Performance and Accountability Report

Fiscal Year 2012

Table of Contents ______ __________________

Part I – Introduction .....................................................................................1

A. About OGE ...............................................................................1

B. Mission Statement ........................................................................1

C. Organizational Structure of OGE ........................................................1

D. Long Term Strategic Goals ...............................................................3

E. Fiscal Year 2012 Budget Priorities .....................................................4

F. Performance Measures ...................................................................4

Part II – Fiscal Year 2012 Performance Highlights ................................................4

A. Strengthening Ethical Culture Within the Executive Branch .......................5

B. Preventing Conflicts of Interest .........................................................8

C. Promoting Good Governance .........................................................10

D. Focusing on OGE’s People and Internal Operations .................................12

Part III – Management Discussion & Analysis of Results .......................................13

A. Strategic Goal 1: Strengthening Ethical Culture Within the Executive Branch.13

B. Strategic Goal 2: Preventing Conflicts of Interest ..................................17

C. Strategic Goal 3: Promoting Good Governance ....................................19

Part IV – Management Assurances .......................................................................................24

Part V – Financial Statements & Independent Auditor’s Report .............................25

Limitations of the Financial Statements

Independent Auditor’s Report on the Financial Statements

Independent Auditor’s Report on Internal Control Over Financial Reporting 

Independent Auditor’s Report on Compliance with Laws and Regulations 

Fiscal Year 2012 Financial Statements

Notes to the Financial Statements 
Part I – Introduction________________________________________________

A. About OGE 

The United States Office of Government Ethics (OGE) was established by the Ethics in 

Government Act of 1978 (EIGA) to provide direction and oversight of, and accountability for, 

policies designed to prevent and resolve conflicts of interest involving Executive Branch officers 

and employees. OGE is charged with promoting the highest ethical standards for Executive 

Branch employees. To carry out these responsibilities, OGE promulgates and maintains 

enforceable regulations governing ethical conduct for approximately four million civilian 

employees and uniformed service members serving in more than 130 Executive Branch agencies 

as well as the White House.

OGE oversees two financial disclosure systems. The first covers more than 28,000 

public financial disclosure reports in a system that reaches, among others, the 1,200 most senior 

officials in the Executive Branch, appointed by the President with the advice and consent of the 

Senate, who must be certified by the OGE Director as being in compliance with all applicable 

ethics laws. The second, a confidential financial disclosure report system, reaches another 

325,000 employees who serve in less senior positions but who nonetheless have responsibilities 

that create a higher risk for conflict of interest. 

OGE exercises its oversight responsibilities by reviewing and evaluating agency ethics 

programs across the Executive Branch to ensure compliance with the conflict of interest laws and 

ethics regulations and to enhance agencies’ abilities to meet ethics program requirements. The 

agency also provides education and training to nearly 6,000 ethics officials throughout the 

Executive Branch to help ensure that the services provided to employees are current and 

informed. OGE promotes good governance through mutually informative interactions with the 

private sector, non-profit groups, and the general public, as well as by sharing good practices 

with and providing technical assistance to state, local, and foreign governments, and 

international organizations.

B. Mission Statement

OGE 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 departments and agencies, OGE fosters high ethical standards 

for employees and strengthens the public confidence that the government’s business is conducted 

with impartiality and integrity. OGE’s mission directly supports the President’s goal of 

responsibly governing the Nation.

C. Organizational Structure of OGE 

OGE is led by its Director who is appointed by the President to a five-year term with the 

advice and consent of the Senate. The Director reports to the President and interacts with the 

most senior officials of every agency of the Executive Branch. In addition to leading the 

Executive Branch ethics program, the Director is a member of the Council of Inspectors General 
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for Integrity and Efficiency (CIGIE) and the Integrity Committee of the CIGIE, which reviews 

allegations of misconduct against Inspectors General; he also serves as a member of the 

Administrative Conference of the United States.

In carrying out his responsibilities, the Director is supported by a team of career Senior 

Executives. These include the General Counsel, who also serves as the Principal Deputy 

Director, and Deputy Directors responsible for Executive Branch agency ethics programs, 

international assistance and governance initiatives, and OGE administration. (See Figure 1) At 

the present time, the General Counsel/Principal Deputy Director serves as the Acting Director 

pursuant to the Vacancies Reform Act.

OGE carries out its broad responsibilities with fewer than 80 employees, who are the 

agency’s greatest resource. OGE’s multi-disciplinary staff consists of attorneys, ethics and 

finance experts, information technology professionals, and support staff. OGE leverages its 

human resources and accomplishes its mission through cross-functional teams that can respond 

to changing demands and circumstances. These teams accomplish such diverse tasks as clearing 

potential Executive Branch nominees for possible financial conflicts of interest; training 

Executive Branch ethics officials; issuing regulations and legal and policy guidance; exercising 
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Fiscal Year 2012 Performance and Accountability Report Page 3

oversight of Executive Branch ethics programs; engaging in outreach to domestic and foreign 

audiences; and, supporting U.S. foreign policy anti-corruption and good governance initiatives.

D. Long Term Strategic Goals

OGE’s strategic plan has three major goals. Objectives within each of these strategic 

goals drive the daily work of OGE and form the basis for how the performance of the agency and 

its employees are measured. OGE’s strategic goals and objectives consist of:

o Strengthening Ethical Culture Within the Executive Branch: 

o Improve the Effectiveness of Ethics Policy;

o Enhance Assistance to and Oversight of Agency Ethics Programs;

o Increase Employees’ Awareness of Their Ethics Responsibilities; and,

o Increase OGE’s Focus on Senior Officials’ Roles in Implementing Ethics 

Programs.

o Preventing Conflicts of Interest: 

o Enhance Assistance to the President and the Senate in the Presidential 

Appointment Process;

o Monitor Continued Compliance with Conflict of Interest Laws; and,

o Administer an Effective Confidential Financial Disclosure System.

o Promoting Good Governance: 

o Cooperate with Federal, State, and Local Agencies Implementing Programs 

that Help Support Good Governance;

o Enhance Outreach to the Public and Private Sector, and to Civil Society; and,

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

Initiatives.

OGE’s key fiscal year 2012 accomplishments in furtherance of these objectives and goals are 

discussed in Section II of this report.
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E. Fiscal Year 2012 Budget Priorities

During fiscal year 2012, OGE focused on achieving its long-term strategic goals and 

objectives with four budget priorities:

o Preparing for the influx of new Presidential appointees following the 2012 election;

o Working to modernize government ethics laws, regulations, and programs;

o Harnessing technology to promote transparency, training, and oversight; and,

o Promoting continuity and succession planning in the Executive Branch ethics

program.

F. Performance Measures

OGE measures its progress toward achieving its strategic objectives through a variety of 

sources. These include ethics training surveys, annual ethics program questionnaires, employee 

ethics surveys, and surveys of ethics officials. Over the life of the strategic plan, OGE has 

established and adjusted specific performance targets against which progress is measured. In 

deciding whether to adjust targets upward when performance levels have been met or exceeded, 

OGE balances available resources to meet specific needs, many of which are cyclical in nature. 

Detailed performance objectives and measures are discussed in Part III of this report. 

