Performance and Accountability Report

Fiscal Year 2011

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.............................................................................................. 2

E. FY 2011 Budget Priorities............................................................................................... 3

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

Part II – FY 2011 Performance Highlights................................................................................ 4

A. Strengthening Ethical Culture Within the Executive Branch.......................................... 4

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

C. Promoting Good Governance.......................................................................................... 9

D. Focusing on OGE’s People and Internal Operations..................................................... 11

Part III – Management Discussion & Analysis of Results...................................................... 12

A. Strategic Goal 1 – Strengthening Ethical Culture within the Executive Branch ........... 12

B. Strategic Goal 2 – Preventing Conflicts of Interest....................................................... 18

C. Strategic Goal 3 – Promoting Good Governance .......................................................... 21

Part IV - Management Assurances.....................................................................27

Part V – Financial Statements & Independent Auditor’s Report.......................................... 27

Limitations of the Financial Statements ........................................................................ 28

 Independent Auditor’s Report on the Financial Statements.................................29

 Independent Auditor’s Report on Internal Control Over Financial Reporting............31

 Independent Auditor’s Report on Compliance with Laws and Regulations...............32

 FY 2011 Financial Statements..................................................................33

 Notes to the Financial Statements...............................................................37
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, oversight, and accountability of 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 reaches more than 

28,000 public financial disclosure filers. This includes 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. A 

second financial disclosure system reaches another 325,000 officials in sensitive positions who 

file confidential disclosure reports. OGE exercises its oversight responsibilities by examining 

agency ethics programs across the Executive Branch to ensure compliance with the conflict of 

interest laws and ethics regulations. OGE helps prevent conflicts of interest by providing

education and training to nearly 6,000 ethics officials throughout the Executive Branch. OGE 

promotes good governance through outreach to 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 

for Integrity and Efficiency (CIGIE) and the Integrity Committee of the CIGIE, which reviews 

allegations of misconduct against Inspectors General.

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 government initiatives, and OGE administration. (See Figure 1) At 
U.S. Office of Government Ethics

FY 2011 Performance and Accountability Report Page 2

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, 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, legal and policy guidance; exercising oversight of Executive 

Branch ethics programs; and, conducting outreach to domestic and foreign audiences.

D. Long Term Strategic Goals

OGE established a five-year strategic plan in FY 2007 and is developing its new strategic 

plan. The plan in place from FY 2007 through FY 2011 had three major goals. Objectives within 

each of these strategic goals drive the daily work of OGE and form the basis for how the 
U.S. Office of Government Ethics

FY 2011 Performance and Accountability Report Page 3

performance of the agency and its employees are measured. OGE’s strategic goals and 

objectives consist of:

• 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;

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

Programs

• 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;

o Administer an Effective Confidential Financial Disclosure System.

• 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 Civil Society;

o Support United States Foreign Policy Anti-Corruption and Good Governance 

Initiatives.

OGE’s key FY 2011 accomplishments in furtherance of these objectives and goals are discussed 

in Section II of this report.

E. FY 2011 Budget Priorities

During FY 2011, OGE focused on achieving its long-term strategic goals and objectives 

with three budget priorities:

• Modernizing government ethics laws, regulations, and programs;

• Harnessing technology to promote transparency, training, and oversight; and
U.S. Office of Government Ethics

FY 2011 Performance and Accountability Report Page 4

• 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. 

Approximately every 18 months, as was the case this past year, OGE conducts a national ethics 

training conference. 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 nominee’s 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 Executive Order 13490, “Ethics Commitments by 

Executive Branch Personnel,” and apply resources to the interpretation and implementation of 

new laws, executive orders, and regulations. Detailed performance objectives and measures are 

discussed in Part III of this report.

Part II – FY 2011 Performance Highlights ____ _________________________

OGE achieved numerous accomplishments in FY 2011 that directly advanced its three 

long-term strategic goals.

