U.S. OFFICE OF GOVERNMENT ETHICS

 

 

 

Fiscal Year 2008 

Performance Accountability Report 

Management Discussion and Analysis 

Annual Program Performance Report 

Management Assurances 

Audited Financial Statements

 

November 2008


INTRODUCTION 

The Office of Government Ethics (OGE) is a separate 

executive branch agency established under the Ethics in 

Government Act of 1978, as amended (5 U.S.C. app. 401). The 

Director is appointed by the President with the advice and 

consent of the Senate for a five-year term. 

The Office of Government Ethics is headquartered in 

Washington, D.C. Currently, OGE is authorized a staff of 

80 full-time equivalents. This discussion and analysis provides 

a brief overview of OGE’s mission, goals of its Strategic Plan, 

and highlights of its accomplishments in FY 2008. For detailed 

information about OGE, visit its website at www.usoge.gov.

SUMMARY OF OGE’S MISSION 

The Office of Government Ethics exercises leadership in the 

executive branch to prevent conflicts of interest on the part of 

Government employees and to resolve those conflicts of interest 

that do occur. In partnership with executive branch agencies 

and departments, OGE fosters high ethical standards for 

employees and strengthens the public’s confidence that the 

Government’s business is conducted with impartiality and 

integrity. The chief responsibilities of OGE are: 

• Developing, in consultation with the Attorney General and 

the Office of Personnel Management (OPM), rules and 

regulations to be promulgated by the President or the 

Director of the Office of Government Ethics (OGE’s 

Director) pertaining to standards of ethical conduct of 

executive branch officials, public and confidential 

financial disclosure of executive branch officials, 

executive agency ethics training programs, and the 

resolution of conflicts of interest; 

• Monitoring compliance with the executive branch financial 

disclosure requirements of the Ethics in Government Act of 

1978, as amended; 

• Providing ethics program assistance and information to 

executive branch agencies through a desk officer system; 

• Developing and delivering training courses and creating 

materials and training aids to be used by agencies in 

conducting training of Federal employees; 
• Conducting periodic reviews of the ethics programs of 

executive agencies; 

• Ordering corrective action on the part of agencies that 

OGE’s Director deems necessary, including orders to 

establish or modify an agency’s ethics program; 

• Providing guidance on and promoting understanding of 

ethical standards in executive agencies through an 

extensive program of Government ethics advice, education, 

and training; 

• Evaluating the effectiveness of the Ethics in Government 

Act, the conflict of interest laws, and other related 

statutes; 

• Recommending appropriate new legislation or amendments; and 

• Supporting U.S. international anti-corruption initiatives 

by providing technical assistance primarily concerning 

prevention programs. 

GOALS OF OGE’S STRATEGIC PLAN for FY 2007-2011 

To achieve its mission and ultimately its stated vision, OGE 

has established the following three strategic goals: 

• Strengthening the ethical culture within the executive 

branch; 

• Preventing conflicts of interest; and 

• Promoting good governance. 

2
Highlights of FY 2008 Accomplishments 

FY 2008 was the second year of OGE’s five-year Strategic 

Plan. In its FY 2007 budget submission, OGE announced it would 

undertake initiatives to support three main priorities in 

FY 2008 and FY 2009: (1) assisting in the transition to a new 

administration; (2), engaging agency leadership in developing 

and supporting an ethical culture; and (3) using technology to 

improve the delivery of ethics services, information, and 

materials. OGE made substantial progress during FY 2008 in all 

three areas. 

1. Prepared to assist in the transition to a new 

administration 

During FY 2008, OGE focused primarily on preparing to 

assist in the transition to a new administration. OGE worked 

vigorously to build internal capacity for its role in ensuring a 

smooth Presidential transition and to prepare agency ethics 

officials to face the challenges that the transition will 

present. OGE specifically prepared its staff and agency 

officials for the anticipated increase in public and 

confidential financial disclosure reports during the transition. 

To this end, OGE held a regional conference on financial 

disclosure attended by approximately 300 experienced ethics 

officials from over 70 agencies, finalized new rules on 

post-employment restrictions, issued additional guidance and 

resources for ethics officials on key transition-related topics, 

and provided training for reviewers of nominee financial 

disclosure reports. OGE also prepared to assist agencies with 

the myriad ethics issues that outgoing and incoming 

administration officials will face. In addition, OGE undertook 

a series of focused reviews to evaluate agencies’ processes and 

procedures for collecting, reviewing, and certifying financial 

disclosure reports. OGE completed comprehensive evaluations of 

the financial disclosure programs at nine agencies. 

2. Engaged agency leadership in developing and supporting an 

ethical culture 

 As part of OGE’s leadership initiative, OGE senior 

management met with numerous agency leaders during FY 2008. 

These meetings focused on ways to strengthen agencies’ ethical 

culture and served to raise the level of discourse relating to 

the importance of support from senior leadership for the ethics 

program. OGE developed a training program on ethical 

3
leadership specifically for agency leaders. OGE also developed 

and prepared ethics materials that can be provided to the many 

new appointees who enter the Government as part of the incoming 

administration in FY 2009. Also, as mentioned above, OGE 

undertook reviews of agency ethics programs that often included 

meetings with agency leadership and resulted in the development 

of model practices and recommendations that enhance the 

executive branchwide ethics program. 

3. Used technology to improve the delivery of ethics 

services, information and materials 

OGE increased its use of technology to deliver resources to 

ethics officials in FY 2008. For example, OGE supplied financial 

disclosure reviewers at executive branch agencies with an 

electronic compilation of new guidance on public financial 

disclosure requirements for complex financial instruments and 

posted the compilation on OGE’s website. OGE also used its 

electronic notification mailing system (ListServe) to distribute 

a manual that provides extensive guidance on drafting ethics 

agreements for Presidentially-appointed, Senate-confirmed 

nominees. This manual also is available electronically through 

OGE’s website. In addition, OGE used technology to improve the 

delivery of training in FY 2008. OGE delivered a web-based 

training seminar on financial disclosure, released a CD-ROM to 

augment financial disclosure training, developed video clips to 

enhance the classroom experience for ethics training, and 

delivered a series of electronic ethics crossword puzzles to 

help agencies enhance their ethics training. OGE also launched 

a new website during FY 2008. These mechanisms have allowed OGE 

to reach a wider audience in a cost-effective manner. Finally, 

to improve the effectiveness of its ethics policy and its 

assistance to agency ethics programs, OGE used new survey 

technologies to administer surveys to ethics officials. The 

survey results ensured that OGE focused on emerging issues and 

incorporated these issues into its training. The surveys also 

raised awareness of ways in which ethics officials could improve 

their ethics programs; for example by undertaking 

self-assessments, increasing leadership involvement, and 

leveraging resources. 

The successful planning and delivery of the 16th National 

Government Ethics Conference was another significant undertaking 

for OGE in FY 2008. The conference agenda provided a major 

opportunity to address OGE’s top priorities. The conference 

offered workshops that OGE organized in themed tracks, with an 

overall theme focused on the Presidential transition. Sessions 

4
covered topics such as reviewing nominee financial disclosure 

reports, seeking private sector employment, post-employment 

restrictions, and what ethics officials need to know about the 

transition process. Over 600 members of the ethics community 

attended, and OGE extended invitations to members of both 

candidates’ transition teams to raise their awareness of 

relevant ethics issues and to build relationships with the 

executive branch ethics community. 

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Annual Program Performance Report 

Office of Government Ethics for FY 2008 

FY 2008 Results

Strategic Goal One: Strengthening Ethical Culture Within the 

Executive Branch 

Objective 1.1: Improve the Effectiveness of Ethics Policy 

As part of OGE’s continual effort to review and update 

policy guidance for ethics officials, OGE published written 

materials, provided significant guidance to address key and 

emerging ethics issues, and provided assistance to Congress on 

legislative proposals. In FY 2008, OGE published 16 substantive 

legal memoranda and advisory opinions. These memoranda and 

opinions, which OGE distributed to agency ethics officials, are 

permanently available to the public on OGE’s website. The 

documents discuss issues such as the gift exception for widely 

attended gatherings, conflicts of interest when seeking 

employment, and a post-employment exception for senior and very 

senior employees who represent candidates and political 

entities. A number of other written materials provide guidance 

on numerous financial disclosure issues including the treatment 

of exchange-traded funds for the purposes of financial 

reporting, and the reporting of emerging and complex financial 

instruments such as hedge funds and discretionary trusts. One 

memorandum provides extensive guidance on the complex rules 

applicable to Federal employees who plan to write books related 

to their Government experience. Throughout the fiscal year, OGE 

also continued to use the OGE electronic notification mailing 

system (ListServe) to distribute substantive information and 

timely notices to over 2,700 members of the ethics community. 

Nearly all ethics officials responding to OGE's annual survey of 

ethics officials indicated that OGE guidance is useful and that 

OGE provides the guidance they need to do their jobs 

effectively. 

In FY 2008, OGE published a final rule promulgating 

expanded guidance explaining the scope and content of the 

post-employment restrictions of 18 U.S.C. § 207 and containing 

certain implementing procedures. Publication of this rulemaking 

represented a significant achievement for OGE. Following 

publication, OGE conducted training to familiarize ethics 

officials and other interested stakeholders with the guidance, 

including several presentations at OGE’s 16th National Government 

Ethics Conference. OGE also conducted more extensive internal 

6
training on 18 U.S.C. § 207 and the new regulations in order to 

prepare its desk officers and attorneys to answer questions they 

may receive from ethics officials throughout the executive 

branch. 

Contractor ethics continues to be an emerging issue in 

which OGE has been active for several years. In FY 2008, the 

issue of contractor ethics drew increased attention from the 

media, Federal regulators, and Congress. Ethical risks and 

issues continue to arise in this area because Federal employees 

are working in Federal buildings alongside an increasing number 

of contractor employees, yet these contractor employees are 

subject to different standards than those applicable to Federal 

employees. In January 2008, the Federal Acquisition Regulatory 

Council’s law team invited OGE to participate in the development 

of an advanced notice of proposed rulemaking (ANPR) on 

contractor employees’ personal conflicts of interest (FAR Case 

2007-017). OGE assisted in drafting the ANPR, submitted formal 

comments on the ANPR, and alerted the ethics community to the 

ANPR. In addition to this initiative, OGE participated in other 

related efforts to propose rules addressing the conduct of 

contractors. 

OGE addressed a wide range of audiences on the topic of 

Government contractor ethics. In FY 2008, OGE delivered a 

formal presentation to the National Procurement Fraud Task 

Force. At the 16th National Government Ethics Conference, OGE 

also delivered several formal presentations on this topic to 

officials in the executive branch ethics community. OGE made 

formal presentations to the National Institutes of Health’s 

ethics counselors, members of academia, Congressional staff, and 

a number of nonprofit organizations. Similarly, OGE advised and 

provided comments to the Government Accountability Office on its 

inquiries into ethics issues involving contractors at the 

Department of Defense. In addition, OGE published a booklet to 

provide guidance directly to executive branch employees who work 

with Government contractors. 

During FY 2008, OGE paid significant attention to a number 

of legislative proposals that would affect Federal ethics laws. 

OGE closely tracked the development of these proposals and 

provided technical assistance regarding the impact they would 

have on the existing executive branch ethics program. OGE also 

provided formal views on some proposals. OGE provided several 

briefings to Congressional staff on a range of topics including 

contractor ethics, conflicts of interest, the Presidential 

transition, and financial disclosure among other topics. 

7
Moreover, OGE responded to Congressional and OMB requests for 

comment on numerous draft bills, legislation, bill reports, and 

testimony. Specifically, OGE timely responded to over 100 OMB 

requests for review and comment in FY 2008, with OGE’s comments 

on direct ethics issues incorporated approximately 90 percent of 

the time. Also, in light of the impending Presidential 

transition, OGE developed and, on behalf of the administration, 

submitted to Congress proposed legislation that would streamline 

financial disclosure requirements under the Ethics in Government 

Act. Finally, OGE undertook efforts to build internal capacity 

for enhancing its legal and legislative review in the coming 

years. 

