Performance and Accountability Report

Fiscal Year 2013
Table of Contents ______ _____________________________________________

Part I – About OGE............................................................................................. 2 

Mission Statement....................................................................................... 2 

Background................................................................................................ 2 

 

Part II – Fiscal Year 2013 Performance Highlights ..................................................... 2 

Priority 1: Interpreting, Implementing, and Advising on Government Ethics 

Laws, Policies and Program Management............................................. 3 

Priority 2: Harnessing Technology to Promote Transparency, Education, and 

Oversight.................................................................................... 9 

Priority 3: Ensuring Effective Communications to Enhance Understanding of 

Government Ethics Laws, Policies, and Program Management and to 

Promote Transparency, Education, and Oversight................................. 11

Creating and Promoting a Positive Performance Culture..................................... 14 

 Conclusion.............................................................................................. 15

Part III – Management Discussion & Analysis of Results ............................................. 16

 

Strategic Goal 1: Strengthening Ethical Culture within the Executive Branch.................16 

Strategic Goal 2: Preventing Conflicts of Interest................................................. 20 

Strategic Goal 3: Promoting Good Governance.................................................... 22 

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

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

Limitations of the Financial Statements............................................................ 25 

Independent Auditor’s Report on the Financial Statements...................................... 26 

Independent Auditor’s Report on Internal Control over Financial Reporting..................27 

Independent Auditor’s Report on Compliance with Laws and Regulations....................28 

Fiscal Year 2013 Financial Statements...............................................................30 

Notes to the Financial Statements.................................................................... 35 
Part I – About OGE

Mission Statement

The United States Office of Government Ethics (OGE) provides overall 

leadership and oversight of the executive branch ethics program designed to prevent and 

resolve conflicts of interest. OGE’s mission directly supports the President’s goal of 

responsibly governing the nation. 

Background 

OGE was established by the Ethics in Government Act of 1978. To carry out its 

leadership and oversight responsibilities over the executive branch ethics program, OGE 

promulgates and maintains enforceable standards of ethical conduct for approximately 

2.7 million civilian employees in over 130 executive branch agencies and the White

House; oversees a financial disclosure system that reaches more than 28,000 public 

and 325,000 confidential financial disclosure report filers; ensures that executive branch 

ethics programs are in compliance with applicable ethics laws and regulations; 

provides education and training to the more than 5,600 ethics officials executive branchwide; conducts outreach to the general public, the private sector, and civil society; and 

shares model practices with state, local, and foreign governments, and international 

organizations. 

OGE’s greatest resource is its multi-disciplinary staff of attorneys, ethics and 

financial experts, and support staff. OGE is a lean organization, with approximately 

80 full-time equivalents, and accomplishes its responsibilities by organizing crossfunctional teams to perform such diverse tasks as working with Presidential nominees 

for appointments requiring Senate confirmation to resolve potential financial conflicts

of interest, training executive branch ethics officials, and enhancing oversight of 

executive branch ethics programs. 

 

Part II – Fiscal Year 2013 Performance Highlights

 In fiscal year 2013, the last year under OGE’s prior strategic plan, OGE advanced 

its strategic goals of strengthening the ethical culture within the executive branch, 

preventing conflicts of interest, and promoting good governance. OGE advanced each of 

the strategic goals by focusing on the following three priorities: 

1. Interpreting, implementing, and advising on government ethics laws, policies, 

and program management; 

2. Harnessing technology to promote transparency, education, and oversight; and 

3. Ensuring effective communications to enhance understanding of 

government ethics laws, policies, and program management, and to promote 

transparency, education, and oversight.

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OGE’s fiscal year 2013 strategic goals and priorities, as well as the strategic 

objectives that OGE identified in order to achieve its priorities, are depicted in Figure 1 

below. 

Figure 1 

The following summary details the major accomplishments that OGE achieved in 

fiscal year 2013 in order to advance its priorities and to meet each of its objectives.

Priority 1: Interpreting, Implementing, and Advising on Government Ethics 

Laws, Policies, and Program Management 

 In fiscal year 2013, OGE undertook numerous efforts and initiatives to advance 

its priority of interpreting, implementing, and advising on ethics laws, policies, and 

program management. Notably, OGE implemented several changes in the executive 

branch ethics program that were necessitated by legislative or regulatory reforms. During 

this period, OGE also continued to ensure that new Presidential appointees were free of 

financial conflicts of interest and took steps to improve overall ethics program 

management and professionalism. Finally, OGE provided support and assistance to the 

work of inspectors general and to international anti-corruption and good governance 

initiatives.