A. Strengthening Ethical Culture Within the Executive Branch

In the past fiscal year, OGE took a number of steps to strengthen the ethical culture in the 

Executive Branch by improving the effectiveness of ethics policies, providing assistance to and 

oversight of agency ethics programs, increasing employees’ awareness of their ethical 

responsibilities, and focusing on senior officials’ roles in implementing ethics programs. OGE’s 

performance highlights include the following:

• OGE planned and hosted the 18th National Government Ethics Training Conference -

“Organizational Integrity: A Shared Responsibility”. This intensive training 

conference was attended by 850 Executive Branch ethics officials, employees of and 

Inspectors General, representatives of the international community, and, in keeping 

with the training conference theme, human resource and IT officials who also play a 

key role in ethics programs. This was the largest number of participants ever hosted 

by OGE;

• At its national training conference, OGE developed and presented an extensive range 

of training modules on topics as varied as emerging ethics issues, program 
U.S. Office of Government Ethics

FY 2011 Performance and Accountability Report Page 5

management, continuity and succession planning, the perspectives of private sector 

and good governance organizations, program support, and ethics education. OGE 

showcased these topics in 64 breakout sessions and 24 innovative “Learning Lab” 

sessions, which provided a novel framework for high-level, informative and engaging 

dialogue about the entire range of complex topics; 

• OGE leveraged technology to provide innovative and effective training at the 18th

National Government Ethics Training Conference. These innovations included:

o A virtual training conference for ethics officials who were unable to attend;

o A comprehensive smart-phone “APP” and dedicated conference website 

through which attendees could view the conference agenda, course materials, 

handouts, and participants’ contact information. Ninety-seven percent of APP 

users at the training conference used that tool to enhance their training 

conference experience; and

o An at-speed alternative reality exercise used to bring training conference 

attendees together in competition while providing a novel approach to 

expanding professional networks, gathering and applying knowledge learned 

at the conference, identifying ethics program model practices, facilitating 

discussions on various ethics topics, and learning about alternative training 

methods.

• OGE collaborated with other agencies and entities to develop effective and efficient 

solutions to key policy issues, such as: 

o Contributing to the development of a recommendation, by the Administrative 

Conference of the United States (ACUS), regarding ethics oversight of

government contractors;

o Contributing to the development of recommendations, by the ACUS, for 

potential improvements to the Federal Advisory Committee Act (FACA)

designed to help promote more effective use of advisory committees;

o Partnering with the General Service Administration’s Committee 

Management Secretariat (CMS) to provide ethics course instruction in its 

FACA management training and to counsel CMS on matters involving the 

application of ethics rules to advisory committee members;

o Partnering with the Office of Federal Procurement Policy to build greater 

collaboration and communication between the procurement and ethics 

communities on issues of common concern;
U.S. Office of Government Ethics

FY 2011 Performance and Accountability Report Page 6

o Working with the Office of Special Counsel in the development of guidance 

on Executive Branch employees running for and holding nonpartisan elective 

offices.

• OGE continued to implement Executive Order 13490 of January 21, 2009, “Ethics 

Commitments by Executive Branch Personnel.” Specifically, after drawing on its 

experience applying the lobbyist gift ban to political appointees and considering 

carefully the needs and circumstances of career employees, OGE published a 

proposed rule to extend the ban to the entire Executive Branch workforce in 

September 2011. OGE anticipates a final rule will be published in FY 2011;

• In FY 2011, OGE published the second annual assessment of the Ethics Pledge 

required by Executive Order 13490. The most recent report to the President 

confirmed that 100 percent of the 1,096 Presidential appointees required to sign the 

Pledge in calendar year 2010 fulfilled their obligations to do so, and that few former 

lobbyists were appointed to positions in the Executive Branch;

 

• OGE also published proposed rules to streamline approval for service of federal 

employees on boards of nonprofit organizations in their official capacities and to 

modernize existing regulations governing blind and qualified trusts as a mechanism to 

prevent conflicts of interest;

• OGE served as the ethics expert on Executive Branch-wide legislation and related 

matters by: (1) timely responding to 95 OMB legislative memoranda and 45 

executive orders; (2) providing technical expertise in consulting and responding to 

questions by congressional staff; (3) consulting with the Government Accountability 

Office on its ethics-related investigations and reports; and (4) responding to the 

proposals of good government groups and congressional staff on critical ethics topics 

including post employment, reverse revolving door, financial disclosure, and gifts; 

• OGE created a legislative safety net for the broader Executive Branch ethics 

community by: (1) identifying and alerting agency ethics officials of agency-specific 

legislative proposals; (2) consulting with agency ethics officials and providing 

technical assistance on key legislation; and (3) analyzing congressional publications 

and complex legislative search results daily to keep OGE staff and the ethics 

community informed of relevant congressional activity. 

