAGER - GERALD CHAFFINCH

1. Postal Rate Commission

2. Naval Investigative Service

3. Social Security Administration (HHS)

4. National Institutes of Health (HHS)

5. Fort Benning (Columbus, GA)

6. Fort Bragg (Fayetteville, NC)