June 4, 1996
DO-96-029
MEMORANDUM
TO: Designated Agency Ethics Officials
FROM: Stephen D. Potts
Director
SUBJECT: Standardizing an Alternative to Annual Confidential
Financial Disclosure Reports
Last year, the Office of Government Ethics (OGE) authorized
the Department of Education to test an alternative to annual
confidential financial disclosure reports (SF 450s) for regular
employees who had submitted a previous report (see DAEOgram of
July 31, 1995). This experiment was a result of OGE's single-issue
audit and brown-bag lunches in 1994, which focused on how to
improve the confidential disclosure system. Filers at the
Department of Education who had no new items to report on any part
of the SF 450 since their last filing and no substantial change in
work responsibilities during the reporting period for themselves or
their spouse were permitted to sign a certificate in lieu of filing
a new SF 450 for the October 1995 filing cycle.
The Department of Education has reported to us in detail the
results of their test, which they assessed as quite successful.
Over half of their 1277 annual filers used this alternative
certificate, resulting in a high level of customer satisfaction,
fewer delinquent filings, easier and faster reviews, and no
apparent negative impact on conflict prevention. The Department of
Education's full report is attached.
The Office of Government Ethics must now decide whether to
extend to other executive branch agencies the option of using this
alternative to an annual SF 450 report (and the replacement OGE
Form 450), and if so, how to implement it. In making these
decisions, we solicit your responses to the attached questionnaire.
Please complete and return this survey to OGE by July 12, 1996.
This is your chance to help determine the format and usage for a
standard alternative certificate. We will review your responses
and may want to discuss them at an appropriate ethics forum, prior
to initiating any regulatory change. It is our hope that some
variation of the alternative certificate tested at the Department
of Education might become an option available throughout the
executive branch for the fall 1997 reporting cycle.
_____________________________________________________________________
OFFICE OF GOVERNMENT ETHICS (OGE)
Survey of Agency Ethics Officials (June 1996)
Certificate of No New Interests
in Lieu of Annual SF/OGE Form 450
After reviewing the Department of Education's report to
OGE on its test of a "certificate of no new interests" in
lieu of an annual SF/OGE Form 450, please respond to the
following nine questions and return this survey to OGE,
not later than July 12, 1996. OGE will then consider
whether and how to extend the use of this alternative to
other agencies. You may respond by mail to OGE at 1201
New York Avenue, NW., Suite 500, Washington, DC 20005-
3917, or by fax at 202-208-8037.
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1) Would an OGE-standardized certificate of no new interests be
suitable for use at your agency, in lieu of annual SF/OGE Form 450
reports for regular employees? (Consider, for example, whether a
sizeable number of your filers typically have few changes from year
to year, and whether your review process would be streamlined.)
____Yes ____No Comments:
2) Would you prefer a certificate that focuses on:
____ a) no new interests since the last SF/OGE Form 450; or
____ b) no change (no new interests and no interests divested or
terminated) since the last SF/OGE Form 450?
(Note that option "a" would permit a greater number of filers
to use the certificate.)
Comments:
3) For how many consecutive years should filers be permitted to
use the certificate before being required to file a new SF/OGE Form
450?
____1 year ____2 years ____3 years Other:
4) Determining for individual filers how many years they have used
the alternative certificate and thus when they must file a new
SF/OGE Form 450 could be administratively burdensome. Would you,
therefore, prefer a system that requires all filers to submit a new
SF/OGE Form 450 in a given year? For example, all might be
required to file an SF/OGE Form 450 in 1996, 1999, 2002, et cetera,
regardless of how recently they had filed a previous such report as
a new entrant or as an annual filer with new interests.
____Yes ____No Comments:
5) Do you anticipate an undue administrative burden in ensuring
that filers have access to their previous SF/OGE Form 450, for
examination prior to signing a certificate of no new interests?
____Yes ____No Comments:
6) Some agencies are currently using the OGE-produced electronic
program for completing the SF/OGE Form 450, which permits filers to
simply update their report each year with any changes, and which
highlights those changes for reviewers. If you are already using
or planning to use that system, would you still want the option of
a certificate of no new interests for filers who do not use
electronic software to complete their reports?
____Yes ____No Comments:
7) Do you foresee any drawbacks to using a certificate of no new
interests, either administratively or with respect to conflict
prevention?
____Yes ____No If yes, please describe:
8) Are there any other changes not mentioned above that you would
make to the format or usage of the alternative certificate that was
tested at the Department of Education?
____Yes ____No If yes, please describe:
9) As a separate matter, OGE is currently testing a similar
certification system at another agency for special Government
employees (SGEs) who serve more than one year on advisory
committees and therefore have to file SF/OGE Form 450s subsequent
to their initial report. Would a certification system for SGEs,
similar to the one that was tested at the Department of Education
for regular employees, be appropriate to your needs?
____Yes ____No ____Not applicable at this agency
Comments:
___________________________ _________________________
RESPONDING OFFICIAL DATE
(Printed name and title)
___________________________ _________________________
NAME OF AGENCY DAYTIME PHONE NUMBER