• OGE also issued several publications to aid ethics officials in staying current on 

ethics laws and policy. These publications included: 

o A comprehensive legal advisory on issues associated with Executive Branch 

employees who run for or hold nonpartisan elective office;

o A legal advisory setting forth the requirements for Presidential candidates to file 

public financial disclosure reports; and
U.S. Office of Government Ethics

FY 2011 Performance and Accountability Report Page 7

o A revised compilation of federal ethics laws that flags the relevant statutory 

changes of which ethics practitioners should be aware.

• OGE answered thousands of complex ethics questions received from ethics officials 

across the Executive Branch;

• OGE enhanced oversight activities by increasing the number of on-site program 

reviews, gathering pertinent information electronically, and conducting in-person 

outreach. OGE oversight activities ensure that Executive Branch ethics programs are 

in compliance with regulatory requirements, essential processes and procedures are

documented, and agency ethics programs are structured to provide optimal support to 

federal employees. Oversight also facilitates the identification of vulnerabilities and 

the effective dissemination of model practices;

• OGE completed a benchmarking effort of all Cabinet-level and regulatory agencies 

determining the extent to which these agencies’ ethics programs had incorporated 

critical success factors: leadership, awareness, resources, and oversight. The results 

were shared with the broader ethics community to assist them in determining where 

their programs stood in comparison to the benchmarked agencies and to make 

changes, as appropriate; 

• OGE jointly issued ethics regulations supplementing the Standards of Ethical 

Conduct to meet the needs of the following four agencies: the Court Services and 

Offender Supervision Agency, the Federal Energy Regulatory Commission, the 

Federal Labor Relations Authority, and the Securities and Exchange Commission; 

• OGE drafted and circulated through the OMB clearance process proposed legislation

to update and modernize Title IV of EIGA, the law that created OGE and the 

Executive Branch ethics program. These would be the first significant amendments 

to EIGA since 1989;

• OGE continued to refine its new ethics official certificate program, which promotes

government ethics as a professional career, helps identify persons best qualified for 

positions as ethics officials, and raises the standards of technical competencies in the 

ethics program. OGE’s program advances recruitment, retention, and succession 

planning; 

• OGE enhanced the knowledge and practical expertise of OGE staff who answer 

conflicts of interest and ethics questions from agency ethics officials, the White 

House, congressional offices, and the public by conducting substantive bi-weekly 

internal training sessions, which continuously raises the bar on the quality of OGE’s

ethics advice;
U.S. Office of Government Ethics

FY 2011 Performance and Accountability Report Page 8

• Using existing budget resources, OGE developed and implemented an honors 

attorney program to create a pathway for several entry-level attorneys to enter the 

federal government and the ethics field. By training and mentoring these attorneys, 

the agency is preparing tomorrow’s leaders in the ethics community.

B. Preventing Conflicts of Interest

OGE supported the President and the Senate in the Presidential appointment process and, 

through its nominee public financial disclosure program, resolved potential conflicts of interest 

for PAS officials. OGE also monitored compliance with conflict of interest laws, implemented

and oversaw an effective public and confidential financial disclosure system, and reviewed the 

ethics programs of Executive Branch agencies. 

• In direct support of the President’s constitutional duties to nominate and appoint 

officers to the Executive Branch, OGE:

o Analyzed and reviewed the financial disclosure reports and resolved potential 

conflicts of interests of approximately 300 potential nominees, as well as 

several dozen public financial disclosure reports of high-level officials serving 

in the White House and in the Office of the Vice President. These reviews 

included resolving financial disclosure issues and negotiating ethics 

agreements to address actual and potential conflicts of interest on the part of 

senior leaders in the Executive Branch; 

o Worked with agency ethics officials and White House staff to introduce 

potential nominees to the broader scope of Executive Branch ethical 

requirements; and

o Developed and conducted advanced financial disclosure training for over 100 

ethics officials, increasing their skills to better conduct difficult nominee 

financial disclosure reviews.

• OGE began the design phase of replacing its Financial Disclosure Tracking System. 