Performance Measures

OGE tracks its progress toward achieving its strategic 

goals through specific objectives assessed with reference to 

established performance measures. Baseline data for the 

majority of measures was established by merging statistical data 

from a variety of existing sources, including ethics training 

surveys, annual ethics program questionnaires, employee ethics 

surveys, and surveys of ethics officials. Certain performance 

targets for FY 2009 and thereafter have been modified as a 

result of surveys and OGE's experience in implementing the 

Strategic Plan. 

 OGE’s success in meeting its performance targets is shown 

below: 

Performance Measures: Objective 1.1 

Improve the Effectiveness of Ethics Policy 

Performance Targets – Projected 

FY Actual Results in bold 

Performance 

Measures 

Basel

ine 

FY 

2007 

FY 

2008 

FY 

2009 

FY 

2010 

FY 

2011 

Percent of ethics 

officials who rate 

OGE as responsive 

to emerging ethics 

program issues 

78% 80% 

81% 

80% 

84% 

80% 80% 80% 

Percent of ethics 

officials who rate 

guidance as useful 

94% 95% 

93%

95% 

93% 

95% 95% 95% 

8
Performance Measures: Objective 1.1 

Improve the Effectiveness of Ethics Policy 

Performance Targets – Projected 

FY Actual Results in bold 

Performance 

Measures 

Basel

ine 

FY 

2007 

FY 

2008 

FY 

2009 

FY 

2010 

FY 

2011 

Percent of ethics 

officials who say 

they receive the 

guidance they need 

to do their jobs 

effectively 

85% 85%

82%

85% 

88%

85% 90% 90% 

Objective 1.2: Enhance Assistance to and Oversight of Agency 

Ethics Programs 

OGE attorneys and desk officers answered more than 2,000 

complex legal and policy questions from agency ethics officials 

in FY 2008. Through this support to agencies, OGE ensured 

consistent application of the complex legal authorities that 

form the framework of ethics regulation in the Federal executive 

branch. OGE responded effectively to a high volume of calls 

from agency ethics officials regarding complex legal issues 

related to ethics authorities. The availability of this support 

consistently produced qualitative enhancements in agency ethics 

programs. 

OGE continued to use technology to enhance support of 

agency ethics programs. More than 90 percent of ethics 

officials used the OGE website in FY 2008, and OGE launched a 

redesigned website, www.usoge.gov, to streamline access to 

information. In addition, OGE shared guidance with agency 

ethics officials through ListServe announcements and electronic 

DAEOgrams. About 95 percent of ethics officials reported that 

these electronic notifications were effective means for 

disseminating ethics information. 

In FY 2008, OGE continued to focus not only on its own 

communications with agency ethics officials but also on the 

communications regarding ethical requirements that occur 

internal to agencies. To this end, OGE continued its efforts to 

raise the level of communication between the leadership of 

Federal agencies and the many officials throughout the executive 

branch who comprise the ethics community. OGE also continued 

its “Leadership Initiative” that focused on the critical role of 

9
high-level agency leadership in promoting an ethical culture 

within the Federal executive branch. Among other actions, OGE 

undertook the following measures in furtherance of this 

objective: 

• The OGE Director met with various high ranking officials at 

several departments and agencies. 

• OGE continued convening focus groups in FY 2008 to discuss 

its Leadership Initiative. 

• OGE instituted lunch-time forums to focus on emerging 

issues related to the upcoming Presidential transition and 

related agencies’ program management matters. 

• OGE conducted surveys regarding leadership prior to the 

16th National Government Ethics Conference, and OGE used 

those responses to facilitate its preparations for the 

conference in order to address issues that executive branch 

agencies identified as important. 

• OGE developed and provided agencies with suggestions for 

concrete actions that can be implemented at the leadership 

level to enhance agency ethics programs. These suggestions 

are posted on OGE’s website. 

• OGE integrated into its agency program review process the 

emphasis on leadership involvement in the ethics program. 

• Over the fiscal year, OGE also recorded approximately 

1,000,000 hits on its website, which is popular with both 

the ethics community and the general public. 

In preparation for the Presidential transition, OGE had 

preliminary contacts with representatives of both of the 

Presidential candidates’ transition teams to discuss relevant 

ethics requirements. OGE also reviewed and began preparing 

materials for the incoming administration to facilitate a smooth 

transition. In order to prepare agency ethics offices for the 

change in administrations, “Transition” was the theme of the 16th

National Government Ethics Conference, which OGE held from 

September 16, 2008, through September 19, 2008. Three of the 

seven thematic tracks for the conference focused specifically on 

transition issues. OGE also dedicated several sessions to 

teaching agency ethics officials how to counsel outgoing senior 

officials effectively while preparing to assist incoming PAS 

10
officials. Over 600 ethics officials participated in the 31⁄2-day 

conference, and more than half of all agencies or components of 

executive branch departments were represented. OGE distributed 

conference materials to participants on flash drives to ensure 

that these materials will continue to be available in electronic 

format. As a result, these conference materials will continue 

to serve as useful reference material long after the conference, 

and agencies can easily share them with employees and archive 

them for future use. 

OGE also provided assistance to agency officials on a 

variety of ethics issues in connection with executive branch 

ethics activities. For example, OGE prepared a “podcast” of the 

Senate-confirmed nominations process and video clips that 

provide scenarios for discussion during training sessions on 

ethics restrictions on seeking employment. In order to assist 

executive branch agencies in requesting Certificates of 

Divestiture, which allow employees to defer capital gains taxes 

on assets that the Government requires them to divest, OGE also 

issued a recommended format for requests. OGE distributed this 

recommended format to agency ethics officials and provided 

training on requests for Certificates of Divestiture in February 

2008. The format continues to be available electronically on 

OGE’s website. 

In addition to branchwide emerging issues, individual 

agencies face their own unique challenges that they seek to 

remedy through supplemental, agency-specific ethics rules that 

OGE reviews. In FY 2008, OGE continued to emphasize the 

availability and advantages of alternative financial disclosure 

procedures and assisted agencies in developing those alternative 

procedures where appropriate. OGE reviewed and approved 

requests to implement alternative financial disclosure 

procedures at four agencies, in order to advance OGE’s goal of 

promoting the efficient allocation of ethics program resources 

and focusing resources on important program objectives. 

OGE also focused on succession planning, recognizing that 

effective succession planning will require thoughtfully directed 

action by OGE and the ethics community. In order to establish 

baseline information for targeting future action, OGE designed 

and distributed a special survey to agency ethics officials: 

the Ethics Program Succession Planning Survey. OGE also added a 

pertinent new section to the Annual Survey of Ethics Officials 

covering FY 2008. The groundwork for further work and training 

on a range of substantive topics relating to succession planning 

was established in several courses presented during the 16th

11
National Government Ethics Conference. These efforts and others 

will culminate in a succession planning initiative in FY 2010. 

Performance Measures

OGE’s success in meeting its performance targets is shown 

below: 

Objective 1.2

Enhance Assistance and Oversight 

Performance Targets – Projected 

FY Actual Results in bold 

Performance 

Measures 

Baseline FY 

2007 

FY 

2008 

FY 

2009 

FY 

2010 

FY 

2011 

Percent of ethics 

officials who are 

satisfied with 

education and 

training provided 

by OGE to support 

ethics officials 

64% 70%

72% 

75% 

73% 

80% 80% 80% 

Percent of ethics 

officials who view 

OGE’s program 

review process as 

adding value to 

their own 

programs* 

 

65% 75% 

57%* 

 

85% 

93% 

 

90% 

 

90% 

 

90% 

Percent of 

agencies that 

conduct internal 

reviews or audits 

to evaluate their 

program’s 

compliance with 

applicable ethics 

laws and 

regulations 

59% 60%

60% 

65% 

61%

65% 70% 75% 

12
Objective 1.2

Enhance Assistance and Oversight 

Performance Targets – Projected 

FY Actual Results in bold 

Performance 

Measures 

Baseline FY 

2007 

FY 

2008 

FY 

2009 

FY 

2010 

FY 

2011 

Percent of 

agencies that use 

self-assessment 

surveys to 

evaluate employee 

perceptions of 

their agency’s 

ethics program and 

ethical culture 

24% 25% 

28% 

30% 

40%

40% 40% 50% 

Percent of ethics 

officials who are 

satisfied with 

information shared 

on ethics program 

model practices 

 

55% 65% 

63% 

70% 

67%

75% 

 

80% 

 

80% 

* Analysis of the survey data used to track this metric for FY 

2007 suggests that the information used may not have been an 

accurate measure. Of those respondents stating an opinion for 

FY 2008, 93 percent believed that the program review process 

added value. 

Objective 1.3: Increase Employees’ Awareness of Their Ethics 

Responsibilities 

Consistent with OGE’s preparation for the Presidential 

transition in FY 2009, OGE developed training and written 

guidance on topics related to the transition. Specifically, OGE 

held numerous training sessions and discussion groups for 

executive branch employees and for the ethics officials who 

provide advice to departing employees. OGE issued a pamphlet on 

the qualified blind trust program and a pamphlet for employees 

who work with Government contractors. OGE completed the first 

draft of a revised post-employment training course that includes 

information about the new post-employment regulation. OGE also 

completed the first draft of a revised course on ethics 

requirements related to seeking employment. In addition, OGE 

issued an updated version of a pamphlet titled, “Rules for the 

Road,” that provides summaries of 18 U.S.C. § 207, 18 U.S.C. 

13
§ 203, and the Procurement Integrity Act, and alerts employees 

to other post-employment restrictions; and an updated version of 

a pamphlet titled, “Understanding the Revolving Door: How 

Ethics Rules Apply to Your Job Seeking and Post-Government 

Employment Activities,” which provides a general discussion 

about how the Federal ethics laws and restrictions may affect 

departing employees, both while looking for a job and after 

leaving the Government. These last two pamphlets summarize the 

most common post-employment restrictions on what employees can 

do after they leave Government service. They contain revisions 

that reflect, among other things, a recent statutory change to 

18 U.S.C. § 207(d) that increased the cooling off period for 

“very senior” employees from one year to two years. 

Many employees serve the Government as special Government 

employees (SGE) or as Federal advisory committee members. For 

this reason, OGE continued its assistance to advisory committees 

in FY 2008. To assist these employees in understanding their 

ethical obligations, OGE did the following: 

• published a pamphlet titled, “To Serve with Honor”; 

• published a longer booklet on the ethics rules that apply 

to advisory committee members serving as special Government 

employees; 

• completed two FACA training courses for GSA and continued 

to coordinate with the General Services Administration on 

advisory committee matters; 

• evaluated agency processes for determining SGE status 

during the OGE program review process; and 

• provided significant feedback on proposed legislation to 

revise the Federal Advisory Committee Act during FY 2008. 

OGE continued to develop a suite of training courses, 

materials, and evaluation instruments for agencies to use in 

training their employees and in assessing the effectiveness of 

such training. In FY 2008, over 80 percent of agencies used 

OGE-provided education and training products to promote employee 

awareness of ethics responsibilities. During FY 2008, OGE: 

• developed a course titled, “Are You Vulnerable to 

Conflicts?” that addresses conflicts of interest and 

appearance concerns; 

14
• continued to distribute the first course of the series 

titled, “Initial Ethics Orientation,” which OGE has 

provided to approximately 100 requesters; 

• delivered training at the 16th National Government Ethics 

Conference to demonstrate ways to deliver initial ethics 

orientation to employees; and 

• created new and updated materials (such as job aides, 

bookmarks, and posters) to assist agencies in increasing 

employee awareness of ethics requirements, using materials 

that OGE designed in ways that enable mass production by 

ethics officials for direct distribution to their agencies’ 

employees. 

Notably, OGE continued to develop a wide variety of instructorled training courses for ethics officials. After attending 

OGE-conducted training in FY 2008, all participants reported 

that their knowledge of ethics rules had increased. 

OGE also expanded its use of educational posters to 

increase awareness among agency employees. The posters focus on 

the primary principles of ethical conduct. They are available 

to agencies in an electronic format that allows customization of 

information about agency ethics contact points. OGE received 

numerous requests from agencies seeking customized versions of 

the posters. In addition, OGE continued to develop and 

distribute a series of online ethics crossword puzzles available 

through the OGE website. 

