OGE Explains Reviews of Financial Disclosures

With the annual deadline for filing confidential financial disclosures now having passed, the Office of Government Ethics has posted an explanation of what happens next.

Some 370,000 mid-level federal officials must file such reports (OGE Form 450) on first starting in their position and again by each February 15. Agencies identify which positions are subject to the requirement, most commonly involving duties related to contracting, procurement, grants, subsidies, licensing, and other activities that affect the interests of non-federal entities.

“Agency ethics officials first review the reports to make sure the filers have satisfied the technical disclosure requirements. They then review the reports for conflicts of interest with the duties of the filers’ positions … Some agencies, such as the Department of Defense, require an additional level of review by each filer’s supervisor. This approach enhances the review because the supervisor is intimately familiar with the filer’s assignments and can help the agency’s ethics office identify conflicts of interest,” said OGE.

OGE added that its own reviews of agency ethics programs “provide a quality control mechanism for the confidential financial disclosure process.” OGE examines aggregate data regarding filings to check whether agencies are collecting the data as required, and also samples reports to check whether agencies are reviewing them thoroughly.

If a financial conflict of interest is indicated, there are a number of potential solutions apart from taking an action against the employee. These include application of an exemption, a grant of an individual waiver, recusing the employee from involvement in a matter before the agency, or the employee divesting the conflicting property or placing it in a trust.