This critical but outdated system tracks the receipt, review, certification, and 

destruction of approximately 6,000 reports filed by PAS officials, certain Presidential 

appointees, senior White House employees, and Presidential and Vice Presidential 

candidates;

• OGE continued to work with agencies to ensure that agency-developed systems for 

financial disclosure reports meet standards established by their CIOs, and that 

embedded information is accurate. In FY 2011, there were 14 agency-developed 

electronic filing systems;
U.S. Office of Government Ethics

FY 2011 Performance and Accountability Report Page 9

• OGE also researched and tested agencies’ financial disclosure electronic filing 

systems to determine whether any existing system should be converted for OGE’s 

nominee financial disclosure program;

• OGE completed the majority of an interactive, electronic workbook that will guide 

new entrant and nominee public financial disclosure filers through the complex 

financial disclosure process; 

• Within existing budget resources, OGE increased the number and qualifications of 

OGE staff who review financial disclosure reports in order to prepare for the post2012 election period; and

• OGE also leveraged technology through its development of web-based ethics training 

modules. In FY 2011, OGE doubled the number of on-demand, web-based training 

courses offered over the previous fiscal year. Both OGE’s instructor-led and selfpaced tutorials effectively communicate specialized information to ethics officials, 

staff of Inspectors General, and Executive Branch employees generally. 

C. Promoting Good Governance

OGE engaged and cooperated with federal, state, and local agencies whose programs 

support good governance; enhanced outreach to the public, the private sector and good 

governance groups; and supported United States foreign policy anti-corruption and good 

governance initiatives. Key FY 2011 accomplishments include:

• OGE supported the vital work of Inspectors General to investigate alleged ethical 

misconduct by:

o Actively participating in the CIGIE;

o Providing practical and well-received training at the Inspector General 

Academy on a regular basis;

o Inviting IGs to actively participate in OGE’s 18th National Government Ethics 

Training Conference; and 

o Regularly providing expertise to prosecutors and investigators concerning the 

interpretation and application of the conflict of interest laws and ethics rules.

• OGE also continued to engage the state and local ethics communities, primarily 

through the Council on Governmental Ethics Laws (COGEL).
U.S. Office of Government Ethics

FY 2011 Performance and Accountability Report Page 10

• In its drive to improve outreach and increase transparency, OGE completely 

overhauled its website (www.usoge.gov) to improve access to information for the 

general public, ethics officials, media, good governance groups, and international 

visitors to our site. This overhaul, which was on time and on budget, represents a 

quantum leap in terms of accessibility. OGE:

o Reorganized the site content;

o Vastly improved the search and filter capabilities; and 

o Developed a whole new aesthetic look and feel.

• As part of the website overhaul project, and to implement OMB’s Open Government 

directive of December 8, 2009, OGE posted new data sets, such as:

o The 2012 Presidential Candidate financial disclosure records;

o Agency program review reports;

o Reports of non-Federal source travel payments accepted by agencies; and

o OGE legislative proposals and reports sent to Congress, congressional 

correspondence, and GAO reports in which OGE provided input. 

 

• Additional steps OGE took during FY 2011 to improve outreach and increase 

transparency included: 

o Making reports of non-Federal source travel payments accepted by agencies 

publicly available on OGE’s new website. This new process allows 

immediate public access to about 400 reports, increasing transparency and 

improving the efficiency with which OGE carries out its customer service 

mandate;

o Publishing on OGE’s website OGE legislative proposals and reports sent to 

Congress, congressional correspondence, and GAO reports in which OGE 

provided input;

o Maintaining a 100 percent on time response rate to Freedom of Information 

Act (FOIA) requests despite a rising number and complexity of requests; and

o Addressing over 50 national, local, international, trade, academic, and other 

news sources during hundreds of phone calls about financial disclosure, 

conflicts of interest, the Standards of Ethical Conduct, and matters concerning 

access to ethics documents, including requests made under the FOIA. 
U.S. Office of Government Ethics

FY 2011 Performance and Accountability Report Page 11

• As part of its robust international program, and at the request of the U.S. Department 

of State, OGE:

o Continued to coordinate with and serve as a U.S. representative at anticorruption and good governance meetings of a number of multilateral 

government organizations. Detailed information on these efforts is discussed 

in Section III; and

o Continued to provide international assistance on topics such as codes of 

conduct, outside activities, financial disclosure, and gifts, as well as briefed 52 

visiting delegations, reaching at least 571 individuals from 73 countries.

D. Focusing on OGE’s People and Internal Operations

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

respects. During FY 2011, 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: 

• OGE further consolidated support services with the Bureau of Public Debt’s 

Administrative Resources Center (BPD) in the human resources area and improved 

coordination of existing BPD services in the areas of procurement and financial 

management. This consolidation has yielded more efficient personnel services 

resulting in better human capital management as well as enhanced management and 

employee satisfaction. Additionally, OGE leveraged technology in the administrative 

support area by successfully converting its paper-based Official Personnel Files to 

electronic media and transitioning to an automated time and attendance system;

 

• OGE also made substantial improvements in the agency’s budget and fiscal planning. 