Every 18 months, OGE conducts a national ethics training conference. The most recent 

training conference was held in 2011; the next is planned for 2014. As preparation for a national 

ethics training conference increases, other training and new training products may decrease. In 

addition, in the first year following a Presidential election, the number of potential Executive

Branch nominees peaks and causes OGE to shift more resources to that function. Finally, OGE 

must be ready to respond to emerging issues, such as those presented by 2012’s STOCK Act. 

Part II – Fiscal Year 2012 Performance Highlights_______________________

OGE achieved significant accomplishments in fiscal year 2012 that directly advanced its 

three, long-term strategic Goals. OGE’s budget priorities for this fiscal year had substantial 

cross-Goal benefits. For example, technology allowed OGE to become more efficient within its

own processes, providing more accurate and timely information to support the agencies’

programs, increasing assistance to the President and the Senate with the Senate appointment 

process, and enhancing OGE’s ability to provide more records to the public in an easily 

accessible fashion.
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A. Strengthening Ethical Culture Within the Executive Branch

A number of the initiatives taken by OGE primarily fell within this Goal as they helped 

improve the effectiveness of ethics policies, provided assistance to and oversight of agency 

ethics programs, increased employees’ awareness of their ethical responsibilities, and focused on 

senior officials’ roles in implementing their agency’s ethics programs. OGE’s performance 

highlights include the following:

o In fiscal year 2012, OGE continued to leverage technology to improve transparency and 

increase efficiency in the Executive Branch ethics program and to enhance training and 

oversight of agency ethics programs. OGE implemented a replacement for its outdated 

and deteriorating Financial Disclosure Tracking System (FDTS), and began development 

of an Agency Information Management System (AIMS) to more effectively track 

interactions with other Executive Branch agencies. OGE enhanced transparency by 

making nominee financial disclosure reports and related documents more readily 

available online. In addition, OGE implemented an internal electronic audit tracking 

system to bring model practices and efficiencies to the review process and to share 

knowledge within OGE. More specifically:

o OGE completed the redesign of FDTS, ensuring that this system will be fully operational 

prior to the 2012 Presidential election. This redesigned web-based application, which 

will import legacy data from the old application, gathers comprehensive information 

about the collection, review, and certification of public financial disclosure reports and 

other covered documents as required by law. The redesigned application includes new 

reporting features that will improve OGE’s processes for monitoring receipt, review, and 

retention of required public financial disclosure reports and related documents following 

the 2012 election.

o In fiscal year 2012, OGE began development of AIMS, a system being designed and 

implemented to better track and manage interactions such as incoming requests for 

guidance and interpretation from over 130 Executive Branch agencies and other 

organizations. The AIMS system will provide OGE officials at all levels instant access to 

ethics program-related information about all Executive Branch agencies. AIMS relies on 

off-the-shelf technology, is on schedule and on budget, and will be operational in fiscal 

year 2013.

o OGE identified and disseminated -- via webinar -- model practices throughout the 

Executive Branch and developed training to prepare the ethics community for an efficient 

and effective post-election period.

o OGE developed an internal electronic audit tracking system to manage the ethics program 

review process.

o OGE implemented a system to allow the public to electronically request, view, and 

download public financial disclosure reports (OGE Form 278 reports) and related 
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documents of PAS nominees and Presidential candidates through its website. This 

system has resulted in a substantial increase in the number of OGE Form 278 reports 

released, and has proven to be an invaluable aid in implementing the STOCK Act. See:

http://www.oge.gov/Open-Government/Presidential-Appointee---Nominee-Records/.

o OGE began posting on its website the semiannual reports of non-Federal source travel 

payments accepted by agencies under the authority of 31 U.S.C. § 1353. The new 

process allows for immediate public access to the reports, thus increasing transparency 

and improving the efficiency with which OGE provides customer service. See: 

http://www.oge.gov/Open-Government/Travel-Reports/Travel-Reports/.

o OGE began posting Executive Branch ethics programs reviews. As a result, over 100 

reports -- some going back as far as 1982 -- are publicly available on the OGE website. 

See: 

http://www.oge.gov/Program-Management/Program-Review/Program-ReviewReports/Program-Review-Reports/.

o OGE created a new Freedom of Information Act (FOIA) web page on its website, and 

continues to have a 100 percent on-time FOIA response rate. 

See: http://www.oge.gov/DisplayTemplates/SectionIndex.aspx?id=47.

o In collaboration with the Office of Management and Budget (OMB) and the entire 

Executive Branch ethics community, OGE developed a centralized system through which 

each agency can electronically upload and publish to a database the approximately 

28,000 financial disclosure reports that are required to be publicly available on the 

internet pursuant to the STOCK Act.

o To meet the STOCK Act requirement of Executive Branch-wide electronic public 

financial disclosure by October 2013, OGE evaluated existing Executive Branch e-filing 

systems and prepared a detailed summary of the technological requirements necessary to 

develop, implement, and maintain electronic filing and a publicly searchable, sortable, 

and downloadable financial disclosure system.

o OGE developed and delivered on-demand and live instructor-led courses directed at 

ethics officials, IG staff, and Executive Branch employees, including a self-paced tutorial 

for filers of periodic financial transaction reports; these were viewed more than 700 times 

in the first month of availability. See: http://www.oge.gov/Financial-Disclosure/PublicFinancial-Disclosure-278/Nominee-and-New-Entrant-278-Guide/Nominee---NewEntrant-278-Guide/, a new, live monthly series of webinars for advanced ethics 

practitioners highlighting topics of common concern and sharing agency experiences and 

information, and instructor-led courses -- 71 in total -- including a series of courses for 

senior ethics officials on election year preparedness and OGE’s well-received New Ethics 

Official Certification Program.

o OGE continued in its leadership of the ethics community by prioritizing and promoting 

continuity and succession planning in the overall Executive Branch ethics program. This 
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priority includes activities to ensure key positions in the Administration are filled and the 

Executive Branch ethics program continues to develop capacity. For most PAS 

nominees, OGE’s financial disclosure program represents their first introduction to the 

ethics requirements of the Executive Branch. OGE continues to work closely with 

nominees as well as with the ethics officials from their prospective agencies to ensure 

compliance with all financial disclosure and conflict of interest requirements. These 

early interactions helped to stress the importance of a conflict-free government workplace 

and ensure that new appointees understand the importance of the Executive Branch ethics 

program.

o In fiscal year 2012, due to the ongoing appointment of officials to vacant positions and 

routine turnover of senior leaders, OGE personnel reviewed and certified almost 200 

public financial disclosure reports of PAS nominees. These reviews involved the 

resolution of financial disclosure issues and the negotiation of ethics agreements, and are 

in addition to its review and certification of approximately 1,100 annual and termination 

financial disclosure reports of PAS appointees.

o OGE worked with the Federal Election Commission regarding the review of public 

financial disclosure reports of Presidential and Vice Presidential candidates to ensure that 

candidates received OGE assistance regarding the requirements to prepare their financial 

disclosure reports. OGE also made these reports available to the public.

o OGE completed compliance reviews and follow-up monitoring for more than 50 

Executive Branch agencies, focusing on three general areas: micro agencies (agencies 

with 11-100 full-time employees), cabinet agencies, and post-election readiness. These 

statutorily mandated oversight activities were enhanced through the use of 

questionnaires, on-site reviews, and follow-up activities. Ongoing monitoring by OGE 

ensured that agency programs complied with regulatory requirements, documented 

essential processes and procedures, and provided support to Federal employees.

o OGE assisted two new agencies in creating ethics programs, and detailed employees to

train ethics officials and employees, establish financial disclosure policies and 

procedures, provide advice and counsel to employees, deploy an electronic financial 

disclosure filing and review system, and conduct reviews of public and confidential 

financial disclosure reports. OGE also assisted in establishing networks of support with 

established ethics programs at other agencies.

o In fiscal year 2012, OGE implemented a new model to provide day-to-day support to 

ethics programs in over 130 Executive Branch agencies. In addition to enhancing

customer service, the new team model supports OGE’s succession training objectives by 

having newer ethics specialists work directly with senior OGE experts and by creating 

“team lead” positions for more experienced personnel to develop their leadership skills.

o OGE expanded its new ethics official certificate program, a “boot camp” for those new to 

the practice of ethics. Participants learn to apply relevant ethics authorities to a series of 

critical tasks, assess and discuss the importance of effective processes in the management 
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of an ethics program, and use the tools and resources critical to practicing ethics officials. 