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Strategic Objective: Implement Changes to Ethics Policy and Practice Mandated by 

Legislative and Regulatory Reforms

The most far-reaching and complex changes to the executive branch ethics 

program in fiscal year 2013 were the result of the passage of the Stop Trading on 

Congressional Knowledge Act of 2012 (STOCK Act). To assist agencies in effectively 

implementing the STOCK Act, OGE issued several pieces of legal guidance outlining the 

new financial disclosure reporting procedures and requirements for periodic transaction 

reporting, as well as the employment negotiation notification and recusal requirements. 

OGE also provided training to hundreds of executive branch agency ethics officials, as 

well as administrative law judges, and members of the intelligence community on the 

various provisions of the STOCK Act. 

 In fiscal year 2013, OGE also published a legislative Legal Advisory analyzing 

the significant ethics-related legislative activity during the 112th Congress, including key 

statutory changes including the STOCK Act. In addition to the STOCK Act, the Legal 

Advisory addressed the Presidential Appointment Efficiency and Streamlining Act of 

2011, which, among other things, established the President’s working group on 

streamlining the Presidential appointments process. OGE’s Director participated in the 

working group, which issued two reports to Congress in fiscal year 2013 recommending 

ways to improve the appointment process. 

 Another change that resulted in far-reaching ethics implications in fiscal year 

2013 was the decision in United States v. Windsor case in which the Supreme Court 

found Section 3 of the Defense of Marriage Act to be unconstitutional. Shortly after this 

decision, OGE issued a Legal Advisory providing guidance on the effect of the Supreme 

Court’s decision on the Federal ethics provisions that use the terms “spouse,” “marriage,” 

and “relative.” As a result of the decision, and after a comprehensive consultative process 

between OGE and the Department of Justice, OGE issued a Legal Advisory explaining 

that Federal ethics rules and requirements now apply to employees in same-sex marriages 

in the same way that they apply to opposite-sex marriages. In addition to the Legal 

advisory, OGE provided language approved by the Department of Justice that agency 

ethics officials could use to proactively notify all agency employees of the new 

requirements. 

 In order to alert and assist agency ethics officials regarding other new or 

emerging issues and to ensure the uniform application of laws within the executive 

branch ethics program, OGE also provided legal guidance concerning ethics implications 

of certain appropriations act provisions. For instance, OGE issued guidance summarizing 

the new high-dollar value conference reporting requirements under the Consolidated and 

Further Continuing Appropriations Act of 2013. Further, OGE issued guidance 

reminding ethics officials and employees that ethics laws and rules apply to Federal 

employees who are in a furlough status as a result of sequestration. 

 

 In addition to issuing formal guidance, OGE routinely provided advice and 

assistance in response to requests from a variety of stakeholders. Notably, OGE 

responded to over 85 requests for technical assistance from the Congress on issues 

including the STOCK Act and its amendments, financial disclosure and the Presidential

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nomination process, post-government employment, gifts, and outside positions. The 

provision of this type of assistance helped to build understanding of the executive branch 

ethics program among congressional staff and to inform potential statutory revisions to 

ethics laws.

 On the regulatory front, OGE published a final rule amending the regulation that 

describes financial interests that are exempt from the prohibition on employees 

participating in their official capacities in particular matters in which they have personal 

financial interests. These final rule amendments: (1) created a new exemption permitting 

a government employee to participate in a particular matter affecting the financial 

interests of a nonprofit organization in which the employee serves in an official capacity 

as officer, director, or trustee; and (2) revised the existing exemption for interests in the 

holdings of sector mutual funds to clarify that the exemption applies to interests in the 

holdings of sector unit investment trusts. The former exemption will, among other things, 

contribute significantly to the accomplishment of the statutory mission of agencies and 

will facilitate the professional development of government scientists and engineers. 

 

 OGE also jointly issued two new supplemental agency ethics regulations with 

financial regulatory agencies. These regulations more closely align the ability of the 

agencies’ employees to own certain financial assets and participate in outside activities 

related to the missions of the agencies. 

Strategic Objective: Ensure New Presidential Appointees are Free of Financial Conflicts 

of Interest

OGE reviews the financial interests of Presidentially-appointed, Senateconfirmed nominees for possible conflicts of interest with their prospective duties. As a 

result of the 2012 Presidential election, in fiscal year 2013 OGE reviewed 68 percent 

more PAS nominee public financial disclosure reports than it reviewed in fiscal year 

2012. OGE prioritized its responsibility for reviewing and certifying PAS nominee 

financial disclosure reports and shifted its staff resources to timely review the 

significantly increased volume of reports. This cyclical increase in volume, owing to the 

transition from the first term to the second term of the Administration, necessitated that 

OGE train additional internal staff to meet increased demand. Targeted staff underwent 

intensive financial disclosure review training which included instructor-led courses, 

practical exercises using complex hypothetical reports, one-on-one mentoring by 

experienced reviewers, and supplemental instructional forums. In fiscal year 2013, OGE 

reviewed the reports of nominees for approximately 28 percent of the roughly 1,100 

Senate-confirmed, Presidential appointees. By leveraging existing resources, OGE was 

able to meet the priorities set by the White House and the Senate. 