Performance Measures

 OGE’s success in meeting its performance targets is shown 

below: 

Objective 1.3 

Increase Employee Awareness and Understanding

Performance Targets – Projected 

FY Actual Results in bold 

Performance Measures 

Baseline FY 

2007 

FY 

2008 

FY 

2009 

FY 

2010 

FY 

2011 

Percent of agencies 

that incorporate OGE 

education and 

training products 

into their program 

66% 70% 

72% 

75% 

76% 

80% 85% 90% 

15
Objective 1.3 

Increase Employee Awareness and Understanding

Performance Targets – Projected 

FY Actual Results in bold 

Performance Measures 

Baseline FY 

2007 

FY 

2008 

FY 

2009 

FY 

2010 

FY 

2011 

Percent of 

participants whose 

knowledge of the 

ethics rules 

increased after 

participating in OGE 

conducted training 

87% 90% 

100% 

90% 

100%

100% 100% 100% 

Percent of ethics 

officials who are 

satisfied with 

employee education 

and training 

products provided by 

OGE 

44% 55% 

57% 

60% 

65%

70% 75% 80% 

Percent of employees 

who indicate they 

are familiar with 

ethics rules 

52% 60% 

59% 

70% 

N/A* 

70% 

* 

80% 

* 

80% 

* 

Percent of employees 

who indicate that 

they recognize 

ethics issues when 

they arise 

59% 65% 

66% 

70% 

N/A*

75% 

* 

80% 

* 

80% 

* 

Percent of employees 

who believe that if 

ethics concerns are 

reported to the 

agency, action is 

taken to resolve 

them 

51% 55% 

56% 

65% 

N/A*

70% 

* 

75% 

* 

75% 

* 

16
Objective 1.3 

Increase Employee Awareness and Understanding

Performance Targets – Projected 

FY Actual Results in bold 

Performance Measures 

Baseline FY 

2007 

FY 

2008 

FY 

2009 

FY 

2010 

FY 

2011 

Percent of employees 

who believe that 

employees who are 

caught violating 

ethics rules are 

disciplined 

42% 45% 

50% 

45% 

N/A*

50% 

* 

55% 

* 

60% 

* 

Percent of agencies 

that incorporate 

OGE-provided 

education and 

training products to 

promote employee 

awareness of their 

ethics 

responsibilities 82%* 

80% 80% 80% 

Percent of agencies 

that are satisfied 

with OGE-provided 

education and 

training products 

designed to promote 

employee awareness 

of their ethics 

responsibilities 79%* 

80% 80% 80% 

* Note: Two new measures have been added for FY 2008 to 

measure Objective 1.3. In previous years, OGE obtained data 

related to employee awareness and understanding metrics from 

employee surveys that it conducted in agencies, and OGE met all 

objectives. Funding for employee surveys was not available in 

FY 2008. OGE has encouraged agencies to conduct self-assessment 

surveys. 

Objective 1.4: Increase OGE’s Focus on Senior Officials’ Roles 

in Implementing Ethics Program 

OGE’s Leadership Initiative provides the leaders of 

executive branch agencies with suggestions for concrete actions 

that they can implement in order to fulfill their ethics 

responsibilities. Leadership support is a critical component of 

17
a successful agency ethics program. OGE is committed to raising 

the level of communication between the leadership of executive 

branch agencies and the ethics community. In FY 2008, OGE 

emphasized that commitment and action by agency leadership is 

the keystone for ensuring the integrity of an agency’s ethical 

culture and for fostering public confidence in the Government’s 

decision-making processes. To carry this message to the 

executive branch’s leadership in FY 2008, OGE delivered 

presentations on ethical leadership and building ethics into the 

culture that reached approximately 600 mid- and high-level 

managers. To further OGE’s commitment to this message, OGE 

senior officials met with the leadership from several agencies 

in connection with ethics program reviews in FY 2008. In 

addition, OGE’s Director personally met with a number of agency 

heads and other high-level agency officials to discuss ways that 

they could strengthen the existing ethical cultures of their 

agencies. Several presentations at the 16th National Government 

Ethics Conference also focused on teaching ethics officials 

skills for engaging their own agency leadership in this 

initiative. Over 90 percent of ethics officials believed that 

their agency's leaders paid attention to ethics and demonstrated 

support for the ethics program in FY 2008. 

Performance Measures

OGE’s success in meeting its performance targets is shown 

below: 

Objective 1.4 

Promote Agency Leadership

 Performance Targets – Projected 

FY Actual Results in bold

Performance 

Measures 

Baseline FY 

2007 

FY 

2008 

FY 

2009 

FY 

2010 

FY 

2011 

Percent of 

employees who 

believe their 

agency leaders 

pay attention 

to ethics 

64% 65% 

69% 

70% 

N/A* 

75% 

*

75% 

*

80% 

*

Percent of 

employees who 

believe their 

immediate 

supervisors pay 

attention to 

ethics 

75% 75% 

80% 

75% 

N/A*

80% 

*

80% 

*

80% 

*

18
Objective 1.4 

Promote Agency Leadership

 Performance Targets – Projected 

FY Actual Results in bold

Performance 

Measures 

Baseline FY 

2007 

FY 

2008 

FY 

2009 

FY 

2010 

FY 

2011 

Percent of 

ethics 

officials who 

indicate that 

their agency's 

leaders pay 

attention to 

ethics 92%* 

90% 90% 90% 

Percent of 

ethics 

officials who 

indicate that 

their agency's 

leadership 

demonstrates 

support for the 

ethics program 

92%* 

90% 90% 90% 

* Note: Two new measures have been added for FY 2008 to measure 

Objective 1.4. In previous years, OGE obtained data related to 

employee awareness and understanding metrics from employee 

surveys that it conducted in agencies, and OGE met all 

objectives. Funding for employee surveys was not available in 

FY 2008. OGE has encouraged agencies to conduct self-assessment 

surveys. 

Strategic Goal Two: Preventing Conflicts of Interest 

Objective 2.1: Enhance Assistance to the President and the 

Congress in the Presidential Appointment Process 

OGE took proactive measures to enhance its assistance 

during the upcoming Presidential transition. During the 

Presidential transition, OGE anticipates the turnover of most of 

the 1,100 to 1,200 Presidentially-appointed, Senate-confirmed 

(PAS) positions in the executive branch. To prepare for the 

anticipated increase in the volume of PAS nominee reports and 

termination reports that OGE will receive during the transition, 

OGE undertook the following specific measures: 

19
 

• OGE’s 16th National Government Ethics Conference in 

September 2008 focused primarily on transition-related 

matters such as post-employment restrictions, seeking 

private sector employment, writing and publication of 

books, and disqualification issues. Several presentations 

at the conference addressed both technical disclosure 

issues and substantive conflicts issues related to nominee 

financial disclosure. In addition to the usual attendees, 

who numbered over 600, OGE invited key members of the 

campaign staffs of the two major party Presidential 

candidates in order to acclimate their transition teams to 

ethics and disclosure requirements and to establish liaison 

relationships with OGE staff as early in the transition 

process as possible. 

• OGE prepared briefings for transition teams on ethics and 

financial disclosure as well as other transition-specific 

topics, and arranged meetings with the staffs of each of 

the major campaigns before the election. 

• OGE conducted additional training for new financial 

disclosure reviewers in Washington, D.C. OGE also 

developed and distributed an electronic compilation of 

OGE’s financial disclosure guidance and documents to 

individuals who attended financial disclosure training. 

This post-training CD-ROM provided students with a 

comprehensive reference guide and a series of audio files, 

recorded by OGE experts. The audio files addressed complex 

financial disclosure issues and “grey areas” that reviewers 

will typically face during the transition period. 

• On February 28, 2008, OGE presented a Regional Conference 

for ethics officials from over 70 departments and agencies 

on financial disclosure issues related to PAS nominees in 

order to help prepare individual ethics officials for the 

increased number and complexity of financial disclosure 

reports that are expected during transition. The 

conference focused on advanced technical disclosure and 

substantive conflicts issues specific to PAS individuals. 

Approximately 300 experienced attorneys and ethics 

officials registered for the conference, and feedback from 

these attendees indicated that the result was an increase 

in their expertise in addressing financial disclosure 

requirements. 

20
• In connection with the February 2008 Regional Conference, 

OGE distributed a bound volume containing 258 pages of 

instructional material and contact information designed to 

prepare executive branch ethics officials for the 

anticipated increase in the volume of nominee and 

termination financial disclosure reports associated with 

the Presidential transition. Nearly all of the material in 

this volume was new material that OGE developed 

specifically for this purpose. 

• OGE supplied financial disclosure reviewers at executive 

branch agencies with an electronic compilation of new 

guidance on public financial disclosure requirements for 

complex financial instruments. This compilation 

supplements OGE’s “Financial Disclosure: A Reviewer’s 

Reference” manual and is posted on OGE’s website. 

• OGE issued a written manual that provides extensive 

guidance on drafting ethics agreements for PAS nominees. 

OGE distributed this manual both at its February 2008 

Regional Conference on public financial disclosure and 

through the electronic notification mailing system 

(ListServe), to which over 2,700 executive branch ethics 

officials are subscribed. OGE also made this manual 

available to both agency ethics officials and the general 

public by posting it on OGE’s website. 

• OGE continued to expand its pool of public financial 

disclosure report reviewers and continued to encourage 

other executive branch ethics programs to expand their 

pools as well. To assist one major department with its 

capacity-building effort, OGE allowed the department to 

detail a nominee report reviewer to OGE. During the 

detail, OGE provided both formal training and on-the-job 

training to the department’s employee. OGE has offered 

similar opportunities to other departments and agencies. 

• OGE’s Director testified at a hearing before a Senate 

subcommittee regarding OGE’s role in, and preparations for, 

the Presidential transition. Officials of the Office of 

Management and Budget in the Executive Office of the 

President and the General Services Administration also 

testified at the hearing. 

• OGE expedited the Certificate of Divestiture request 

process by issuing a new sample format for requests. This 

21
format will assist with the increased volume of requests 

that OGE expects to receive during the Presidential 

transition. 

• OGE obtained the administration’s approval for draft 

legislation to streamline the financial disclosure process 

and submitted the draft legislation to Congress. 

• OGE published comprehensive post-Federal employment ethics 

regulations and conducted training on these regulations. 

• OGE published several new pamphlets on substantive ethics 

requirements. 

• OGE began the development of a video for potential PAS 

nominees that explains the reasons for the financial 

disclosure requirements, as well as the essential nature of 

early and strong involvement by nominees in ethical 

leadership. 

• OGE issued a memorandum on the heightened scrutiny of PAS 

nominee reports and the need for agencies’ ethics officials 

to seek additional information, rather than relying on 

standard review assumptions, when reviewing PAS nominee 

reports. 

In conjunction with the foregoing efforts to prepare for 

the Presidential transition, OGE began conducting a series of 

focused reviews to evaluate agencies’ processes and procedures 

for collecting, reviewing, and certifying financial disclosure 

reports, including those filed by PAS nominees. While 

evaluating agencies’ financial disclosure processes and 

procedures is a routine part of OGE's plenary reviews, 

conducting the focused reviews allows OGE to evaluate a larger 

number of agencies in a shorter period of time. In order to 

identify areas for improvement before the transition, OGE 

designed components of the reviews, as follows: 

• The reviews consist of two parts, including both a 

questionnaire to be completed electronically and on-site 

follow-up interviews by OGE reviewers. 

• The reviews focus on internal controls. 

• The reviews underscore the importance of ensuring accuracy, 

consistency, and timeliness in the processing of PAS 

22
nominee reports in anticipation of the Presidential 

transition. 

• Part of each focused review includes an emphasis on the 

need for agencies to develop and maintain follow-up 

procedures for pursuing the collection of the reports of 

delinquent filers. 

In connection with these focused reviews, OGE completed 

comprehensive evaluations of the financial disclosure programs 

at nine agencies. OGE used the information gathered through 

these reviews to develop model practices and recommendations 

that will enhance the executive branch ethics program. 

OGE continued in FY 2008 to provide agency ethics officials 

with guidance and instruction that will improve their review of 

public financial disclosure reports. In the course of reviewing 

nominee reports in FY 2008, OGE closely scrutinized the work of 

agency ethics officials and met internally to discuss the issues 

that were arising in the course of these reviews. OGE’s 

financial disclosure team and program reviewers also worked 

directly with agency reviewers in connection with the report of 

each PAS nominee. During these interactions, OGE staff provided 

agency ethics officials with assistance in reviewing the 

individual financial disclosure reports. This assistance 

included substantive guidance regarding the broadly applicable 

financial disclosure requirements and conflicts of interest 

issues that those reports implicated. As a result, these 

exchanges facilitated the nominations of numerous candidates for 

PAS appointments and increased the level of expertise of the 

community of agency ethics officials who reviewed their reports. 