The program now includes two more certificate programs within the core curriculum of 

introductory classes.

B. Preventing Conflicts of Interest

OGE plays an important role in the process of filling positions that require 

Presidential appointment with Senate confirmation through its review of Presidential nominee 

financial disclosure reports for potential conflicts of interest. In the period following a 

Presidential election, substantial changes in senior leadership within agencies occurs regardless 

of the outcome of an election, To prepare for its role in assisting the White House and all 

Executive Branch agencies following the 2012 election, OGE undertook three key initiatives to 

prepare for the increased volume of financial disclosure reports: (1) creating a web-based, plain 

English guide for financial disclosure filers; (2) increasing financial disclosure training for OGE 

and Executive Branch agency ethics officials; and, (3) conducting focused ethics program 

reviews of agencies to ensure their readiness for the post-election period. Key fiscal year 2012 

accomplishments include:

o OGE conceptualized, designed, and implemented a web-based, plain English guide to 

educate and assist senior officials required to complete public financial disclosure reports. 

This user-friendly tool will reduce or eliminate the most common errors found in 

financial disclosure reports while allowing for a more efficient and effective means for 

senior officials to complete the financial disclosure report, better assuring potential 

conflicts are discovered before they become problematic. By updating its manual and 

templates used by agency ethics officials to draft nominee ethics agreements, OGE has 

provided agency ethics officials with the means to expedite the completion and 

submission of the required agreement. Both of these efforts will result in a reduction of 

the time it takes filers and reviewers to complete the financial disclosure part of the 

nominee clearance process.

o To carry out its Executive Branch-wide mission with fewer than 80 FTEs, OGE employs

a multi-functional professional workforce. In fiscal year 2012, many staff members were 

redirected from other non-election year duties to undertake extensive nominee financial 

disclosure training, directly enhancing the ability to identify and resolve potential conflict 

issues. This training was reinforced by hands-on experiential learning through 

assignment of pending nominee financial disclosure reports.

o To help agencies prepare for new nominees, OGE provided intensive election-year 

focused nominee financial disclosure training to nearly 300 ethics officials across the 

Executive Branch. OGE also provided increased training to help agency ethics officials 

deal effectively with legal and programmatic issues related to appointees leaving 

government, including rules governing seeking employment and limits on postgovernment employment activities. OGE provided training to selected agencies focusing 

on the unique role that leadership plays in establishing and maintaining an ethical 

organizational culture, and in promoting professional integrity among employees. The 

training facilitated a dialogue about the importance of promoting the obligations of public 
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service and of having those obligations inform the day-to-day processes and decisionmaking of the agency.

o OGE completed a targeted assessment of post-election readiness of the Departments of 

Justice, Treasury and State. These three agencies account for nearly 40 percent of all 

Senate-confirmed Executive Branch positions. Specifically, OGE determined current 

capabilities and future planning related to their financial disclosure report processes and 

identified potential vulnerabilities that could impair the ability of agency ethics officials 

to conduct timely, accurate, and consistent conflict of interest reviews. This assessment 

provided guidance to agency leadership and ethics officials about better ways to structure 

and execute ethics programs to provide even more effective service to PAS nominees. It 

also reinforced the essential elements of a successful ethics program -- namely, 

succession planning, specific and continuous training, and a program structure ensuring

accountability.

o OGE continued its ongoing work to modernize government ethics laws, regulations, and 

programs. OGE dealt effectively with changes it initiated as well as unexpected challenges 

such as the STOCK Act. 

o On April 4, 2012, the President signed the STOCK Act into law, establishing, through 

amendments to EIGA, significant new requirements for the Executive Branch ethics 

program, ethics officials, and the thousands of Federal officials who file publicly 

available financial disclosure reports. During the course of legislative debate on the 

STOCK Act, OGE responded to more than 65 requests for technical assistance from 

congressional committee staffs and members, and has continued to provide 

significant assistance since enactment of the law.

o Immediately following enactment, OGE began its preparations to implement the 

STOCK Act’s extensive and unprecedented requirements -- a process that affected 

and drew upon all OGE’s programs and most of its staff. Within a week of its 

enactment, OGE provided policy guidance to the ethics community regarding 

reporting requirements for periodic financial transactions, mortgages on personal 

residences, post-employment negotiations and arrangements for future employment, 

and posting of financial disclosure reports. OGE also engaged Designated Agency 

Ethics Officials (DAEOs) in numerous face-to-face meetings and teleconferences to 

assess and address issues raised by the new law. With technical support from OMB, 

OGE also lead weekly conference calls with more than 100 agencies to address the 

Act’s requirements for web posting of public financial disclosure reports. 

Additionally, OGE created training tools for ethics professionals and filers regarding 

the STOCK Act requirements and established procedures to facilitate technical 

review of the periodic financial transaction reports required of public filers. Finally, 

OGE developed a framework and cost estimate to accomplish the Act’s mandate of 

Executive Branch electronic financial disclosure report filing in fiscal year 2014.

o OGE continued implementation of the President’s Executive Order on Ethics (E.O. 

13490) by publishing a proposed rule amending the Standards of Conduct to extend 
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the lobbyist gift ban to all Executive Branch employees and by publishing the third 

annual report to the President on compliance with and implementation of the 

Executive Order.

o OGE published final rules to make qualified trusts more accessible. Such trusts may 

be established by Executive Branch employees to avoid financial conflicts of interest. 

OGE also published a proposed final rule to streamline the process for authorizing 

official participation of Executive Branch employees on the boards of scientific, 

technical, and other nonprofit organizations that are relevant to an agency’s interests.

o In fiscal year 2012, OGE implemented a new service delivery model to provide dayto-day support to ethics programs in over 130 Executive Branch agencies. By relying 

upon teams of ethics specialists rather than individual points of contact, OGE is able 

to more effectively provide advice, training, oversight, and consultative monitoring.

o OGE continued the benchmarking program reviews it began in fiscal year 2009, 

focusing on regulatory agencies in 2012. These reviews are provided as a service to 

senior leaders and DAEOs to help them compare their ethics programs with similarly 

situated agencies, assess potential vulnerabilities, chart and measure improvements, 

and share model practices used in other agencies.