 

OGE also identifies and resolves potential conflicts of interest on the part of the 

nominees by establishing written ethics agreements with them prior to their 

confirmations. OGE monitored the timeliness of compliance with these ethics 

agreements through the collection and review of documentation received by agency 

ethics officials. Forty-five PAS appointees entered into ethics agreements that required 

compliance documentation in fiscal year 2013. Agency ethics officials reported that 96 

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percent of these individuals complied with their ethics agreements within the established 

timeframes. 

 To ensure that executive branch leaders who have been appointed by the 

President and confirmed by the Senate remain free of conflicts of interest after taking 

office, OGE reviews their annual and termination public financial disclosure reports. 

OGE took significant steps in fiscal year 2013 to improve the efficiency and 

effectiveness of this review process. As a result of these improvements, OGE completed 

its review of 1,383 new entrant, annual, and termination public financial disclosure 

reports required to be submitted to OGE in fiscal year 2013. Additionally, OGE reviewed 

392 periodic transaction reports in fiscal year 2013, the first year in which such reports 

were required as a result of the STOCK Act.

One of OGE’s new Director’s first initiatives and OGE’s most notable 

accomplishments in fiscal year 2013 was improving the security, accountability, and 

integrity of its financial disclosure program. Through the extraordinary efforts of several 

cross-agency teams OGE closed out a significant backlog of PAS annual and termination 

public financial disclosure reports. First, OGE staff reviewed all PAS public financial 

disclosure reports that were pending OGE certification. Within the 60-day deadline 

established by the Director, staff working in an office-wide effort identified and 

completed reviews of 170 reports, representing a 4-year backlog. As a second step in this 

effort, OGE staff physically audited and examined the complete inventory of 4,296 

report files. This inventory was the first, and perhaps the most significant, step toward 

completely reconciling the physical file inventory with the virtual records inventory of 

financial disclosure reports in OGE’s history. As a third step, OGE staff enhanced the 

procedures for maintaining and tracking the reports that come to OGE for final review, 

including centralizing the physical filing and location of the report files. 

 To further ensure that PAS officials are free of conflicts of interest, in fiscal year 

2013, OGE issued its fourth annual report on compliance with and implementation of 

the President’s Executive Order on Ethics (Executive Order 13490). OGE found that 

during calendar year 2012, agencies successfully administered the Ethics Pledge required 

by the Executive Order. Of significance, 618 of 619 appointees required to sign the 

Ethics Pledge in 2012 had done so. One appointee resigned prior to signing the Ethics 

Pledge, but would have been required to sign it if the appointee had remained in the 

position. 

Strategic Objective: Improve Executive Branch Agency Ethics Program Management and 

Professionalism

 In fiscal year 2013, OGE improved executive branch ethics program management 

and professionalism by augmenting its ethics program review process, refining program 

management metrics, expanding educational offerings for ethics officials, and 

formalizing its commitment to the continuous professional development of its staff.

 

On-site reviews of agency ethics programs continued to be an important 

component of OGE’s statutorily mandated oversight activities in fiscal year 2013. The 

primary objective of reviews is to report on the strengths and vulnerabilities of the 

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program by evaluating agency compliance with ethics requirements, and ethics-related 

systems, processes, and procedures. OGE also identifies and shares model practices as

part of its strategy for improving agency ethics programs. In the third quarter of fiscal 

year 2013, OGE developed a new inspection review methodology to augment its review 

program. The objective of an inspection is to provide a useful snapshot of the quality of 

agency implementation of selected core ethics program elements. Inspections will allow 

OGE to more efficiently exercise oversight and ensure on-site monitoring of a 

significantly greater number of agency programs than would be possible exclusively 

through plenary reviews. 

Notable among OGE’s review achievements in fiscal year 2013 was the follow-up 

work OGE conducted related to its 2012 Post-Election Readiness review. OGE worked 

with agencies to address vulnerabilities identified during the review that could impair the 

ability of agency ethics officials to conduct timely, accurate, and consistent conflict of 

interest reviews of PAS nominee financial disclosure reports. As a direct result of the 

Post-Election Readiness review and follow-up work, the Inspector General for an agency 

undertook a special review of the agency’s ethics program due to significant concerns 

highlighted in OGE’s review report. 

 Also of note, in March 2013, the National Academy of Public Administration 

(NAPA) emphasized the value of OGE’s program review function in its independent, 

congressionally mandated report on the STOCK Act. NAPA noted that program reviews 

are a substantial reason for the effective government-wide ethics program. It also stated 

that OGE’s follow-up reviews have successfully underscored the need to find solutions 

and held agencies accountable for making needed changes. In an effort to continue to 

improve the efficiency and effectiveness of OGE’s reviews and the review selection 

process, OGE also standardized its review activities in fiscal year 2013 by developing 

new standard operating procedures. 