Notably, 95 percent of conflict and technical reporting issues 

for nominee financial disclosure reports were resolved within 

five days after a nomination was made. 

During FY 2008, OGE reviewed and certified 254 financial 

disclosure reports filed by PAS nominees. In addition, OGE 

increased its focus on the ethics agreements of PAS nominees, 

working closely with ethics officials to provide extensive 

guidance on such agreements in order to resolve potential 

conflicts of interest and concerns about appearances of 

conflicts of interest. Heightened scrutiny of the quality of 

these ethics agreements resulted in better outcomes with regard 

to resolving conflicts prospectively. In order to build the 

skills of agency ethics officials, OGE contacted agency ethics 

officials directly to explain and negotiate changes to their 

nominees’ ethics agreements. OGE also enhanced its service by 

23
working directly with PAS nominees and their representatives in 

many cases in order to expedite the processing of reports when 

agency ethics officials were unable to resolve disclosure and 

conflicts issues quickly. In addition, OGE continued to monitor 

compliance with the ethics agreements of PAS officials following 

their confirmations; 97 percent of PAS officials complied with 

the agreements within required time frames. 

 

As there continues to be significant agency interest in 

electronic filing of financial disclosure forms, OGE decided in 

FY 2007 to allow each agency to undertake its own development of 

an electronic filing process to use with either the public 

reporting system (Standard Form 278) or the confidential 

reporting system (OGE Form 450). In FY 2008, OGE continued to 

support agency e-filing efforts in the following ways: 

• OGE participated in an interagency e-filing working group 

called the “Electronic Filing Workgroup,” which promotes 

the development and advancement of executive branchwide 

electronic financial disclosure report filing. OGE also 

facilitated a presentation by this group at the 16th

National Government Ethics Conference in September 2008. 

In addition to the panel presentation, OGE organized a 

one-day e-filing workshop where participants saw three live 

demonstrations of existing electronic filing systems. 

 

• As a member of the e-filing workgroup of the Interagency 

Ethics Council (IEC), OGE assisted in the development of a 

document titled, “eFiling Roadmap & Planning Workbook: 

Electronically File (eFile) & Manage Financial Disclosure 

Reports (FDRs).” Once completed, this document will serve 

as a guide for ethics officials seeking to implement an 

electronic process for the filing of financial disclosure 

reports (Standard Form 278 and OGE Form 450) in their 

agencies. The roadmap details ways to decide on and deploy 

an e-filing solution based on the experiences of several 

agencies. The workgroup will finalize this document in FY 

2009. 

• OGE met with several agencies that are in the process of 

developing e-filing systems, including the National 

Aeronautics and Space Administration, the Department of 

Veterans Affairs, the Executive Office of the United States 

Attorneys, the Department of Health and Human Services, the 

United States Postal Service, and the Federal Deposit 

Insurance Corporation. 

 

24
• OGE developed and distributed an e-filing survey to 129 

independent agencies and 46 major components. The survey 

provided OGE with specific information on the extent to 

which steps in each agency’s process can be completed 

electronically, and it helped OGE to fulfill its commitment 

to monitor the e-filing efforts of individual agencies. 

OGE enhanced the assistance it provides to the President 

and Congress by updating its regulations. Specifically, OGE 

submitted in FY 2007 a proposed regulation on qualified blind 

trusts and qualified diversified trusts to the Department of 

Justice (DOJ) and the Office of Personnel Management (OPM) for 

review. This proposed regulation revises existing regulations 

in order to clarify the processes for establishing such trust 

instruments. OGE received and responded to comments from DOJ 

and OPM in FY 2008. OGE hoped to submit the proposed regulation 

to the Office of Management and Budget (OMB) in FY 2008 and 

adopt a final regulation before the beginning of the 

Presidential transition, but was unable to submit the rule to 

OMB in FY 2008 because OMB imposed a moratorium on new rules 

that will remain in force through the end of the current 

administration. OGE will continue to pursue this initiative in 

FY 2009. Also in FY 2008, OGE began developing revised 

regulations dealing with exemptions to the conflicts of interest 

rules, but did not submit the regulations to OMB in FY 2008 due 

to the moratorium on new rules. 

In FY 2008, in conjunction with its nominee review process, 

OGE also continued its efforts to ensure that incumbent PAS 

appointees’ financial interests did not pose actual or apparent 

conflicts of interest with their current duties. OGE 

accomplished this effort by reviewing annual financial 

disclosure reports and termination reports that such officials 

submitted. OGE performed a conflicts analysis on 1,087 annual 

and termination public financial disclosure reports filed by 

these employees. OGE also worked with small boards and 

commissions to strengthen their substantive and technical 

reviews of financial disclosure reports. In addition, OGE 

provided instructor-led courses to ethics officials from various 

agencies on identifying and resolving conflicts of interest. 

25
Performance Measures

OGE’s success in meeting its performance targets is shown 

below: 

Objective 2.1 

Enhance Assistance to the President and the Congress 

Performance Targets – Projected 

FY Actual Results in bold 

Performance 

Measures 

Baseline FY 

2007 

FY 

2008 

FY 

2009 

FY 

2010 

FY 

2011 

Number of agencies 

using an 

electronic filing 

system 

 

2 

 

6 

4 

* 

9 

* * * 

Percent of 

officials who 

comply with ethics 

agreements within 

required time 

frames 

95% 95% 

98% 

95% 

97% 

95% 95% 95% 

Resolves all 

conflicts and 

technical 

reporting issues 

for nominee 

financial 

disclosure reports 

no later than five 

days after a 

nomination is made 

90% 90% 

95%

90% 

95%

95% 95% 95% 

Objective 2.2: Monitor Continued Compliance With Conflict of 

Interest Laws 

Inspectors General provide critical support in the 

enforcement of ethics laws and rules because they usually 

conduct the primary investigations of alleged violations. OGE 

has sought opportunities to strengthen the relationship between 

the community of Inspectors General and the community of ethics 

officials, in an effort to help Inspectors General understand 

the application of the ethics requirements. OGE’s Director 

maintained consistent communication with the Inspectors General 

community through regular attendance at the meetings of the 

President’s Council on Integrity and Efficiency (PCIE) and the 

26
Executive Council on Integrity and Efficiency (ECIE). In 

FY 2008, OGE continued its effort to foster effective working 

relationships with the Inspectors General community. In 

addition to its meetings with Inspector General personnel, OGE 

provided educational support to the Inspectors General 

community, including the following: 

• OGE developed and conducted two formal training courses on 

investigating conflicts of interest during FY 2008 at the 

Inspector General Academy. 

• OGE staff presented training directly to the staffs of 

Inspectors General on five other occasions during FY 2008. 

On one of these occasions, OGE provided individualized 

training to the staff of the Department of Education’s 

Inspector General on reviewing financial disclosure 

reports. This training enabled the Inspector General’s 

staff to respond to an important Congressional inquiry 

regarding financial disclosure at the Department of 

Education. 

 

• At the 16th National Government Ethics Conference, OGE 

expanded its outreach to Inspectors General by inviting 

them to increase the number of their representatives at the 

conference. OGE also reached out to the Inspectors General 

community before the conference in order to ensure that the 

conference agenda included topics of interest to them. The 

Inspectors General community’s attendance and participation 

in the conference provided an opportunity for the staffs of 

Inspectors General to develop better working relationships 

with members of the ethics community. The collaboration 

between these communities also served to help develop 

strategies for assisting one another in carrying out their 

respective responsibilities. As a result, they identified 

common needs and ways to meet these responsibilities 

through future collaboration. 

OGE also continued to work directly with the Department of 

Justice and Inspectors General on enforcement of ethics 

requirements. OGE regularly provides assistance to prosecutors 

and investigators concerning the interpretation and application 

of the conflict of interest laws and ethics rules in the context 

of specific prosecutions and investigations. The subjects of 

these interactions included such matters as improper gifts, 

falsification of financial disclosure statements, financial 

conflicts of interest, and post-employment restrictions. In 

addition to these activities, OGE continued to collect and 

27
monitor concurrent notifications of conflict of interest 

referrals to the Department of Justice to identify trends. In 

FY 2008, OGE also developed an electronic process for receipt of 

concurrent notification of conflict of interest referrals to the 

Department of Justice. 

Also in FY 2008, OGE’s formal tracking systems effectively 

monitored the activities of executive branch agencies in 

connection with conflicts of interest laws, as follows: 

 

• OGE continued to maintain a monitoring system that ensures 

that PAS appointees file annual and termination financial 

disclosure reports as quickly as possible. In FY 2008, OGE 

achieved a 10% increase in the number of PAS reports that 

agencies timely filed with OGE for final review and 

certification. 

• OGE continued to monitor compliance of PAS appointees with 

their ethics agreements. In FY 2008, OGE found that 97% of 

all tracked PAS appointees met the regulatory requirement 

of complying with their agreements within applicable 

timelines. 

• As part of the standard program review process, OGE program 

reviewers routinely emphasized to agencies the importance 

of notifying public filers once their reports are reviewed 

and certified. All agency programs reviewed in FY 2008 

provide public financial disclosure report filers with 

feedback after their reports have been reviewed. In those 

cases where reports had not been certified or were 

certified late due to filing errors or inconsistencies, OGE 

program reviewers ensured that agency officials were making 

efforts to collect information or correct any deficiencies 

that were delaying certification. 

28
Performance Measures

OGE’s success in meeting its performance targets is shown 

below: 

Objective 2.2 

Monitoring Compliance with Conflict of Interest Laws 

Performance Targets – Projected 

FY Actual Results in bold 

Performance 

Measures 

Baseline FY 

2007 

FY 

2008 

FY 

2009 

FY 

2010 

FY 

2011 

Percent of 

audited 

entities that 

provide public 

financial 

disclosure 

report filers 

with feedback 

after their 

reports have 

been reviewed 

84% 85% 

100% 

90% 

100% 

90% 95% 95% 

Percent of 

audited 

entities that 

have written 

procedures for 

following up 

with delinquent 

filers 

49% 60% 

91% 

75% 

85% 

90% 90% 90% 

Objective 2.3: Administer an Effective Confidential Financial 

Disclosure System 

In FY 2008, OGE continued to emphasize the availability and 

advantages of alternative financial disclosure procedures and to 

assist agencies in developing alternative procedures where 

appropriate. All alternative financial disclosure systems 

reviewed in FY 2008 had been implemented effectively. In 

FY 2008 OGE also reviewed and approved requests to implement or 

update alternative financial disclosure procedures at the 

following four agencies: 

• Environmental Protection Agency; 

29
• National Aeronautics and Space Administration; 

• Department of Agriculture; and 

• Department of Veterans Affairs.

OGE also maintained a Frequently Asked Questions section for 

confidential financial disclosure reports on its website. 

Performance Measures

 OGE’s success in meeting its performance targets is shown 

below: 

Objective 2.3 

Improved Administration of Confidential System 

Performance Targets – Projected 

FY Actual Results in bold 

Performance 

Measures 

Baseline FY 

2007 

FY 

2008 

FY 

2009 

FY 

2010 

FY 2011

Percent of 

alternative 

systems judged 

by program 

review to have 

been 

effectively 

implemented 

60% 65% 

100% 

70% 

100%

80% 90% 90% 

Percent of 

required 

confidential 

filers who 

filed by end of 

reporting year 

70% * 75% 

TBD* 

75% 80% 80% 

* The pertinent regulation was amended in FY 2007. Because of 

the amendment, there were no results in FY 2007 and results for 

FY 2008 are not yet available. 

30
Strategic Goal Three: Promoting Good Governance 

Objective 3.1: Increase OGE’s Support of and Cooperation With 

Federal, State, and Local Agencies Implementing Programs That 

Help Support Good Governance 

In FY 2008, OGE engaged in a number of activities with 

Federal, State, and local agencies that promote integrity, 

accountability, and transparency in Government. At the Federal 

level, OGE’s Director maintained consistent communication with 

the Inspectors General community through regular attendance at 

monthly meetings of the President’s Council on Integrity and 

Efficiency (PCIE) and the Executive Council on Integrity and 

Efficiency (ECIE). OGE’s Director continued to serve on the 

PCIE Integrity Committee and served as a presenter for the 

Inspector General Leadership Development Course. In addition, 

OGE developed and began presenting a course for the Inspector 

General Training Academy that will enhance the Academy’s 

training on investigating public corruption and ethics cases. 