C. Promoting Good Governance

OGE continues to engage and cooperate with Federal, state, and local agencies whose

programs support good governance (integrity, accountability, predictability, transparency and 

rule of law); to enhance its communications with the public, particularly through the use of its 

enhanced website and the opportunities it provides to achieve greater transparency; to take 

advantage of mutually beneficial opportunities to interact with the private sector and good 

governance groups; and, to support significant U.S. foreign policy anti-corruption and good 

governance initiatives. Key fiscal year 2012 accomplishments include:

o OGE developed and tested ethics-related questions for use in the Office of Personnel 

Management’s Federal Employee Viewpoint Survey. These questions will promote 

employee awareness of ethics-related requirements, benchmark perceptions of ethical 

culture within agencies, and underscore senior leaders’ responsibilities for agency ethics 

programs.

o OGE continued to support programs and activities of Inspectors General (IGs). The 

Acting Director actively participated as a member of the Council of the Inspectors 

General on Integrity and Efficiency (CIGIE) as well as the CIGIE Integrity Committee, 

which examines allegations of misconduct against IGs and their direct reports.

o OGE instructors provided multiple training sessions at the Inspector General Criminal 

Investigator Academy (IG Academy). This training on investigating ethics-related 

matters and working with ethics officials has become a standard part of the IG 
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Academy’s curriculum, and complements a web-based training module that OGE 

developed for IG investigators.

o OGE experts provided direct support to IG investigators and Federal prosecutors in 

numerous cases on the interpretation and application of the conflict of interest laws and 

ethics rules, and also worked with agency IGs and DAEOs in two agencies on 

organizational changes to better balance IG independence with strong DAEO support.

o In addition to its numerous responses to congressional inquiries on the STOCK Act, OGE 

responded to over 60 additional requests for technical assistance to the Congress on 

issues ranging from financial disclosure and the nomination process to post employment, 

gifts, and outside positions. Thus, OGE provided over 125 instances of assistance to 

Congress in fiscal year 2012, successfully fulfilling its responsibility to promptly reply to 

congressional requests within OMB guidelines.

o OGE collaborated with the most senior ethics practitioners from all three branches of 

Government to meet on issues of common interest, build professional networks, and 

improve ethics across the Federal Government. Participants of this OGE-initiated 

consortium exchanged information and discussed their experiences on key topics of 

common interest. The relationships and understandings that these meetings produced 

benefitted OGE during recent legislative and implementation efforts.

o OGE exchanged good governance practices and learning experiences with state and local 

government entities, international organizations, domestic agencies and organizations, 

and non-profit and business communities. OGE benefitted from support and exchange of 

effective ethics and integrity programs; for example, OGE drew on the research of the 

Organization for Economic Co-operation and Development (OECD) in the area of 

integrity modules to improve its evaluation metrics.

o The Department of State specifically requested senior OGE officials to represent the U.S.

in fulfilling U.S. obligations under the three most robust, multi-disciplinary mutual 

evaluation mechanisms of three international agreements. OGE provided evaluators for 

the 1st round U.S. review of Australia as part of the obligations under the United Nations 

Convention Against Corruption (UNCAC); took the lead in representing the U.S. in its 

3rd round review by the Group of States Against Corruption (GRECO); and served as one 

of the first evaluators for the first site visit evaluations for the Inter-American Convention 

Against Corruption’s Mechanism for Follow-Up on Implementation of the InterAmerican Convention Against Corruption (MESICIC). Outside the individual country 

reviews, an OGE official served as the head delegate to the GRECO and a delegate to the 

Implementation Review Group of the UNCAC. As evidence of OGE’s valued expertise

in this area, a senior OGE official was asked to help train the evaluators for the GRECO 

4th round.

o Again, at the specific request of the State Department and with financial assistance for 

travel, OGE represented the U.S. at anti-corruption and good governance meetings of 

international organizations of which the U.S. is a member. These organizations included
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the United Nations Office on Drugs and Crime, the Council of Europe’s Group of States 

Against Corruption, the Organization of Economic Co-operation and Development, the 

U.S.-China Joint Liaison Group, and the Asia-Pacific Economic Cooperation (APEC). 

The State Department’s satisfaction with OGE’s performance in this area is evidenced by 

its continued reliance on OGE experts and its funding through OGE’s reimbursable 

account for OGE’s travel and program materials used for this purpose.

o In helping to add to practical, internationally useful tools for corruption prevention and 

good governance, OGE produced or took the lead in developing a number of wellreceived projects this fiscal year. Significantly, OGE took the lead in helping APEC 

develop Principles for Financial/Asset Disclosure by Public Officials. Subsequently, 

those same Principles were endorsed by the G-20 -- the leaders, finance ministers, and 

central bank governors from 20 major economies. It designed and compiled the U.S.

submission to the UNCAC prevention working group on effective methods for raising 

awareness of programs that address a variety of topics the UNCAC Chapter on 

Prevention addresses, with links to the websites of a number of U.S. agencies where 

those programs could be found. And in conjunction with a presentation on using 

financial disclosure to help prevent conflicts of interest, OGE produced a short 

informative paper and provided it to the working group in the six UN languages. Finally,

it provided a case study on evidence-based evaluation to the OECD Public Sector 

Integrity Network. All of these products were also posted on the international section of 

OGE’s website.

o OGE also continued to respond to requests from the State Department and from 

individual embassies to provide more tailored assistance on incorporating corruption 

prevention and integrity measures into anticorruption and good governance initiatives. 

For example, OGE personnel participated in multi-day programs in Hungary and Serbia,

and in at the conference of the Anti-Corruption Network for Eastern Europe and Central 

Asia held in Kazakhstan.

o At the request of U.S. foreign policy agencies, OGE engaged in consistently wellreceived, mutually beneficial discussions with representatives of good governance 

programs throughout the world. OGE met in Washington with 51 foreign delegations

totaling 517 persons from 75 countries. OGE also addressed foreign audiences outside 

the U.S. which significantly increased the number of foreign countries represented.

D. Focusing on OGE’s People and Internal Operations

To meet the long-term goals in its strategic plan, OGE strives to be a model agency in all 

respects. During fiscal year 2012, OGE continued to focus on key internal management 

challenges, refining the agency’s internal processes to cut costs, better manage agency resources, 

and provide the highest quality administrative and IT support to OGE’s people and mission. A 

few of OGE’s major internal achievements this fiscal year include:

o In fiscal year 2008, OGE instituted a student intern program that now operates throughout 

the year; 12 students interned at OGE during fiscal year 2012. This program exposes 
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students to service in the Executive Branch and increases OGE’s and other agencies’ 

abilities to recruit highly qualified talent, contributing to succession planning in the ethics 

field. The success of this program can be measured by the fact that three former interns 

were hired as junior attorneys at OGE by the end of fiscal year 2012. By selecting from a 

pool of former interns who have experienced OGE’s existing programs and culture, OGE 

decreased dramatically the time required to fill critical vacancies and select from the most 

highly qualified persons available.

o OGE dedicated significant resources to internal cross-training in order to promote 

continuity and succession planning within OGE. For instance, an intra-office detail of 

staff from OGE’s international assistance program to the agency program section not 

only enhanced OGE’s ability to provide international technical assistance, it also 

provided personnel to the agency program section during a time of staff turnover. This 

cross-training of staff gives OGE the flexibility to shift personnel resources in the future, 

as may be needed.

o OGE management supported employees’ professional development goals during fiscal 

year 2012. OGE used a variety of methods to accomplish this, including details to other 

agencies and the White House; entering into a partnership with the Treasury Executive 

Institute for access to GS-14, GS-15, and SES professional development programs;

manager specific training; personality/managerial assessment; diversity and inclusion 

programs; and coaching. OGE also hosted several OGE staff-developed Issue Forums to 

keep its employees abreast of developments in ethics laws and emerging issues.

