Benchmarking Your Agency: CY17 Annual Agency Ethics Program Questionnaire

CY17 Annual Agency Ethics Program Questionnaire: Benchmarking Your Agency August 30, 2018 Wendy Pond, Senior Desk Officer Office of Government Ethics

Agenda • Annual Questionnaire Background • How to Access the Individual Responses and the Summary Document • Individual Responses • Summary Document • Benchmarking Your Agency • Agency Practices • Compliance Rates • DAEOs • Ethics Staffing (Geographical Allocation) • Ethics Staffing (Ratios)

Background • The of the Ethics in Government Act of 1978, as amended, requires executive branch agencies to submit an annual report to OGE (5 U.S.C., app, section 402(e)(1)). • OGE regulations stipulate that the report is due to OGE on or before February 1 of each year and covers the previous calendar year (5 C.F.R. § 2638.207).

Accesswww.oge.gov

Access: Individual Responses

Access: Summary Document

Benchmarking: Agency Practices 16. Did the agency head meet with the ethics staff to discuss the strengths and weaknesses of the ethics program in 2017? Yes 88 (65%) No 48 (35%) 15. Describe one concrete action the head of your agency took in 2017 to support or strengthen the agency’s ethics program: Q15 Table.

Benchmarking: Agency Practices “[The agency head] recorded a video message for the mandatory live annual ethics training sessions… which was incorporated into a training video viewed by employees unable to attend the live training session. The…message to the workforce expressed the importance of maintaining an ethical culture” “The Director sends out the Ethics Office's quarterly newsletter.” “After [the agency’s] Executive Director received the OGE program inspection report, he took the time to call [OGE} to discuss it, which shows his investment of the quality of the Agency’s ethics program. He wrote to all of OGC to praise the ethics program and also discussed the positive results of the program inspection with the Agency’s senior executives.”

Benchmarking: Agency Practices “[The agency head] instructed agency ethics officials to use her own ethics inquiries to the ethics office as concrete examples so that staff understand that federal ethics rules apply to everyone and it is each employee's responsibility, no matter the level, to understand ethics parameters and reach out to agency ethics officials at any time with questions. As a result of this instruction, we include examples of the Chairman's own ethics inquiries as well as how she actively engages in the agency's ethics practice in our new employee ethics orientation and annual ethics training.’ “Announced at a staff meeting the importance of timely completing the confidential financial disclosure reports and encouraged all filers to please file their reports prior to the deadline for filing the reports.”

Benchmarking: Compliance Rates • 95% (522) of new Senate-confirmed Presidential appointees received their initial ethics briefing within the 15-day requirement (Q.32) • 91% of new employees received initial ethics training within the 3-month requirement (Q.24) • 96% of public and confidential financial disclosure filers received required annual ethics training (Q.34) • 91% of special Government employees serving on a board, commission, or committee received initial ethics training before or at the first meeting (Q.92)

Benchmarking: Compliance Rates

Benchmarking: DAEOs

Benchmarking: Ethics Staffing

Benchmarking: Ratios Example: The table below provides an example of an agency with 13 employees that performed ethics program duties in 2017. In this example, the agency has the equivalent of 5.8 full time ethics officials: (2 x .025) + (3 x .25) + (5 x .5) + (2 x .75) + (1x1) = 5.8

Benchmarking: Ratios • Remember: The ratio for each data point is just that, a ratio. • It is does not reflect the actual number of FTEs, 278s, or 450s.

Benchmarking: Ratios There is no “right” ratio. You have to contextualize the ratio. Financial Disclosure • Scope of potential conflicts for your agency • Complexity of your filers’ reports • Whether you use a simplified 450 report • Etc. Training • How useful your employees find the training • Etc. Advice and Counsel • Number of calls • Complexity of questions • Etc.

Ideas for Further Data Analysis? Please email me at wgpond@oge.gov

Benchmarking Your Agency: CY17 Annual Agency Ethics Program Questionnaire