OGE also maintained a consistent presence at the Federal 

Interagency Ethics Council, an informal group of executive 

branch ethics officials who meet monthly to share model 

practices and practical information. In particular, OGE made a 

significant presentation on the newly issued post-employment 

regulations. 

In continued support of the substantial number of Federal 

advisory committees, OGE staff participated in a multi-day 

curriculum development exercise held by the General Services 

Administration to improve training for Federal advisory 

committee management officers in departments and agencies. 

Transparency in government is fundamental to good 

governance. OGE provided team leadership in conjunction with 

the Department of Justice on a long-standing FOIA and 

Constitutional law claims suit. 

Exploring a new opportunity to reach a broader audience on 

subjects complementary to the ethics program, OGE participated 

in the development of a podcast that addressed the duty to 

report misconduct and identified the offices that can receive 

reports of misconduct. OGE developed this broadcast with a 

representative of the Office of Special Counsel’s Disclosure 

Unit and a representative of an Inspector General Hotline 

program. 

31
At the State and local level, OGE continued to be an active 

member of the Council on Governmental Ethics Laws (COGEL), an 

organization comprised of Federal, State, and local government 

agencies primarily from the United States and Canada, which are, 

in part, responsible for government ethics and access to 

information programs. In FY 2008, OGE utilized the newly 

revamped COGEL member forum to answer program inquiries from 

other members, and to pose its own questions concerning good 

practices. 

Throughout FY 2008, OGE coordinated extensively with other 

Federal agencies and, to some degree, with State, and local 

government agencies in conjunction with the United States’ 

obligations under international anti-corruption conventions and 

mutual evaluation mechanisms. In the more general area of 

programs within public administration that help support the 

prevention of corruption, as opposed to law enforcement, OGE 

took the lead within Federal working groups in gathering 

specific information on applicable laws, regulations, policies 

and practices of these agencies for those programs. For 

example, OGE worked cooperatively with Federal agencies to 

implement or report on implementation of recommendations made to 

the United States as the result of the first-round and 

second-round evaluations by the Council of Europe’s Group of 

States Against Corruption (GRECO) and the first-round evaluation 

by the follow-up mechanism for the Inter-American Convention 

Against Corruption (MESICIC). As a more general matter, OGE 

used the anti-corruption conventions and evaluation mechanisms 

as platforms for discussions of specific internationally 

recognized good governance and integrity issues. 

OGE’s participation and interaction with other Federal, 

State and local agencies on topics that build on the 

complementarity of a variety of programs within public 

administration was well received and also provided helpful 

insights to OGE as it evaluated its own programs. 

32
Performance Measures

OGE’s success in meeting its performance targets is shown 

below: 

Objective 3.1 

Increase OGE’s Support of and Cooperation With 

 Federal, State and Local Agencies Implementing 

 Programs That Help Support Good Governance

Performance Targets

FY Actual Results in bold

Performance 

Measures 

Baseli

ne 

FY 

2007 

FY 

2008 

FY 

2009 

FY 

2010 

FY 

2011 

Number of 

programs/ 

projects 

involving 

federal 

agencies/ 

organizations 

6 8 

14 

8 

9 

10 10 10 

Percent of 

feedback from 

federal 

program/project 

attendees 

indicating OGE 

participation 

was useful 

30% 30% 

95% 

40% 

100% 

50% 50% 60% 

Number of 

programs/projec

ts involving 

state/local/ 

government 

agencies/ 

organizations 

2 2 

5 

2 

3 

3 3 3 

Percent of 

feedback from 

state and local 

program/project 

attendees 

indicating OGE 

participation 

was useful 

30% 30% 

100% 

40% 

100% 

50% 50% 60% 

33
Objective 3.2: Enhance Outreach to the Public and Private 

Sector and Civil Society 

In FY 2008, OGE’s Director and other members of OGE’s staff 

made numerous presentations to private sector and civil society 

organizations whose understanding of the Federal ethics program 

helped to support public trust in Government. The audiences 

included non-Government organizations, professional and business 

associations, and educational institutions, such as the American 

Bar Association, the D.C. Bar Association, and a national 

association of scientists. The OGE Director and his staff also 

specifically reached out to various organizations for their 

views on such issues as the role of leadership in enhancing and 

maintaining ethical cultures in agencies and the anticipated 

challenges in the upcoming Presidential transition. These 

interactions also consistently drew positive responses. OGE’s 

16th National Government Ethics Conference included presentations 

by representatives of private sector and civil society 

organizations focused on ethics issues. 

In FY 2008, OGE continued to serve the public effectively 

through its help desk, which provided timely and thorough 

responses to over 900 queries for information. OGE timely 

responded to numerous press inquiries in order to ensure 

accuracy of reporting on ethics laws and rules that apply to the 

executive branch. In addition, OGE conducted three formal 

interviews with various media outlets on ethics issues. OGE 

responded directly to letters from the public seeking 

information or assistance on issues that often require referral 

to other Federal or State entities. OGE released 160 reports of 

PAS officials in response to 32 requests. OGE continued its 100 

percent on-time response rate for FOIA and Privacy Act requests. 

OGE also released 64 travel payment reports (or § 1353 reports). 

All executive branch agencies file these reports with OGE semiannually in order to show the extent to which agencies accepted 

payments for travel, subsistence and related expenses received 

from non-Federal sources in connection with the attendance of 

employees at certain meetings and similar functions. 

34
Performance Measures

OGE’s success in meeting its performance targets is shown 

below: 

Objective 3.2 

Enhance Outreach to the Private Sector and Civil Society

Performance Targets

FY Actual Results in bold

Performance 

Measures 

Baseline FY 

2007 

FY 

2008 

FY 

2009 

FY 

2010 

FY 2011 

Number of 

meetings, 

speeches, 

presentations 

and similar 

outreach 

efforts to 

organizations 

that represent 

the public, 

civil society 

and persons 

who do 

business with 

the Government 

8 10 

12 

10 

13 

12 12 15 

Percent of 

feedback from 

attendees 

indicating 

that 

interaction 

with OGE was 

useful 

30% 30% 

100% 

40% 

100% 

50% 50% 60% 

Objective 3.3: Support U.S. Foreign Policy Anti-Corruption and 

Good Governance Initiatives 

OGE’s provision of ethics program expertise and an 

understanding of an ethics program’s role in good governance 

continued to have an appreciable and positive effect on the 

recipients of the United States’ anti-corruption foreign policy 

initiatives. Its expertise was also highly appreciated by the 

Federal agencies whose initiatives and programs OGE supported. 

As a result, FY 2008 was an extremely active and highly 

successful year for OGE in its continuing support of the United 

35
States’ foreign policy initiatives in the area of corruption 

prevention. 

Throughout the year, OGE staff continued to represent the 

United States Government at the plenary meetings of the Council 

of Europe’s Group of States Against Corruption (GRECO) and serve 

as expert evaluators of other GRECO members for the third round 

of evaluations. In addition, a representative from OGE was 

asked to write the substantive section of GRECO’s Eighth General 

Activity Report that addressed practices and lessons learned 

from GRECO reviews on the topic of “revolving doors” or 

“pantouflage.” The section was well received by the member 

countries, with a number of countries subsequently translating 

that section of the text into other languages for use by their 

own policymakers. 

The United Nations Convention Against Corruption has been, 

and continues to be, a priority anti-corruption foreign policy 

initiative of the United States. Because of OGE’s expertise in 

mutual evaluation mechanisms, OGE continued to serve as a 

principal member of an interagency committee that is responsible 

for developing the United States’ position on a review mechanism 

for implementation of the Convention; represented the United 

States at meetings that the United Nations Office on Drugs and 

Crime (UNODC) held to advance the development of a review 

mechanism; and assisted the United States with its own review 

and with its commitments to review three other countries in a 

pilot review program. Based on OGE’s active participation in 

these activities, the Department of State asked OGE to serve as 

a member of the United States’ delegation to the Second Council 

of States Parties to the Convention. 

Throughout FY 2008, OGE provided expertise in a number of 

initiatives of other international organizations in which the 

United States is a member. For example, OGE worked with the 

members of the Asia Pacific Economic Cooperation’s (APEC) 

Anti-corruption and Transparency Task Force, and with China in 

particular, to begin designing a symposium on the APEC 

Principles of Conduct for Public Officials tentatively to be 

held in FY 2009. In addition, OGE continued to serve as a 

United States expert resource to the Organization for Economic 

Cooperation and Development through the Directorate on Public 

Governance and Territorial Development for a variety of topics 

and programs including post-employment, lobbying, and assessing 

integrity programs and to the Directorate for Financial and 

Enterprise Affairs in a program for the Anti-Corruption Network 

for Eastern Europe and Central Asia. 

36
In long-standing support of the Department of State’s 

International Visitor Leadership Program, OGE continued to meet 

with delegations of foreign visitors interested in ethics, 

conflicts of interest, transparency, and other good governance 

initiatives. During FY 2008, OGE hosted 33 delegations made up 

of over 375 visitors from over 80 countries. Approximately 80 

percent of the surveyed visitors were public officials and the 

remainder included journalists, academics, and members of nongovernmental organizations. From completed surveys of the 

visitors, OGE found that nearly all visitors reported OGE’s 

presentations helped them to understand the activities of OGE 

and its role and function in the broader context of good 

governance. Most indicated they felt the knowledge they gained 

from the presentations would be useful to them in their 

countries. 

Finally, OGE continued to serve as a resource to the 

Department of State’s Bureau for International Narcotics and Law 

Enforcement Affairs (INL) and the Department of Justice’s Office 

for Overseas Prosecutorial Development Assistance and Training 

(OPDAT) for technical assistance to individual country 

anti-corruption programs. In support of INL, OGE continued to 

review follow-up reports on anti-corruption prevention efforts 

made by countries who have agreed to participate in the 

Follow-up Mechanism of the Inter-American Convention Against 

Corruption. 

Performance Measures

OGE’s success in meeting its performance targets is shown 

below: 

Objective 3.3 

Support U.S. Foreign Policy Anti-Corruption and Good 

Governance Initiatives

Performance Targets

FY Actual Results in bold

Performance 

Measures 

Baseline FY 

2007 

FY 

2008 

FY 

2009 

FY 

2010 

FY 

2011 

Number of 

programs/projects 

OGE participates 

in at the request 

U.S. foreign 

policy agencies/ 

organizations 

7 7 

21 

7 

21 

8 8 8 

37
Objective 3.3 

Support U.S. Foreign Policy Anti-Corruption and Good 

Governance Initiatives

Performance Targets

FY Actual Results in bold

Performance 

Measures 

Baseline FY 

2007 

FY 

2008 

FY 

2009 

FY 

2010 

FY 

2011 

Percent of 

feedback from 

program/project 

participants 

indicating that 

interaction with 

OGE was useful 

30% 30% 

90% 

40% 

100% 

50% 50% 60% 

Enhanced Internal Administrative Support 

During FY 2008, OGE staff maintained vital services related 

to budget, finance, human resources, graphics, facilities, 

property management, travel, procurement, telecommunications, 

records management, information, and website technologies. To 

add to this array of services and related reporting 

requirements, OGE took steps to enhance its ability to attract 

and retain a highly effective workforce. OGE obtained 

recertification of its SES pay-for-performance system and 

completed a human capital survey of its employees. OGE also 

enhanced its ability to continue operations in the event of a 

natural disaster, attack, or other emergency through 

participation in the Department of Homeland Security’s 

“Operation Eagle Horizon” exercise. OGE redrafted its 

Continuity of Operations Plan, updated its building evacuation 

plan, reviewed the currency of its Shelter-in-Place procedures, 

and provided emergency training to employees. OGE also 

continued its compliance with HSPD-12 deadlines. 