Part III – Management Discussion & Analysis of Results__________________

This section provides data on OGE’s success in achieving its strategic goals and 

performance objectives. The following measurements are based on statistical data from a variety 

of existing sources, including ethics training surveys, annual ethics program questionnaires, 

employee ethics surveys, and surveys of ethics officials.

A. Strategic Goal 1 – Strengthening Ethical Culture within the Executive Branch

o Objective 1.1: Improve the Effectiveness of Ethics Policy 

OGE continues to earn high marks from ethics officials for providing guidance to 

improve the effectiveness of ethics policy. OGE’s assessment of agency ethics officials’ 

customer satisfaction focused on three areas: 

o Usefulness of ethics policy guidance;

o Effectiveness of ethics policy guidance; and,

o Responsiveness to emerging ethics program issues.
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Fiscal Year 2012 Performance and Accountability Report Page 14

The results related to Objective 1.1 performance measures again met OGE targets. (See 

Figure 2)

Objective 1.2: Enhance Assistance to and Oversight of Agency Ethics Programs

OGE reviews agency ethics programs to identify and report on strengths and weaknesses 

and to share model practices. In fiscal year 2012, OGE completed compliance reviews and 

follow-up monitoring for more than 50 Executive Branch agencies, focusing on three general 

areas: micro agencies (agencies with 11-100 full-time employees), cabinet agencies, and postelection readiness. In addition, OGE continues to devote considerable resources to training 

ethics officials. In fiscal year 2012, OGE provided training to over 1,200 ethics officials and 

other employees (e.g., Inspectors General). Of these many participants, survey respondents

overwhelmingly indicated that OGE’s training was well organized, that respondents were better 

equipped to do their job because of the training, and that they were inspired to continue working 

in the field of ethics as a result of the training. The results of these efforts to advance Objective 

1.2 are illustrated below. (See Figure 3) 
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o Objective 1.3: Increase Employees’ Awareness of Their Ethics Responsibilities 

In view of significant new responsibilities undertaken as a result of drafting and 

implementation of the Stock Act, in fiscal year 2012 OGE substantially shifted resources. In 

particular, OGE de-emphasized the priority of providing education and training products for 

employees, which explains the decrease in agencies responding satisfaction with products and 

the extent to which agencies incorporated these products into their programs. OGE did 

continue to provide training to agency ethics officials to assist them in carrying out their 

responsibilities. As shown in Figure 4, ethics officials were overwhelmingly satisfied with the 

OGE-provided training and continued to incorporate OGE products into their training programs. 

(See Figures 4 and 5)
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o Objective 1.4: Increase OGE’s Focus on Senior Officials’ Roles in Implementing 

Ethics Programs

OGE recognizes that commitment and action by agency leadership is the keystone for

establishing an agency’s ethical culture and for fostering public confidence in the decisionmaking processes of government. OGE reinforces the critical role of agency leadership through 

its program reviews and, when appropriate, makes recommendations to improve the overall 

ethics program. (See Figures 6 and 7)
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B. Strategic Goal 2 – Preventing Conflicts of Interest

o Objective 2.1: Enhance Assistance to the President and the Senate in the Presidential 

Appointment Process

In coordination with agency ethics officials, OGE monitors the timeliness of employee 

compliance with ethics agreements through documentation received by agency ethics officials. 

In fiscal year 2012, 96 PAS officials entered into ethics agreements that required compliance 

documentation. As reported by DAEOs, 97 percent of ethics agreements were satisfied within 

statutory deadlines. Additionally, OGE measures the resolution of conflicts and technical 

reporting issues for nominee financial disclosure reports. OGE’s established standard is to 

finalize conflict resolution and technical issues no later than five days after a nomination is 

made. The figure below illustrates the results of OGE’s efforts to further Objective 2.1. (See 

Figure 8)
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o Objective 2.2: Monitor Continued Compliance with Conflict of Interest Laws; and

Objective 2.3: Administer an Effective Confidential Financial Disclosure System

Financial disclosure promotes public confidence. Through monitoring and oversight, 

OGE ensures that agencies have implemented effective financial disclosure processes. 

Specifically, as part of the OGE review process, it ensures that agencies provide public filers with 

feedback after reports have been reviewed and that agencies have written procedures for 

following up with delinquent filers. In fiscal year 2012, OGE met its targets. (See Figure 9)

In furtherance of Objectives 2.2 and 2.3, OGE continued to encourage agencies to 

use alternative procedures for handling confidential financial disclosure. Appropriate 

implementation of alternative procedures promotes efficient allocation of ethics program 

resources and allows agencies to focus resources on other important program objectives, 

including leadership support, succession planning, training, awareness building, and selfassessment. OGE also assessed whether confidential filers have filed their reports by the end of 

the reporting period to ensure that potential conflicts identified on the reports are resolved in a 

timely manner. The following two charts show continued positive results. (See Figures 10 and 

11)
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C. Strategic Goal 3 – Promoting Good Governance

o Objective 3.1: Increase OGE’s Support of and Cooperation with Federal, State, and 

Local Agencies Implementing Programs that Help Support Good Governance

As part of its strategic goals, OGE actively coordinates and cooperates with other 

Federal, state, and local government agencies that have complementary missions and programs 

in promoting integrity, accountability, predictability, and transparency of government. To the 

extent that it can quantify the usefulness of individual interactions depends to a certain degree on 

the nature of the interaction. OGE, in judging the usefulness of its actions to others, evaluates 

usefulness by actual surveys or through written notes from those with whom OGE interacts. For 

some types of interactions, such as presentations to FACA committee managers or the IG 

Academy, recurrent requests for OGE’s participation is an indication of the usefulness of the 

program to those audiences. More importantly, OGE’s interaction with other Federal and state 

and local agencies quite often provides OGE with useful ideas and good practices.
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During this fiscal year, OGE exceeded its target goals for programs and projects with 

other Federal, state, and local agencies both in terms of numbers and in terms of usefulness. 

Highlights of those programs and projects are set forth in part II, subsection C of this report.

OGE also continued to engage the state and local ethics community, primarily through 

the Council on Governmental Ethics Laws (COGEL), an organization of Federal, state, and local 

government agencies whose responsibilities include ethics, campaign finance, freedom of 

information, and lobbying disclosure. As in the past, OGE used COGEL’s annual conference to 

share and learn good practices -- from both domestic and international sources.

o Objective 3.2: Enhance Outreach to the Public, Private Sector, and Good Governance 

Groups

As is the case for any entity, a public-facing website is one of the most significant 

methods of outreach to the general public. Leveraging OGE’s new website, and in support of a 

budget priority to harness technology to promote transparency, a number of newly-created and 

existing agency documents as well as financial disclosure reports of Presidential appointees --

documents of high public interest -- were posted on or made more readily available through the

website. 

OGE also continued its engagement with the private sector, primarily through its 

continued relationships with the Ethics Resource Center and the Ethics and Compliance Officer 

Association, as well as with non-governmental organizations that focus on good government

issues, academic institutions, and bar associations. Because of increased activities associated 

with post-election readiness training and the STOCK Act, OGE’s interactions decreased slightly 

from the prior fiscal year; however, OGE still met performance targets. OGE’s engagements

continued to receive positive responses from those with whom it interacted. 