As a result of these ongoing changes, there have been major improvements in OGE’s 

acquisition and accounting processes;

• OGE continued to comply with the President’s hiring initiatives, improved its timeto-hire statistics, and exceeded OPM’s targets for bringing veterans into the federal 

workplace;

• OGE also implemented a number of significant improvements in the delivery of 

information technology services in support of the agency’s mission, including: 

o Meeting the GSA deadline for Managed Trusted Internet Protocol Services 

(MTIPS) that will, among other advancements, increase the level of protection 

for external (Internet-based) threats and reduce the costs associated with the 

detection of and recovery from IT security incidents; 
U.S. Office of Government Ethics

FY 2011 Performance and Accountability Report Page 12

o Implementing a remote “virtual desktop”; and

o Hosting OGE’s new website on a commercial cloud server and reducing OGE 

owned and maintained IT infrastructure.

These IT changes improved OGE operations by reducing network downtime, improving 

network performance and reliability, reducing maintenance costs over time, and increasing staff 

productivity. 

Part III – Management Discussion & Analysis of Results__________________ 

This section of OGE’s PAR 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

• 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: 

• Usefulness of ethics policy guidance;

• Effectiveness of ethics policy guidance; and

• Responsiveness to emerging ethics program issues.

The results related to Objective 1.1 performance measures again met or surpassed OGE 

targets. (See Figure 2)
U.S. Office of Government Ethics

FY 2011 Performance and Accountability Report Page 13

• 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 FY 2011, OGE conducted 33 on-site reviews. In addition, OGE 

continues to devote considerable resources to training ethics officials. In FY 2011, OGE 

provided training to over 2,265 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 they 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) 

OGE attributes the drop in the first measure to a change in report format, which sharpened its 

compliance findings, and the number of improvements that OGE required agency ethics officials 

to make to bring their programs into compliance.
U.S. Office of Government Ethics

FY 2011 Performance and Accountability Report Page 14

Finally, OGE encourages and supports internal reviews or audits (self-assessments) by 

agencies to evaluate their ethics program. (See Figure 4) OGE’s benchmarking of the extent to 

which Cabinet-level and regulatory agencies have incorporated critical success elements 

identified conducting internal reviews is a significant component in ensuring the enduring 

success of agency-level programs.
U.S. Office of Government Ethics

FY 2011 Performance and Accountability Report Page 15

• Objective 1.3: Increase Employees’ Awareness of Their Ethics Responsibilities 

To strengthen the ethical culture within the Executive Branch, OGE continues efforts to 

raise employee awareness of their ethics responsibilities. OGE provides training to agency ethics 

officials to assist them in carrying out their responsibilities. OGE also provides education and 

training products that agencies can incorporate into their ethics training programs, and distributes 

the products throughout the Executive Branch. 

Ethics officials were overwhelmingly satisfied with the OGE-provided training and 

incorporate OGE products into their training programs. (See Figures 5 and 6)
U.S. Office of Government Ethics

FY 2011 Performance and Accountability Report Page 16

• 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 7 and 8)
U.S. Office of Government Ethics

FY 2011 Performance and Accountability Report Page 17
U.S. Office of Government Ethics

FY 2011 Performance and Accountability Report Page 18

B. Strategic Goal 2 – Preventing Conflicts of Interest

• 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 FY 2011, 78 PAS officials entered into ethics agreements that required compliance 

documentation. Based on documentation OGE received, 100 percent of the officials complied 

with their ethics agreements within required timeframes. 

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 9)
U.S. Office of Government Ethics

FY 2011 Performance and Accountability Report Page 19

• 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 FY 2011, OGE came between two and three percentage 

points of meeting the targets for these measures. (See Figure 10)

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 11 and 

12)
U.S. Office of Government Ethics

FY 2011 Performance and Accountability Report Page 20
U.S. Office of Government Ethics

FY 2011 Performance and Accountability Report Page 21

C. Strategic Goal 3 – 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

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

federal, state, and local government agencies having complementary missions and programs in 

promoting integrity, accountability, predictability, and transparency of government. 

