The Office of Government Ethics has issued guidance on requirements that apply when employees subject to filing public financial disclosure reports move to a different agency or from the executive branch to another branch of the government.
If an employee moves between covered positions before the filing deadline of May 15 and has not already filed an annual report, it says, “OGE suggests as a best practice that the receiving agency encourage the employee” to file the required annual report within 30 days of changing positions. For those who already have filed their report with their former agency, the receiving agency “should collect that annual report from the employee or the former agency” to review it for potential conflicts of interest in the new position.
Filers sometimes question whether they are required to file an annual report for their previous position when they already filed a report covering a similar time period for their new position, a legal advisory says. The answer, it says, is that employees who worked for more than 60 days in a calendar year in a position requiring the filing of public financial disclosure forms must file for one for that year “even if the employee changes agencies or branches.”
Those reports are to be filed with the agency where the employee is working at the time of filing, it adds.
The policies apply only to employees subject to filing public financial disclosures–using OGE Form 278–mainly those at higher levels and those whose duties come with a potential higher risk of conflicts of interest. Far more employees file disclosure forms that are kept confidential by their agencies.