To improve its business processes, OGE took steps to 

improve remote connectivity to its IT network, oversaw the 

installation and security requirements for a multi-media 

workstation system within the Office of Agency Programs, 

assisted in the development of electronic survey instruments, 

met NIST security requirements, and successfully completed its 

facilitation of the redesign of the OGE website. OGE continued 

its progress in meeting trusted Internet connection requirements 

and the accompanying transition to WITS3. OGE approved an action 

38
plan for refreshing its IT equipment in FY 2009. OGE also 

successfully tested its Internet Protocol version 6 capability. 

39

UNITED STATES OFFICE OF GOVERNMENT ETHICS 

FINANCIAL STATEMENTS 

AND 

INDEPENDENT AUDITOR’S REPORT 

FOR THE FISCAL YEARS ENDED 

SEPTEMBER 30, 2008 AND 2007 

BY 

BROWN & COMPANY CPAs, PLLC 

NOVEMBER 7, 2008 
UNITED STATES OFFICE OF GOVERNMENT ETHICS 

FOR THE FISCAL YEARS ENDED 

SEPTEMBER 30, 2008 AND 2007

TABLE OF CONTENTS

INDEPENDENT AUDITOR’S REPORT ON THE FINANCIAL STATEMENTS.................. 1 

INDEPENDENT AUDITOR’S REPORT ON INTERNAL CONTROL ................................... 2 

INDEPENDENT AUDITOR’S REPORT ON COMPLIANCE WITH LAWS AND 

REGULATIONS ... .......................................................................................................................... 4 

BALANCE SHEET.......................................................................................................................... 5 

 

STATEMENT OF NET COST . ..................................................................................................... 6 

 

STATEMENT OF CHANGES IN NET POSITION................................................................... 7 

 

STATEMENT OF BUDGETARY RESOURCES.. ...................................................................... 8 

 

NOTES TO THE FINANCIAL STATEMENTS . ........................................................................ 9 
~=====BROWN & COMPANY CPAs, PLLC=============~~

CERI'IFIED PUBLIC ACCOUNTANTS AND MANAGEMENT CONSULTANTS 

INDEPENDENT AUDITOR'S REPORT ON THE FINANCIAL STATEMENTS 

Board of Directors 

Office of Government Ethics 

Washington, DC 

We have audited the accompanying balance sheet of the Office of Government Ethics (OGE) as of
 

September 30, 2008 and 2007, and the related statements of net cost, changes in net position, and
 

budgetary resources, for the years then ended (collectively referred to as the financial statements). These
 

financial statements are the responsibility of OGE's management. Our responsibility is to express an
 

opinion on these financial statements based on our audit.
 

We conducted our audit in accordance with auditing standards generally accepted in the United States of 

America and the standards applicable to financial audits contained in U.S. Government Auditing 

Standards, issued by the Comptroller General of the United States; and Office of Management and Budget 

(OMB) Bulletin No. 07-04, Audit Requirements for Federal Financial Statements. Those standards and 

OMB Bulletin No. 07-04 require that we plan and perform the audit to obtain reasonable assurance about 

whether the financial statements are free of material misstatement. An audit includes examining, on a test 

basis, evidence supporting the amounts and disclosures in the financial statements. An audit also includes 

assessing the accounting principles used and significant estimates made by management, as well as 

evaluating the overall financial statement presentation. We believe that our audit provides a reasonable 

basis for our opinion. 

In our opinion, the financial statements referred to above present fairly, in all material respects, the 

financial position of the OGE as of September 30, 2008 and 2007 and its net costs, changes in net 

position, and budgetary resources for the years then ended in conformity with accounting principles 

generally accepted in the United States of America. 

In accordance with U.S. Government Auditing Standards and OMB Bulletin No. 07-04, we have also 

issued a report dated November 7, 2008 on our consideration of the OGE internal control over financial 

reporting and its compliance with provisions of laws and regulations. Those reports are an integral part of 

an audit performed in accordance with U.S. Government Auditing Standards and should be read in 

conjunction with this report in considering the results of our audit. 

The information in "Management's Discussion & Analysis" (MD&A) is presented for the purpose of 

additional analysis and is required by OMB Circular No. A-136, revised Financial Reporting 

Requirements. The OGE's MD&A contains a wide range of information, some of which is not directly 

related to the financial statements. We do not express an opinion on this information. However, we 

compared this information for consistency with the financial statements and discussed the methods of 

measurement and presentation with OGE officials. Based on this limited work, we found no material 

inconsistencies with the financial statements, U.S. generally accepted accounting principles, or OMB 

guidance. 

This report is intended solely for the information and use of the management of the OGE, OMB and 

Congress, and is not intended to be and should not be used by anyone other than these specific parties. 

LargO,~d~~
 November 7, 2008 

LARGO RICHMOND
 

9200 BASIL COURT, SUITE 400
 1504 SANTA ROSA ROAD, SUITE 107 

LARGO, MD 20774 RICHMOND, VA 23229 

(240)	 492-1400. FAX: (301) 636-6013 (804) 288-2006. FAX: (804) 288-2233 

mail@brownco-cpas.com tdavis@brownco-cpas.com 
CERTIFIED PUBLIC ACCOUNTANTS AND MANAGEMENT CONSULTANTS 

INDEPENDENT AUDITOR'S REPORT ON INTERNAL CONTROL 

Board of Directors 

Office of Government Ethics 

Washington, DC 

We have audited the financial statements of the Office of Government Ethics (OGE) as of and for 

the year ended September 30, 2008 and have issued our report thereon dated November 7, 2008. 

We conducted our audit in accordance with auditing standards generally accepted in the United 

States of America; and the standards applicable to financial audits contained in U.S Government 

Auditing Standards, issued by the Comptroller General of the United States; and Office of 

Management and Budget (OMB) Bulletin No. 07-04, Audit Requirements jor Federal Financial 

Statements. 

In planning and performing our audit, we considered the OGE's internal control over financial 

reporting by obtaining an understanding of the OGE's internal control, determined whether 

internal controls had been placed in operation, assessed control risk, and performed tests of 

controls in order to determine our auditing procedures for the purpose of expressing our opinion 

on the financial statements. We limited our internal control testing to those controls necessary to 

achieve the objectives described in OMB Bulletin No. 07-04. We did not test all internal controls 

relevant to operating objectives as broadly defined by the Federal Managers' Financial Integrity 

Act of 1982, such as those controls relevant to ensuring efficient operations. The objective of our 

audit was not to provide an opinion on internal control and therefore, we do not express an 

opinion on internal control. 

Our consideration of the internal control over financial reporting would not necessarily disclose 

all matters in the internal control over financial reporting that might be significant deficiencies. 

Under standards issued by the American Institute of Certified Public Accountants and OMB 

Bulletin No. 07-04, a significant deficiency is a deficiency in internal control, or a combination of 

deficiencies, that adversely affects the entity's ability to initiate, authorize, record, process, or 

report financial data reliably in accordance with generally accepted accounting principles such 

that there is more than a remote likelihood that a misstatement of the entity's financial statements 

that is more than inconsequential will not be prevented or detected. Our consideration of the 

internal control over financial reporting would not necessarily disclose all matters in the internal 

control over financial reporting that might be a material weakness. A material weakness is a 

significant deficiency, or combination of significant deficiencies, that result in a more than 

remote likelihood that a material misstatement of the financial statements will not be prevented or 

detected. Because of inherent limitations in internal controls, misstatements, losses, or noncompliance may nevertheless occur and not be detected. However, we noted no matters 

involving the internal control and its operation that we considered to be significant deficiencies or 

material weaknesses as defined above. 

LARGO RICHMOND 

9200 BASIL COURT, SUITE 400 2 1504 SANTA ROSA ROAD, SUITE 107 

LARGO, MD 20774 RICHMOND, VA 23229 

(240) 492-1400. FAX: (301) 636-6013 (804) 288-2006. FAX: (804) 288-2233 

mail@brownco-cpas.com tdavis@brownco-cpas.com 
This report is intended solely for the infonnation and use of the management of the OGE, OMB 

and Congress, and is not intended to be and should not be used by anyone other than these 

speCi~i~S~

Largo, Maryland 

November 7, 2008 

E============= BROWN & COMPANY CPAS, PLLC ============~.
 3
 
~~~=========BROWN & COMPANY CPAs, PLLC==================::3. 

CERI'IFIED PUBLIC ACCOUNTANTS AND MANAGEMENT CONSULTANTS 

INDEPENDENT AUDITOR'S REPORT ON
 

COMPLIANCE WITH LAWS AND REGULATIONS
 

Board of Directors 

Office of Government Ethics 

Washington, DC 

We have audited the financial statements of the Office of Government Ethics (OGE) as of and for the year 

ended September 30, 2008, and have issued our report thereon dated November 7, 2008. We conducted 

our audit in accordance with auditing standards generally accepted in the United States of America, and 

the standards applicable to financial audits contained in U.S. Government Auditing Standards, issued by 

the Comptroller General of the United States; and Office of Management and Budget (OMB) Bulletin No. 

07-04, Audit Requirements/or Federal Financial Statements. 

The management of the OGE is responsible for complying with laws and regulations applicable to the 

OGE. As part of obtaining reasonable assurance about whether the aGE's financial statements are free of 

material misstatement, we performed tests of its compliance with certain provisions of laws and 

regulations, noncompliance with which could have a direct and material effect on the determination of 

financial statement amounts, and certain other laws and regulations specified in OMB Bulletin No. 07-04. 

We limited our tests of compliance to these provisions and we did not test compliance with all laws and 

regulations applicable to the OGE. 

The results of our tests of compliance disclosed no reportable instances of noncompliance with other laws 

and regulations discussed in the preceding paragraph that are required to be reported under U.S. 

Government Auditing Standards or OMB Bulletin No. 07-04. 

Providing an opinion on compliance with certain provisions of laws and regulations was not an objective 

of our audit, and, accordingly, we do not express such an opinion. However, we noted no noncompliance 

with laws and regulations, which could have a direct and material effect on the determination of financial 

statement amounts. 

This report is intended solely for the information and use of the management of the OGE, OMB and 

Congress, and is not intended to be and should not be used by anyone other than these specified parties. 

Largo, Maryland 

~~~

November 7, 2008 

LARGO RICHMOND 

9200 BASIL COURT, SUITE 400 4 1504 SANTA ROSA ROAD, SUITE 107 

LARGO, MD 20774 RICHMOND, VA 23229 

(240) 492-1400· FAX: (301) 636-6013 (804) 288-2006. FAX: (804) 288-2233 

mail@brownco-cpas.com tdavis@brownco-cpas.com 
2008 2007

ASSETS

Intragovernmental:

Fund Balance With Treasury (Note 2) $ 2,454,523 $ 2,444,572

Accounts Receivable 37,636 -

Total Intragovernmental 2,492,159 2,444,572

Accounts Receivable 259 -

Total Assets $ 2,492,418 $ 2,444,572

LIABILITIES

Intragovernmental:

Accounts Payable (Note 3) $ 25,000 $ 179,683

Other (Note 3) 149,117 132,218

Total Intragovernmental 174,117 311,901

Accounts Payable (Note 3) 697,053 277,991

Federal Employee and Veterans' Benefits (Note 3) 335,745 -

Other (Note 3) 1,230,347 1,147,716

Total Liabilities $ 2,437,262 $ 1,737,608

NET POSITION

Unexpended Appropriations $ 1,228,435 $ 1,495,340

Cumulative Results of Operations (1,173,279) (788,376)

Total Net Position 55,156 706,964

Total Liabilities and Net Position $ 2,492,418 $ 2,444,572

The accompanying notes are an integral part of these financial statements.

 5

UNITED STATES OFFICE OF GOVERNM ENT ETHICS

BALANCE SHEET

AS OF SEPTEMBER 30, 2008 AND 2007

(In Dollars)
2008 2007

PROGRAM COSTS

SALARIES AND EXPENSES

Gross Costs (Note 6) $ 13,063,488 $ 12,044,502

Less: Earned Revenue 506,414 260,700

Net Program Costs 12,557,074 11,783,802

Net Cost of Operations $ 12,557,074 $ 11,783,802

The accompanying notes are an integral part of these financial statements.