This past fiscal year, OGE continued to reach out to other agencies to build awareness of 

its role for preventing conflicts of interest in the Executive Branch. In many cases, OGE used 

these outreach opportunities to highlight specific issues, such as:

• The critical role agency leadership plays in promoting ethical behavior for the agency 

as a whole; and

• The nexus between the ethical standards regarding outside activities and the 

whistleblower statutes.

As part of this outreach, OGE also assisted agencies and ethics officials in understanding

the specific application of the ethics program in particular circumstances and to special 

categories of employees. For instance, OGE actively participated in the ACUS, advising on two 

significant ACUS initiatives regarding contractor ethics and federal advisory committees. 

OGE has a natural affinity with the Inspector General community, which detects and 

investigates potential violations of the conflict of interest statutes and regulations. IGs often rely 

on ethics officials’ understanding of the ethics regulations and conflict of interest statutes to 

inform their investigations. As discussed earlier, OGE continued to maintain a healthy 

engagement with this community through: 

• The Director’s regular participation at the monthly meetings of the CIGIE;

• The Director’s service as a member of CIGIE’s Integrity Committee; and

• OGE instruction at the Inspector General Criminal Investigation Academy.

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

COGEL, an organization of federal, state, and local government agencies whose responsibilities 

include ethics, campaign finance, freedom of information, and lobbying disclosure. OGE 

leveraged COGEL’s annual conference, held in Washington, DC, to share and learn good 

practices – both domestic and international.
U.S. Office of Government Ethics

FY 2011 Performance and Accountability Report Page 22

• 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 single most significant 

methods of outreach to the general public. This past year, OGE completely overhauled its 

website to significantly increase transparency and improve public access to thousands of ethics 

documents. Building on the platform of a newly-acquired content management system, OGE: 

• Reorganized the site content;

• Vastly improved the search and filter capabilities;

• Posted new data sets, such as 2012 Presidential Candidate financial disclosure 

records, agency program review reports, agency travel reports, and OGE legislative 

proposals and reports sent to Congress, congressional correspondence, and GAO 

reports in which OGE provided input; and

• Developed a new aesthetic look and feel.

Leveraging the platform of the newly designed site, OGE continues to add resources and 

additional data sets. In the first quarter of FY 2012, OGE’s website will provide immediate 

access to certified public financial disclosure reports and other ethics-related documents 

pertaining to Senate-confirmed Executive Branch officials.

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 13.

Target (T)

Actual (A)
U.S. Office of Government Ethics

FY 2011 Performance and Accountability Report Page 23

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

continued relationships with the Ethics Resource Center (ERC) – a nonprofit organization that 

researches ethical standards and practices in the public and private sector – and the Ethics & 

Compliance Officer Association (ECOA) – a nonprofit professional association of ethics and 

compliance practitioners. Throughout the year, OGE maintained an ongoing discussion with 

ERC and ECOA about universal issues such as evolving compliance models, effective training 

techniques, and ways to build an ethical culture within an organization. OGE leveraged every 

opportunity to cross-pollinate these ideas, including through: 

• Meetings between OGE’s Director and ERC and ECOA leadership;

• OGE employees’ attendance at ERC/ECOA training;

• A training webinar created by OGE and presented to ECOA members; and

• The ECOA Director’s keynote speech at OGE’s 18th National Government Ethics 

Training Conference.

OGE significantly increased its interaction with non-profit, good governance groups this 

past year, in an effort to not only disseminate information about the role the ethics program plays 

in establishing integrity, accountability, and transparency in government, but also to seek outside 

perspectives on OGE’s success in being accountable and transparent. Activities included:

• Meeting with government oversight groups such as the Sunlight Foundation and the 

Project on Government Oversight; and

• Commenting on technical proposals from organizations such as the Partnership for 

Public Service and the Center on Budget and Policy Priorities.
U.S. Office of Government Ethics

FY 2011 Performance and Accountability Report Page 24

• Objective 3.3 Support U.S. Foreign Policy Anti-corruption and Good Governance 

Initiatives

This past fiscal year, OGE continued to support United States foreign policy anticorruption and good governance initiatives, representing the United States at the following 

international fora and working groups:

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

implementation review group and the UNCAC working group on prevention;

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

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

Transparency Working Group;

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

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

Network for Eastern Europe;

• Organization of American States (OAS): the follow-up mechanism of the InterAmerican Convention Against Corruption (MESICIC);

• US-China Joint Liaison Group: the Anti-Corruption Working Group.

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 14.