27 (A)

13 (T)

0

10

20

30

FY 07 FY 08 FY 09 FY 10 FY 11

#

Outreach Activities with Federal, State, and Local Entities Figure 12.

Target (T)

Actual (A)
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o Objective 3.3 Support U.S. Foreign Policy Anti-corruption and Good Governance 

Initiatives

This past fiscal year, OGE continued to receive and fulfill increasing requests to 

participate in substantial programs and projects that help support U.S. foreign policy anticorruption and good governance initiatives. OGE has met those requests both to the articulated 

appreciation of U.S. foreign policy agencies as well as with continued financial resources to 

cover the expenses of international travel and engagement. At the same time, these projects 

often broaden the appreciation of OGE’s own staff to the value of being able to articulate the 

basic principles behind effective integrity programs.

Examples of the types of international programs in which OGE has been asked to 

participate are found in Part IIC. However, many of the projects and programs in which OGE 

participates arise because OGE has consistently been requested to represent the U.S. Government 

at the following international fora and working groups and has become well-known not only 

within the U.S. Government, but also outside for the quality of its services:

o United Nations (UN): the UN Convention Against Corruption (UNCAC) 

Implementation Review Group and the UNCAC Working Group on Prevention;

o Council of Europe: the Group of States Against Corruption (GRECO);

o Asia-Pacific Economic Corporation (APEC): the Anti-Corruption and 

Transparency Working Group;

o Organization for Economic Co-operation and Development (OECD): the Public 

Governance Directorate Network on Public Sector Integrity; the Anti-Corruption 

Network for Eastern Europe;

18 (A)

15 (T)

0

10

20

FY 07 FY 08 FY 09 FY 10 FY 11

#

Outreach Activities with Public, Private Sector, 

and Good Governance Groups

Figure 13.

Target (T)

Actual (A)
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o Organization of American States (OAS): the follow-up mechanism of the InterAmerican Convention Against Corruption (MESICIC); and,

o U.S.-China Joint Liaison Group: the Anti-Corruption Working Group.

Several of the inter-governmental organizations noted above administer peer review 

mechanisms designed to evaluate the progress of members in meeting anti-corruption 

obligations. Based on the quality of their previous services as evaluators, OGE officials were 

again requested to participate as evaluators in every instance when the topics were generally 

related to good governance, not just the implementation of programs such as those carried out by 

OGE. In fiscal year 2012, this included evaluations carried out by the three most robust 

mechanisms. Significantly as well, the State and Justice Departments asked an OGE Deputy 

Director to lead the U.S. review by GRECO which culminated in this fiscal year. That same 

individual was asked by GRECO to help train evaluators from member countries for its 4th round 

on corruption prevention for members of parliament, judges, and prosecutors.

OGE continued to provide international technical assistance briefings to foreign officials 

from the public and private sector traveling under the auspices of the State Department 

International Visitor Leadership Program or other similar programs, a mainstay of OGE’s

international program. This past fiscal year, 52 delegations comprised of 571 individuals 

representing 73 countries came to OGE to learn about the ethics program in the Executive 

Branch and how that program fits into the broader rubric of good governance principles. Results 

of written participant surveys demonstrate that: (1) 100 percent of the participants thought the 

presentation helped them understand the role of OGE and how the Executive Branch ethics 

program works, and (2) 97 percent believed that the presentation helped them understand the 

larger role of transparency and accountability in the Executive Branch. 

Adding to the number of countries represented by participants from briefings in 

Washington are those individuals who have been in audiences where OGE has made 

presentations outside of the U.S. The map below shows the total of both countries in green.
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In fiscal year 2012, OGE provided some form of technical assistance in support of U.S. foreign 

policy interests to the countries highlighted in green.
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Part V – Financial Statements & Independent Auditor’s Report____________

Limitations of the Financial Statements

OGE’s principal financial statements have been prepared to report its financial position 

and results of operations, pursuant to the requirements of 31 U.S.C. § 3515 (b). While the 

statements have been prepared from the books and records of OGE, in accordance with generally 

accepted accounting principles for federal entities and the formats prescribed by OMB, the 

statements are in addition to the financial reports used to monitor and control budgetary 

resources, which are prepared from the same books and records. These statements should be 

read with the realization that they are for a component of the United States Government, a 

sovereign entity.
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UNITED STATES OFFICE OF GOVERNMENT ETHICS

NOTES TO THE FINANCIAL STATEMENTS

NOTE 1. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES

A. Reporting Entity

The United Sates Office of Government Ethics (USOGE), established by the Ethics in 

Government Act of 1978, provides overall direction, oversight, and accountability of Executive 

Branch policies designed to prevent and resolve conflicts of interest. Specifically, USOGE 

promulgates and maintains enforceable standards of ethical conduct for nearly four million 

civilian employees and uniformed service members in over 130 Executive Branch agencies and 

the White House; overseeing a financial disclosure system that reaches 28,000 public and nearly 

325,000 confidential financial disclosure filers; providing direct education and training products 

to 5,700 ethics officials; conducting outreach to the general public, the private sector and civil 

society; and sharing good practices with and providing technical assistance to state, local, and 

foreign governments and international organizations. 

USOGE’s greatest resource is its multi-disciplinary staff of attorneys, ethics and finance experts, 

and support staff. USOGE leverages its human resources by organizing cross-functional teams to 

perform such diverse tasks as reviewing the financial disclosure reports of Senate-confirmed, 

Presidential appointees for financial conflicts of interest, training Executive Branch ethics 

officials, and enhancing oversight of Executive Branch ethics programs. By necessity, USOGE’s 

multi-disciplinary staff must be flexible in order to identify and respond to emerging needs 

within the ethics community and the Government as a whole.

General Funds are accounts used to record financial transactions arising under congressional 

appropriations or other authorizations to spend general revenues. General Fund Miscellaneous 

Receipts are accounts established for receipts of non-recurring activity, such as fines, penalties, 

fees and other miscellaneous receipts for services and benefits. 

USOGE has rights and ownership of all assets reported in these financial statements. USOGE 

does not possess any non-entity assets.

B. Basis of Presentation

The financial statements have been prepared to report the financial position and results of 

operations of USOGE. The Balance Sheet present the financial position of the agency. The 

Statement of Net Cost present the agency’s operating results; the Statement of Changes in Net 

Position displays the changes in the agency’s equity accounts. The Statement of Budgetary 
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Resources present the sources, status, and uses of the agency’s resources and follow the rules for 

the Budget of the United States Government.

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 USOGE in accordance 

with the hierarchy of accounting principles generally accepted in the United States of America, 

standards issued by the principals of the Federal Accounting Standards Advisory Board 

(FASAB), OMB Circular A-136, Financial Reporting Requirements and USOGE 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 USOGE's use of 

budgetary resources. The financial statements and associated notes are presented on a 

comparative basis. Unless specified otherwise, all amounts are presented in dollars. 

C. 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.

D. Fund Balance with Treasury

Fund Balance with Treasury is the aggregate amount of USOGE’s funds with Treasury in 

expenditure, receipt and revolving fund accounts. Appropriated funds recorded in expenditure 

accounts are available to pay current liabilities and finance authorized purchases. 

USOGE does not maintain bank accounts of its own, has no disbursing authority, and does not 

maintain cash held outside of Treasury. Treasury disburses funds for the agency on demand.