 6

 

UNITED STATES OFFICE OF GOVERNM ENT ETHICS

STATEMENT OF NET COST

FOR THE YEARS ENDED SEPTEM B ER 30, 2008 AND 2007

(In Dollars)
2008 2007

 

CUM ULATIVE RESULTS OF OPERATIONS

Beginning Balances $ (788,376) $ (683,517)

Budgetary Financing Sources:

Appropriations Used 11,628,496 11,069,035

Other Financing Sources 

Imputed Financing Sources 543,675 609,908

Total Financing Sources 12,172,171 11,678,943

Net Cost of Operations 12,557,074 11,783,802

Net Change (384,903) (104,859)

Cumulative Results of Operations $ (1,173,279) $ (788,376)

UNEXPENDED APPROPRIATIONS

Beginning Balances $ 1,495,340 $ 1,629,143

Budgetary Financing Sources

Appropriations Received 11,750,000 11,115,085

Other Adjustments (388,409) (179,853)

Appropriations Used (11,628,496) (11,069,035)

Total Budgetary Financing Sources (266,905) (133,803)

Total Unexpended Appropriations $ 1,228,435 $ 1,495,340

NET POSITION $ 55,156 $ 706,964

The accompanying notes are an integral part of these financial statements.

 7

UNITED STATES OFFICE OF GOVERNM ENT ETHICS

STATEMENT OF CHANGES IN NET POSITION

FOR THE YEARS ENDED SEPTEM BER 30, 2008 AND 2007

(In Dollars)
2008 2007

B UDGETARY RES OURCES

Unobligated Balance: $ 1,159,369 $ 1,006,499

Recoveries of Prior Year Unpaid Obligations 351,876 186,569

Budget A uthority

A ppropriation 11,750,000 11,115,085

Spending A uthority From Offs etting Collections

Earned

Collected 468,666 260,700

Change In Receivables From Federal Sources 37,747 -

Change In Unfilled Cus tomer Orders

W ithout A dvance From Federal Sources 34,403 -

Permanently Not A vailable 388,409 179,853

Total Budgetary Res ources $ 13,413,652 $ 12,389,000

S TATUS OF B UDGETARY RES OURCES

Obligations Incurred

Direct $ 11,987,569 $ 10,968,667

Reimburs able 540,817 260,964

Unobligated Balance

A pportioned 71,860 157,939

Unobligated Balance Not A vailable 813,406 1,001,430

Total Status of Budgetary Res ources $ 13,413,652 $ 12,389,000

CHANGE IN OB LIGATED B ALANCE

Obligated Balance, Net

Unpaid Obligations , Brought Forward, October 1 1,285,203 $ $ 1,516,056

Total Unpaid Obligated Balance, Net 1,285,203 1,516,056

Obligations Incurred Net 12,528,386 11,229,631

Les s : Gros s Outlays 11,820,306 11,273,915

Les s : Recoveries of Prior Year Unpaid

Obligations , A ctual 351,876 186,569

Change In Uncollected Cus tomer Payments

From Federal Sources (72,150) -

Obligated Balance, Net, End of Period

Unpaid Obligations 1,641,407 1,285,203

Les s : Uncollected Cus tomer Payments From

Federal Sources 72,150 -

Total, Unpaid Obligated Balance, Net, End of Period 1,713,557 $ $ 1,285,203

NET OUTLAYS

Net Outlays :

Gros s Outlays $ 11,820,306 $ 11,273,915

Les s : Offs etting Collections 468,666 260,700

Net Outlays $ 11,351,640 $ 11,013,215

UNITED S TATES OFFICE OF GOVERNMENT ETHICS

S TATEMENT OF B UDGETARY RES OURCES

FOR THE YEARS ENDED S EPTEMB ER 30, 2008 AND 2007

(In Dollars )

The accompanying notes are an integral part of thes e financial s tatements .

 8
OFFICE OF GOVERNMENT ETHICS 

NOTES TO THE FINANCIAL STATEMENTS 

FOR THE YEARS ENDED SEPTEMBER 30, 2008 AND 2007 

NOTE 1. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES 

A. Basis of Presentation 

The financial statements have been prepared to report the financial position, net cost of 

operations, changes in net position, and the status and availability of budgetary resources of 

Office of Government Ethics (OGE). The statements are a requirement of the Chief Financial 

Officers Act of 1990, the Government Management Reform Act of 1994, and the Accountability 

of Tax Dollars Act of 2002. They have been prepared from, and are fully supported by, the books 

and records of OGE in accordance with the hierarchy of accounting principles generally accepted 

in the United States of America, standards approved by the principals of the Federal Accounting 

Standards Advisory Board (FASAB), OMB Circular A-136, Financial Reporting Requirements

and OGE accounting policies which are summarized in this note. These statements, with the 

exception of the Statement of Budgetary Resources, are different from financial management 

reports, which are also prepared pursuant to OMB directives that are used to monitor and control 

OGE’s use of budgetary resources. 

The statements consist of the Balance Sheet, Statement of Net Cost, Statement of Changes in Net 

Position, and the Statement of Budgetary Resources. In accordance with OMB Circular A-136, 

the financial statements and associated notes are presented on a comparative basis. Unless 

specified otherwise, all amounts are presented in dollars. 

B. Reporting Entity 

The Office of Government Ethics (OGE), a small agency within the executive branch, was 

established by the Ethics in Government Act of 1978. In partnership with executive branch 

agencies and departments, OGE fosters high ethical standards for employees and strengthens the 

public’s confidence that the Government’s business is conducted with impartiality and integrity. 

C. Budgets and Budgetary Accounting 

OGE receives all funding through Congressional appropriation from the budget of the United 

States. Annual appropriations are used within statutory limits, to incur obligations for specified 

purposes. OGE also has reimbursable authority to conduct an Annual Ethics Conference. 

Budgetary resources are recorded when funds on deposit with the Department of Treasury are 

made available to OGE through a warrant(s) for expenditures and liabilities. 

D. Basis of Accounting 

Transactions are recorded on both an accrual accounting basis and a budgetary basis. Under the 

accrual method, revenues are recognized when earned, and expenses are recognized when a 

liability is incurred, without regard to receipt or payment of cash. Budgetary accounting 

facilitates compliance with legal requirements on the use of federal funds. 

The accompanying notes are an integral part of these statements. 

 9 
OFFICE OF GOVERNMENT ETHICS 

NOTES TO THE FINANCIAL STATEMENTS 

FOR THE YEARS ENDED SEPTEMBER 30, 2008 AND 2007 

NOTE 1. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (CONTINUED) 

E. Revenues & Other Financing Sources 

Congress enacts annual and multi-year appropriations to be used, within statutory limits, for 

operating and capital expenditures. Appropriations are recognized as a financing source when 

expended. Revenues from service fees associated with reimbursable agreements are recognized 

concurrently with the recognition of accrued expenditures for performing the services. 

We recognize as an imputed financing source the amount of accrued pension and post-retirement 

benefit expenses for current employees paid on our behalf by the Office of Personnel 

Management (OPM). 

F. Taxes

OGE, as a Federal entity, is not subject to Federal, State, or local income taxes, and, accordingly, 

no provision for income taxes has been recorded in the accompanying financial statements. 

G. Fund Balance with Treasury 

The U.S. Treasury processes cash receipts and disbursements. Funds held at the Treasury are 

available to pay agency liabilities. OGE does not maintain cash in commercial bank accounts. 

See Note 2 for additional information. 

H. Accounts Receivable, Net 

Accounts receivable consists of amounts owed to OGE by other Federal agencies and the public. 

Amounts due from Federal agencies are considered fully collectible. Accounts receivable from 

the public include reimbursements from employees. An allowance for uncollectible accounts 

receivable from the public is established when either (1) based upon a review of outstanding 

accounts and the failure of all collection efforts, management determines that collection is 

unlikely to occur considering the debtor’s ability to pay, or (2) an account for which no allowance 

has been established is submitted to the Department of the Treasury for collection, which takes 

place when it becomes 180 days delinquent. 

The accompanying notes are an integral part of these statements. 

 10 
OFFICE OF GOVERNMENT ETHICS 

NOTES TO THE FINANCIAL STATEMENTS 

FOR THE YEARS ENDED SEPTEMBER 30, 2008 AND 2007

NOTE 1. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (CONTINUED) 

I. Property, Plant and Equipment, Net 

OGE’s property, plant and equipment is recorded at original acquisition cost and is depreciated 

using the straight-line method over the estimated useful life of the asset. Major alterations and 

renovations are capitalized, while maintenance and repair costs are charged to expense as 

incurred. OGE’s capitalization threshold is $50,000 for individual purchases and $500,000 for 

bulk purchases. Applicable standard governmental guidelines regulate the disposal and 

convertibility of agency property, plant and equipment. The useful life classifications for 

capitalized assets are as follows: 

Description Useful Life (years)

Leasehold Improvements 9 

Office Furniture 5 

Computer Equipment 3 

Office Equipment 5 

J. Advances and Prepaid Charges 

Advance payments are generally prohibited by law. There are some exceptions, such as 

reimbursable agreements, subscriptions and payments to contractors and employees. Payments 

made in advance of the receipt of goods and services are recorded as advances or prepaid charges 

at the time of prepayment and recognized as expenses when the related goods and services are 

received. 

K. Liabilities

Liabilities covered by budgetary or other resources are those liabilities for which Congress has 

appropriated funds or funding is otherwise available to pay amounts due. 

Liabilities not covered by budgetary or other resources represent amounts owed in excess of 

available Congressionally appropriated funds or other amounts. The liquidation of liabilities not 

covered by budgetary or other resources is dependent on future Congressional appropriations or 

other funding. Intragovernmental liabilities are claims against OGE by other Federal agencies. 

Liabilities not covered by budgetary resources on the Balance Sheet are equivalent to amounts 

reported as Components requiring or generating resources on the Reconciliation of Net Cost to 

Budget. Additionally, the Government, acting in its sovereign capacity, can abrogate liabilities. 

L. Accounts Payable 

Accounts payable consists of amounts owed to other Federal agencies and the public. 

The accompanying notes are an integral part of these statements. 

 11 
OFFICE OF GOVERNMENT ETHICS 

NOTES TO THE FINANCIAL STATEMENTS 

FOR THE YEARS ENDED SEPTEMBER 30, 2008 AND 2007

NOTE 1. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (CONTINUED) 

M. Annual, Sick, and Other Leave 

Annual leave is accrued as it is earned, and the accrual is reduced as leave is taken. The balance 

in the accrued leave account is adjusted to reflect current pay rates. Liabilities associated with 

other types of vested leave, including compensatory, restored leave, and sick leave in certain 

circumstances, are accrued at year-end, based on latest pay rates and unused hours of leave. 

Funding will be obtained from future financing sources to the extent that current or prior year 

appropriations are not available to fund annual and other types of vested leave earned but not 

taken. Nonvested leave is expensed when used. Any liability for sick leave that is accrued but 

not taken by a Civil Service Retirement System (CSRS)-covered employee is transferred to the 

Office of Personnel Management upon the retirement of that individual. No credit is given for 

sick leave balances upon the retirement of Federal Employee’s Retirement System (FERS)-

covered employees. 

N. Accrued and Actuarial Workers’ Compensation 

A liability is recorded for actual and estimated future payments to be made for workers’ 

compensation pursuant to the Federal Employees’ Compensation Act (FECA). The actual costs 

incurred are reflected as a liability because OGE will reimburse the Department of Labor (DOL) 

two years after the actual payment of expenses. Future appropriations will be used for the 

reimbursement to DOL. The liability consists of (1) the net present value of estimated future 

payments calculated by the DOL, and (2) the unreimbursed cost paid by DOL for compensation 

to recipients under the FECA. 

O. Retirement Plans 

OGE employees participate in either the Civil Service Retirement System (CSRS) or the Federal 

Employees’ Retirement System (FERS). The employees who participate in CSRS are 

beneficiaries of OGE’s matching contribution, equal to seven percent of pay, distributed to their 

annuity account in the Civil Service Retirement and Disability Fund. 

FERS went into effect on January 1, 1987. FERS and Social Security automatically cover most 

employees hired after December 31, 1983. Employees hired prior to January 1, 1984 elected to 

join either FERS and Social Security, or remain in CSRS. FERS offers a savings plan to which 

OGE automatically contributes one percent of pay and matches any employee contribution up to 

an additional four percent of pay. For FERS participants, OGE also contributes the employer’s 

matching share of Social Security. 

FERS employees and certain CSRS reinstatement employees are eligible to participate in the 

Social Security program after retirement. In these instances, OGE remits the employer’s share of 

the required contribution. 