Target (T)

Actual (A)
U.S. Office of Government Ethics

FY 2011 Performance and Accountability Report Page 25

OGE represented the United States at anti-corruption and governance bodies of 5 multinational organizations and 1 bilateral group.

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

mechanisms to review the progress of members in meeting anti-corruption obligations. The 

United States was reviewed under five such mechanisms this past year, for three of which OGE 

provided varying levels of support. Most significantly, an OGE Deputy Director served as the 

primary representative to GRECO during the U.S. review. OGE hosted the GRECO evaluators, 

identified U.S. stakeholders, set up meetings between U.S. stakeholders and GRECO evaluators, 

and compiled and synthesized the U.S. response to the GRECO evaluators. 

OGE complemented its broader good governance policy efforts with activities aimed at 

sharing good practices on specific issues such as financial disclosure and effective ethics 

training. Activities included: 

• Spearheading a workshop on effective financial disclosure as part of the APEC 

meetings hosted by the U.S.;

• Taking the lead in drafting and submitting, for adoption by the APEC economies, a 

set of principles for financial disclosure;

• Reviewing and commenting on a model law, drawn up by the OAS, on financial 

disclosure; and

• Sharing training techniques as part of an OECD working group on effective training 

tools.

Throughout its active schedule within international fore, OGE maintained a robust pace 

of bi-lateral technical assistance. OGE responded to requests for technical information from 

foreign governments on:

• Best practices related to benchmarking ethical leadership;

• How to leverage human resource departments to promote ethics; and

• The Standards of Ethical Conduct for Employees of the Executive Branch.
U.S. Office of Government Ethics

FY 2011 Performance and Accountability Report Page 26

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, in the 

following countries:

• Latvia: A veteran OGE policy attorney met with government officials from Latvia’s 

national anti-corruption body to discuss how OGE handles issues such as outside 

activities, maintaining impartiality, financial disclosure, and gifts. Leveraging its

presence in country, the U.S. embassy set up meetings with students, academics, the 

press, and good governance groups to discuss similar issues;

• Dominican Republic: OGE’s General Counsel explained OGE’s role in preventing 

conflicts of interest during the Dominican Republic’s “National Week of Quality in 

the Public Administration”;

• Slovakia: OGE’s Deputy Director for its international section presented at a meeting 

at the Slovakian Parliament on the uses and benefits of financial disclosure for senior 

officials.

A mainstay of its international program, 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. 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. 

In FY11 OGE provided some form of technical assistance in support of U.S. foreign policy interests 

to the countries highlighted in blue.
U.S. Office of Government Ethics

FY 2011 Performance and Accountability Report Page 27
U.S. Office of Government Ethics

FY 2011 Performance and Accountability Report Page 28

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 the Office of 

Management and Budget, 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.
U.S. Office of Government Ethics

FY 2011 Performance and Accountability Report Page 29
U.S. Office of Government Ethics

FY 2011 Performance and Accountability Report Page 30
U.S. Office of Government Ethics

FY 2011 Performance and Accountability Report Page 31
U.S. Office of Government Ethics

FY 2011 Performance and Accountability Report Page 32
U.S. Office of Government Ethics

FY 2011 Performance and Accountability Report Page 33
U.S. Office of Government Ethics

FY 2011 Performance and Accountability Report Page 34
U.S. Office of Government Ethics

FY 2011 Performance and Accountability Report Page 35
U.S. Office of Government Ethics

FY 2011 Performance and Accountability Report Page 36
U.S. Office of Government Ethics

FY 2011 Performance and Accountability Report Page 37
U.S. Office of Government Ethics

FY 2011 Performance and Accountability Report Page 38
U.S. Office of Government Ethics

FY 2011 Performance and Accountability Report Page 39
U.S. Office of Government Ethics

FY 2011 Performance and Accountability Report Page 40
U.S. Office of Government Ethics

FY 2011 Performance and Accountability Report Page 41
U.S. Office of Government Ethics

FY 2011 Performance and Accountability Report Page 42
U.S. Office of Government Ethics

FY 2011 Performance and Accountability Report Page 43
U.S. Office of Government Ethics

FY 2011 Performance and Accountability Report Page 44
U.S. Office of Government Ethics

FY 2011 Performance and Accountability Report Page 45
U.S. Office of Government Ethics

FY 2011 Performance and Accountability Report Page 46
U.S. Office of Government Ethics

FY 2011 Performance and Accountability Report Page 47