E. Accounts Receivable

Accounts receivable consists of amounts owed to USOGE by other Federal agencies and the 

general 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, 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. 

F. Property, Equipment, and Software

Property, equipment and software represent furniture, fixtures, equipment, and information 

technology hardware and software which are recorded at original acquisition cost and are 

depreciated or amortized using the straight-line method over their estimated useful lives. Major 

alterations and renovations are capitalized, while maintenance and repair costs are charged to 

expense as incurred. USOGE's capitalization threshold is $50,000 for individual purchases and 
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$500,000 for bulk purchases. Applicable standard governmental guidelines regulate the disposal 

and convertibility of agency property, equipment, and software. 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

Software 5

G. 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.

H. Liabilities

Liabilities represent the amount of funds likely to be paid by USOGE as a result of transactions 

or events that have already occurred.

USOGE reports its liabilities under two categories, Intragovernmental and With the Public. 

Intragovernmental liabilities represent funds owed to another government agency. Liabilities 

With the Public represents funds owed to any entity or person that is not a federal agency, 

including private sector firms and federal employees. Each of these categories may include 

liabilities that are covered by budgetary resources and liabilities not covered by budgetary 

resources.

Liabilities covered by budgetary resources are liabilities funded by a current appropriation or 

other funding source. These consist of accounts payable and accrued payroll and benefits. 

Accounts payable represent amounts owed to another entity for goods ordered and received and 

for services rendered except for employees. Accrued payroll and benefits represent payroll costs 

earned by employees during the fiscal year which are not paid until the next fiscal year.

Liabilities not covered by budgetary resources are liabilities that are not funded by any current 

appropriation or other funding source. These liabilities consist of accrued annual leave and 

actuarial FECA. 

I. 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 
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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. Non-vested 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 

OPM upon the retirement of that individual. Credit is given for sick leave balances upon the 

retirement of Federal Employee’s Retirement System (FERS) covered employees effective at 

50% beginning FY 2010 and 100% in FY 2014.

J. Accrued and Actuarial Workers’ Compensation

The Federal Employees' Compensation Act (FECA) administered by the U.S. Department of 

Labor (DOL) addresses all claims brought by USOGE employees for on-the-job injuries. The 

DOL bills each agency annually as its claims are paid, but payment of these bills is deferred for 

two years to allow for funding through the budget process. Similarly, employees that USOGE 

terminates without cause may receive unemployment compensation benefits under the 

unemployment insurance program also administered by the DOL, which bills each agency 

quarterly for paid claims. 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.

K. Retirement Plans

USOGE employees participate in either the CSRS or the FERS. The employees who participate 

in CSRS are beneficiaries of USOGE’s matching contribution, equal to seven percent of pay, 

distributed to their annuity account in the Civil Service Retirement and Disability Fund.

Prior to December 31, 1983, all employees were covered under the CSRS program. From 

January 1, 1984 through December 31, 1986, employees had the option of remaining under 

CSRS or joining FERS and Social Security. Employees hired as of January 1, 1987 are 

automatically covered by the FERS program. FERS offers a savings plan to which USOGE 

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

additional four percent of pay. For FERS participants, USOGE also contributes to 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, USOGE remits the employer's share 

of the required contribution.

USOGE 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 communicate these factors to 

USOGE for current period expense reporting. OPM also provides information regarding the full 

cost of health and life insurance benefits. USOGE recognized the offsetting revenue as imputed 

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

L. Other Post-Employment Benefits

USOGE employees eligible to participate in the Federal Employees' Health Benefits Plan 

(FEHBP) and the Federal Employees' Group Life Insurance Program (FEGLIP) may continue to 

participate in these programs after their retirement. The OPM has provided USOGE with certain 

cost factors that estimate the true cost of providing the post-retirement benefit to current 

employees. USOGE recognizes a current cost for these and Other Retirement Benefits (ORB) at 

the time the employee's services are rendered. The ORB expense is financed by OPM, and offset 

by USOGE through the recognition of an imputed financing source. 

M. Use of Estimates

The preparation of the accompanying financial statements in accordance with generally accepted 

accounting principles requires management to make certain estimates and assumptions that affect 

the reported amounts of assets, liabilities, revenues, and expenses. Actual results could differ 

from those estimates. 

N. 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. 

USOGE recognized imputed costs and financing sources in fiscal years 2012 and 2011 to the 

extent directed by OMB.

O. Reclassification

Certain fiscal year 2011 balances may have been reclassified, retitled, or combined with

other financial statement line items for consistency with current year presentation.
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NOTE 2. FUND BALANCE WITH TREASURY

Fund balance with Treasury account balances as of September 30, 2012 and 2011 were as 

follows:

2012 2011

Fund Balances:

Appropriated Funds $ 2,461,083 $ 2,999,955 

Total $ 2,461,083 $ 2,999,955 

Status of Fund Balance with Treasury:

Unobligated Balance

 Available $ 200,306 $ 114,166 

 Unavailable 252,027 419,445 

Obligated Balance Not Yet Disbursed 2,008,750 2,466,344 

Total $ 2,461,083 $ 2,999,955 

No discrepancies exist between the Fund Balance reflected on the Balance Sheet and the 

balances in the Treasury accounts.

The available unobligated fund balances represent the current-period amount available 

for obligation or commitment. At the start of the next fiscal year, this amount will 

become part of the unavailable balance as described in the following paragraph.

The unavailable 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 obligated balance not yet disbursed includes accounts payable, accrued expenses, 

and undelivered orders that have reduced unexpended appropriations but have not yet 

decreased the cash balance on hand. (See also: Note. 13)
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NOTE 3. ACCOUNTS RECEIVABLE, NET

Accounts receivable balances as of September 30, 2012 and 2011 were as follows:

2012 2011

Intragovernmental

Accounts Receivable $ 53,371 $ 17,361

Total Intragovernmental Accounts Receivable $ 53,371 $ 17,361

With the Public

Accounts Receivable $ 352 $ -

Total Public Account Receivable $ 352 $ -

Total Accounts Receivable $ 53,723 $ 17,361

The accounts receivable is primarily made up of receivables related to reimbursable 

activities. 

Historical experience has indicated that the majority of the receivables are collectible. 

There are no material uncollectible accounts as of September 30, 2012 and 2011.

NOTE 4. PROPERTY, EQUIPMENT, AND SOFTWARE

Schedule of Property, Equipment, and Software as of September 30, 2012.

Major Class

Acquisition 

Cost

Accumulated 

Amortization/

Depreciation

Net Book 

Value

Software-in-Development $ 575,734 $ - $ 575,734

Total $ 575,734 $ - $ 575,734

Schedule of Property, Equipment, and Software as of September 30, 2011.

Major Class

Acquisition 

Cost

Accumulated 

Amortization/

Depreciation

Net Book 

Value

Software-in-Development $ 361,091 $ - $ 361,091

Total $ 361,091 $ - $ 361,091
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NOTE 5. LIABILITIES NOT COVERED BY BUDGETARY RESOURCES

The liabilities on USOGE’s Balance Sheet as of September 30, 2012 and 2011, include 

liabilities not covered by budgetary resources. 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. 