The accompanying notes are an integral part of these statements. 

 12 
OFFICE OF GOVERNMENT ETHICS 

NOTES TO THE FINANCIAL STATEMENTS 

FOR THE YEARS ENDED SEPTEMBER 30, 2008 AND 2007

NOTE 1. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (CONTINUED) 

O. Retirement Plans (Continued)

OGE recognizes the imputed cost of pension and other retirement benefits during the employees’ 

active years of service. OPM actuaries determine pension cost factors by calculating the value of 

pension benefits expected to be paid in the future and communicates these factors to OGE for 

current period expense reporting. OPM also provides information regarding the full cost of 

health and life insurance benefits. OGE recognized the offsetting revenue as imputed financing 

sources to the extent these expenses will be paid by OPM. 

OGE does not report on its financial statements information pertaining to the retirement plans 

covering its employees. Reporting amounts such as plan assets, accumulated plan benefits, and 

related unfunded liabilities, if any, is the responsibility of the OPM. 

P. Use of Estimates 

Management has made certain estimates when reporting assets, liabilities, revenue, and expenses, 

and in the note disclosures. The preparation of financial statements in conformity with generally 

accepted accounting principles requires management to make assumptions that affect the reported 

amounts of assets and liabilities and disclosure of contingent assets and liabilities at the date of 

the financial statements and the reported amounts of revenues and expenses during the reporting 

period. Actual results could differ from those estimates. 

Q. Imputed Costs/Financing Sources 

Federal Government entities often receive goods and services from other Federal Government 

entities without reimbursing the providing entity for all the related costs. In addition, Federal 

Government entities also incur costs that are paid in total or in part by other entities. An imputed 

financing source is recognized by the receiving entity for costs that are paid by other entities. 

R. Contingencies 

Liabilities are deemed contingent when the existence or amount of the liability cannot be 

determined with certainty pending the outcome of future events. OGE recognizes contingent 

liabilities, in the accompanying balance sheet and statement of net cost, when it is both probable 

and can be reasonably estimated. OGE discloses contingent liabilities in the notes to the financial 

statements when the conditions for liability recognition are not met or when a loss from the 

outcome of future events is more than remote. In some cases, once losses are certain, payments 

may be made from the Judgment Fund maintained by the U.S. Treasury rather than from the 

amounts appropriated to OGE for agency operations. Payments from the Judgment Fund are 

recorded as an “Other Financing Source” when made. There are no contingencies that require 

disclosure. 

The accompanying notes are an integral part of these statements. 

 13 
OFFICE OF GOVERNMENT ETHICS 

NOTES TO THE FINANCIAL STATEMENTS 

FOR THE YEARS ENDED SEPTEMBER 30, 2008 AND 2007 

NOTE 1. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (CONTINUED) 

S. Expired Accounts and Cancelled Authority 

Unless otherwise specified by law, annual authority expires for incurring new obligations at the 

beginning of the subsequent fiscal year. The account in which the annual authority is placed is 

called the expired account. For five fiscal years, the expired account is available for expenditure 

to liquidate valid obligations incurred during the unexpired period. Adjustments are allowed to 

increase or decrease valid obligations incurred during the unexpired period but not previously 

reported. At the end of the fifth expired year, the expired account is cancelled. 

T. Reclassification 

The preparation of financial statements in conformity with generally accepted accounting 

principles requires in some cases for prior year balances to be reclassified, retitled, or combined 

with other financial statement line items for consistency with current year presentation. 

NOTE 2. FUND BALANCE WITH TREASURY

Fund balance with Treasury account balances as of September 30, 2008 and 2007 were: 

Fund Balances: 

2008 2007 

Appropriated Funds $ 2,454,523 $ 2,444,572 

Total $ 2,454,523 $ 2,444,572 

Status of Fund Balance with Treasury: 

2008 2007 

Unobligated Balance 

 Available $ 71,860 $ 157,939 

 Unavailable 813,406 1,001,430 

Obligated Balance Not Yet Disbursed 1,569,257 1,285,203 

Total $ 2,454,523 $ 2,444,572 

Restricted unobligated fund balances represent the amount of appropriations for which the period 

of availability for obligation has expired. These balances are available for upward adjustments of 

obligations incurred only during the period for which the appropriation was available for 

obligation or for paying claims attributable to the appropriations. 

The accompanying notes are an integral part of these statements. 

 14 
OFFICE OF GOVERNMENT ETHICS 

NOTES TO THE FINANCIAL STATEMENTS 

FOR THE YEARS ENDED SEPTEMBER 30, 2008 AND 2007 

NOTE 3. LIABILITIES NOT COVERED BY BUDGETARY RESOURCES 

The liabilities on OGE’s Balance Sheet as of September 30, 2008 and 2007, include liabilities not 

covered by budgetary resources, which are liabilities for which congressional action is needed 

before budgetary resources can be provided. Although future appropriations to fund these 

liabilities are likely and anticipated, it is not certain that appropriations will be enacted to fund 

these liabilities. Unfunded FECA liability is an intragovernmental liability not covered by 

budgetary resources. Unfunded FECA liabilities are $71,795 and $69,004 as of September 30, 

2008 and 2007, respectively. Other liabilities not covered by budgetary resources consist of 

unfunded leave. Unfunded leave balances are $ 766,467 and $ 719,372 as of September 30, 2008 

and 2007, respectively. 

NOTE 4. OTHER LIABILITIES 

The accrued liabilities for OGE are comprised of program expense accruals, payroll accruals, and 

unfunded annual leave and retirement earned by employees. Program expense accruals represent 

expenses that were incurred prior to year-end but were not paid. Similarly, payroll accruals 

represent payroll expenses that were incurred prior to year-end but were not paid. 

2008 2007 

Intragovernmental 

Payroll Taxes Payable $ 77,322 $ 63,214

Unfunded FECA Liability 71,795 69,004

Total Intragovernmental 149,117 132,218

Accrued Funded Payroll 452,943 420,901

Actuarial FECA Liability 335,745 - 

Payroll Taxes Payable 10,937 7,443

Unfunded Annual Leave 766,467 719,372

Total Liabilities $ 1,566,092 $ 1,147,716

All liabilities are current liabilities. 

NOTE 5. LEASES 

Operating Leases

OGE occupies office space under a lease agreement that is accounted for as an operating lease. 

The lease term is for a period of ten (10) years commencing on February 2, 2004 and ends 

February 1, 2014. 

The accompanying notes are an integral part of these statements. 

 15 
OFFICE OF GOVERNMENT ETHICS 

NOTES TO THE FINANCIAL STATEMENTS 

FOR THE YEARS ENDED SEPTEMBER 30, 2008 AND 2007 

NOTE 5. LEASES (CONTINUED) 

Fiscal Year Totals 

2009 $ 1,372,655

2010 1,386,826

2011 1,401,175

2012 1,415,909

2013 1,431,042

Thereafter 478,711

Total Future Payments $ 7,486,318

NOTE 6. INTRAGOVERNMENTAL COSTS AND EXCHANGE REVENUE 

Intragovernmental costs represent goods and services exchanged between two reporting entities 

within the Federal government, and are in contrast to those with non-federal entities (the public). 

Such costs are summarized as follows: 

2008 2007 

 Intragovernmental Costs $ 3,708,566 $ 3,448,805

 Public Costs 9,354,922 8,595,697

 Less: Earned Revenue 506,414 260,700

 Net Cost $ 12,557,074 $ 11,783,802

NOTE 7. OPERATING/PROGRAM COSTS 

Costs by major budgetary object classification as of September 30, 2008 and 2007 are as follows: 

Budgetary Object Classification 2008 2007 

 Personnel and Benefits $ 10,262,796 $ 9,209,227

 Travel and Transportation 306,685 111,059

 Rents, Communication & Utilities 1,492,214 1,345,165

 Printing and Contractual Services 682,375 1,031,969

 Supplies and Materials 77,802 187,868

 Equipment 241,608 105,011

 Interest and Dividend 8 54,203

 Total $ 13,063,488 $ 12,044,502

The accompanying notes are an integral part of these statements. 

 16 
OFFICE OF GOVERNMENT ETHICS 

NOTES TO THE FINANCIAL STATEMENTS 

FOR THE YEARS ENDED SEPTEMBER 30, 2008 AND 2007 

NOTE 8. IMPUTED FINANCING SOURCES 

OGE recognizes as imputed financing the amount of accrued pension and post-retirement benefit 

expenses for current employees. The assets and liabilities associated with such benefits are the 

responsibility of the administering agency, the Office of Personnel Management (OPM). 

Amounts paid from the U.S. Treasury’s Judgment Fund in settlement of claims or court 

assessments against OGE are also recognized as imputed financing. For the years ended 

September 30, 2008 and 2007, imputed financing was as follows. 

2008 2007 

Office of Personnel Management $ 543,675 $ 609,908 

Total Imputed Financing Sources $ 543,675 $ 609,908 

NOTE 9. EXPLANATION OF DIFFERENCES BETWEEN THE STATEMENT OF 

BUDGETARY RESOURCES AND THE BUDGET OF THE UNITED STATES 

GOVERNMENT. 

Statement of Federal Financial Accounting Standards No. 7, Accounting for Revenue and Other 

Financing Sources and Concepts for Reconciling Budgetary and Financial Accounting, calls for 

explanations of material differences between amounts reported in the Statement of Budgetary 

Resources and the actual balances published in the Budget of the United States Government 

(President’s Budget). However, the President’s Budget that will include FY08 actual budgetary 

execution information has not yet been published. The President’s Budget is scheduled for 

publication in February 2009 and can be found at the OMB Web site: 

http://www.whitehouse.gov/omb. The 2009 Budget of the United States Government, with the 

Actual column completed for 2007, has been reconciled with the Statement of Budgetary 

Resources, and there were no material differences. 

NOTE 10. UNDELIVERED ORDERS AT THE END OF THE PERIOD 

Statement of Federal Financial Accounting Standards No. 7, Accounting for Revenue and Other 

Financing Sources and Concepts for Reconciling Budgetary and Financial Accounting, states that 

the amount of budgetary resources obligated for undelivered orders at the end of the period 

should be disclosed. For the years ended September 30, 2008 and 2007, undelivered orders 

amounted to $ 378,153 and $ 335,971, respectively. 

The accompanying notes are an integral part of these statements. 

 17 
The accompanying notes are an integral part of these statements. 

 18 

OFFICE OF GOVERNMENT ETHICS 

NOTES TO THE FINANCIAL STATEMENTS 

FOR THE YEARS ENDED SEPTEMBER 30, 2008 AND 2007 

 NOTE 11. RECONCILIATION OF NET COST OF OPERATIONS TO BUDGET

2008 2007 

RESOURCES USED TO FINANCE ACTIVITIES 

Budgetary Resources Obligated 

Obligations Incurred $ 12,528,386 $ 11,229,631 

Less: Spending Authority from Offsetting Collections and 

Recoveries 892,692 447,269 

Obligations Net of Offsetting Collections and Recoveries 11,635,694 10,782,362 

Other Resources 

Imputed Financing from Costs Absorbed by Others 543,675 609,908 

Net Other Resources Used to Finance Activities 543,675 609,908 

Total Resources Used to Finance Activities $ 12,179,369 $ 11,392,270 

RESOURCES USED TO FINANCE ITEMS NOT PART OF THE 

NET COST OF OPERATIONS 

Change in Budgetary Resources Obligated for Goods, Services and 

Benefits Ordered But Not Yet Provided $ ( 7,779) $ 286,673

Resources That Fund Expenses Recognize in Prior Period 335,745 - 

Total Resources Used to Finance Items Not Part of the Net Cost of 

Operations 327,966 286,673

Total Resources Used to Finance the Net Cost of Operations $ 12,507,335 $11,678,943

COMPONENTS OF THE NET COST OF OPERATIONS THAT 

WILL NOT REQUIRE OR GENERATE RESOURCES IN THE 

CURRENT PERIOD 

Components Requiring or Generating Resources in Future Periods 

Increase in Annual Leave Liability $ 47,095 $ 103,822

Other 2,644 1,037

Total Components of Net Cost of Operations That will not Require or 

Generate Resources in the Current Period 49,739 104,859

NET COST OF OPERATIONS $ 12,557,074 $ 11,783,802