2012 2011

Intragovernmental – FECA $ 78,289 $ 80,504

Intragovernmental – Unemployment Insurance 12,341 3,009

Unfunded Leave 729,341 814,636

Actuarial FECA 401,523 375,237

Total Liabilities Not Covered by Budgetary Resources $ 1,221,494 $ 1,273,386

Total Liabilities Covered by Budgetary Resources 1,207,173 1,445,964

Total Liabilities $ 2,428,667 $ 2,719,350

FECA and the Unemployment Insurance liabilities represent the unfunded liability for 

actual workers compensation claims and unemployment benefits paid on USOGE's 

behalf and payable to the DOL. USOGE also records an actuarial liability for future 

workers compensation claims based on the liability to benefits paid (LBP) ratio provided 

by DOL and multiplied by the average of benefits paid over three years.

Unfunded leave represents a liability for earned leave and is reduced when leave is taken. 

The balance in the accrued annual leave account is reviewed quarterly and adjusted as 

needed to accurately reflect the liability at current pay rates and leave balances. Accrued 

annual leave is paid from future funding sources and, accordingly, is reflected as a 

liability not covered by budgetary resources. Sick and other leave is expensed as taken.

NOTE 6. ACTUARIAL FECA LIABILITY

FECA provides income and medical cost protection to covered federal civilian employees 

harmed on the job or who have contracted an occupational disease, and dependents of 

employees whose death is attributable to a job-related injury or occupational disease. 

Claims incurred for benefits under FECA for USOGE's employees are administered by 

the DOL and ultimately paid by USOGE when funding becomes available.

USOGE bases its estimate for FECA actuarial liability on the DOL's FECA model. The 

model considers the average amount of benefit payments incurred by USOGE for the past 

three fiscal years, multiplied by the medical and compensation liability to benefits paid 

(LBP) ratio for the whole FECA program. For the years ending September 30, 2012 and 
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2011, USOGE used the overall average percentages of the LBP ratio to calculate the 

$401,523 and $375,237 FECA actuarial liabilities, respectively.

NOTE 7. OTHER LIABILITIES

Other liabilities account balances as of September 30, 2012 were as follows:

Current Non Current Total

Intragovernmental

FECA Liability $ 42,775 $ 35,514 $ 78,289

Unemployment Insurance Liability 12,340 - 12,340

Payroll Taxes Payable 103,481 - 103,481

Total Intragovernmental Other Liabilities $ 158,596 $ 35,514 $ 194,110

With the Public

 Payroll Taxes Payable $ 16,150 $ - $ 16,150

 Accrued Funded Payroll and Leave 509,387 - 509,387

 Unfunded Leave 729,343 - 729,343

Total Public Other Liabilities $ 1,254,880 $ - $ 1,254,880

Other liabilities account balances as of September 30, 2011 were as follows:

Current Non Current Total

Intragovernmental

FECA Liability $ 30,458 $ 50,046 $ 80,504

Unemployment Insurance Liability 3,009 - 3,009

Payroll Taxes Payable 111,984 - 111,984

Total Intragovernmental Other Liabilities $ 145,451 $ 50,046 $ 195,497

With the Public

 Payroll Taxes Payable $ 16,637 $ - $ 16,637

 Accrued Funded Payroll and Leave 605,726 - 605,726

 Unfunded Leave 814,636 - 814,636

Total Public Other Liabilities $ 1,436,999 $ - $ 1,436,999
U.S. Office of Government Ethics

Fiscal Year 2012 Performance and Accountability Report Page 46

NOTE 8. LEASES

Operating Leases

USOGE 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:

Fiscal Year Totals

2013 1,431,042 

2014 478,711 

Total Future Payments $ 1,909,753 

The operating lease amount does not include estimated payments for leases with annual 

renewal options.

NOTE 9. INTRAGOVERNMENTAL COSTS AND EXCHANGE REVENUE

Intragovernmental costs and revenue represent exchange transactions between USOGE 

and other federal government entities, and are in contrast to those with non-federal 

entities (the public). Such costs and revenue are summarized as follows:

2012 2011

Program Costs

 Intragovernmental Costs $ 5,168,336 $ 4,515,155

 Public Costs 9,372,082 10,045,150

 Total Program Costs 14,540,418 14,560,305

 Intragovernmental Earned Revenue (491,925) (17,353)

 Public Earned Revenue (13,786) (466,505)

 Net Program Costs $ 14,034,707 $ 14,076,447
U.S. Office of Government Ethics

Fiscal Year 2012 Performance and Accountability Report Page 47

NOTE 10. IMPUTED FINANCING SOURCES

USOGE recognizes as imputed financing the amount of accrued pension and postretirement 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). For the year ended September 30, 2012 and 2011, 

imputed financing was as follows:

2012 2011

Office of Personnel Management $ 609,584 $ 640,930 

Total Imputed Financing Sources $ 609,584 $ 640,930 

NOTE 11. BUDGETARY RESOURCE COMPARISONS TO THE BUDGET OF 

THE UNITED STATES GOVERNMENT

The President’s Budget that will include fiscal year 2012 actual budgetary execution 

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

publication in February 2013 and can be found at the OMB Web site: 

http://www.whitehouse.gov/omb/. The 2013 Budget of the United States Government, 

with the "Actual" column completed for 2011, has been reconciled to the Statement of 

Budgetary Resources and there were no material differences.

NOTE 12. APPORTIONMENT CATEGORIES OF OBLIGATIONS INCURRED

Obligations incurred and reported in the Statement of Budgetary Resources in 2012 and 

2011 consisted of the following:

2012 2011

Direct Obligations, Category A $ 13,563,869 $ 14,645,869

Reimbursable Obligations, Category A 493,240 576,570

Total Obligations Incurred $ 14,057,109 $ 15,222,439

Category A apportionments distribute budgetary resources by fiscal quarters.

NOTE 13. UNDELIVERED ORDERS AT THE END OF THE PERIOD

For the fiscal years ended September 30, 2012 and 2011, budgetary resources obligated 

for undelivered orders amounted to $890,934 and $1,104,049, respectively.
U.S. Office of Government Ethics

Fiscal Year 2012 Performance and Accountability Report Page 48

NOTE 14. CUSTODIAL ACTIVITY

USOGE's custodial collection primarily consists of excess fees related to its national 

conference. While these collections are considered custodial, they are neither primary to 

the mission of USOGE nor material to the overall financial statements. USOGE's total 

custodial collections are $(663) and $57,306 for the years ended September 30, 2012, and 

2011, respectively. 

NOTE 15. RECONCILIATION OF NET COST OF OPERATIONS TO BUDGET

USOGE has reconciled its budgetary obligations and non-budgetary resources available 

to its net cost of operations.

2012 2011

Resources Used to Finance Activities:

Budgetary Resources Obligated

Obligations Incurred $ 14,057,109 $ 15,222,439

Spending Authority From Offsetting Collections and Recoveries (547,891) (1,288,783)

Net Obligations 13,509,218 13,933,656

Other Resources

Imputed Financing From Costs Absorbed By Others 609,584 640,930

Net Other Resources Used to Finance Activities 609,584 640,930

Total Resources Used to Finance Activities 14,118,802 14,574,586

Resources Used to Finance Items Not Part of the Net Cost of Operations (110,168) (584,770)

Total Resources Used to Finance the Net Cost of Operations 14,008,634 13,989,816

Components of the Net Cost of Operations That Will Not Require or

Generate Resources in the Current Period: 26,073 86,631

Net Cost of Operations $ 14,034,707 $ 14,076,447