 In fiscal year 2013, OGE further advanced its priority of improving agency ethics 

program management and professionalism by significantly expanding educational 

offerings for ethics officials. For example, OGE delivered 27 instructor-led classroom 

and web-based training courses to approximately 1,762 ethics officials on a variety of 

topics. OGE also provided ethics presentations and instruction in various other formats 

reaching 4,249 ethics officials and other government employees. Finally, in, August of 

2013, OGE partnered with the U.S. Department of Agriculture to offer the first 

Government Ethics Symposium. During this single-day event, OGE trained more than 

200 ethics officials from more than 40 departments and agencies on the ethics rules 

surrounding the lifecycle of a Presidential appointee, model ethics program management 

practices, and the implications for the ethics rules after the Supreme Court’s decision in 

Windsor v. United States. OGE plans to build upon the success of this event by partnering 

with other departments and agencies to host twice annual Government Ethics Symposia. 

 OGE also took steps to enhance program management and professionalism in 

fiscal year 2013 by offering additional educational opportunities to the geographically 

dispersed community of ethics officials in an efficient and fiscally responsible manner. 

For example, OGE developed and delivered 14 virtual distance learning events. These

training events covered topics such as STOCK Act requirements, OGE’s recently issued 

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regulatory exemption to 18 U.S.C. § 208 for service on outside boards in an official 

capacity, and navigation of the agency supplemental standards of conduct regulation 

process. Live presentations of these events reached 2,487 officials and recordings of the 

presentations were accessed by an additional 1,400 distinct users. 

 A vital component of ensuring successful program management is an effective 

succession plan. To assist agencies with succession planning in their ethics programs, 

OGE developed, during fiscal year 2013, the Instructor Development Program (IDP), a 

certificate program for ethics instructors who, upon successful completion, will be 

qualified to effectively deliver OGE-developed ethics courses in their own agencies and 

throughout the executive branch. This qualification will assist them in ascending to 

higher positions within their programs as senior program leaders depart or retire.

Finally, in order to assist executive branch ethics officials in the effective 

management of their ethics programs, OGE requires a staff with state-of-the-art ethics 

knowledge, skills, and abilities. To ensure the continuing excellence of OGE’s 

personnel, OGE launched an employee development program in fiscal year 2013 to 

provide time, resources, and support for the continuing professional development of 

OGE staff. The program commits up to 10 percent of a participating employee’s duty 

time to professional development activities such as engaging in research, attending 

internal training, and participating in mentoring and coaching activities. The program is 

cost-effective because it uses internal resources, results in the development of products 

that can be re-used, contributes to knowledge sharing, and plans for succession at a time 

when government is facing an increase in retirements among its employees.

Strategic Objective: Support the Work of Inspectors General and Prosecutors

 In fiscal year 2013, OGE provided direct support to inspector general (IG) 

investigators and Federal prosecutors on the interpretation and application of the conflict 

of interest laws and ethics rules. OGE also collaborated more generally with these groups 

in order to share ethics related information of mutual interest. 

In particular, OGE continued to collaborate with the IG community through the 

Council of Inspectors General on Integrity and Efficiency (CIGIE) and the IG Academy, 

as well as with prosecutors. OGE leadership actively participated as a member of CIGIE, 

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

of these interactions is to assist IGs and prosecutors in understanding the complexities of 

the ethics laws and regulations as they relate to ethics-related investigations and how 

effective ethics programs support enforcement. 

 Additionally, OGE continued to provide training support to IGs. Notably, OGE 

provided its core curriculum on conflicts of interest to members of the Council of 

Counsels to Inspectors General. OGE instructors also provided training at the IG 

Academy. This training on investigating ethics-related matters and working with ethics 

officials has become a standard part of the IG Academy’s curriculum, and complements a 

web-based training module that OGE developed for IG investigators. 

Finally, at the request of the IG Academy, OGE staff participated in the Public 

Corruption Investigations Training Program Curriculum Review Conference. OGE’s 

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participation in the conference led to several modifications to the training program, 

including increased training on public corruption statutes and increased class time 

devoted to practical skills training for investigators.

Strategic Objective: Assist the United States Government in Responding to International 

Anti- Corruption Reporting Requirements and Good Governance Initiatives

Through a variety of multilateral and bilateral activities and at the request of the 

Department of State, OGE continued to support U.S. government anti-corruption 

reporting requirements and good governance goals in fiscal year 2013. Of note, OGE 

provided substantial support for U.S. participation in anti-corruption mutual evaluation 

mechanisms designed to monitor compliance with international anti-corruption standards. 

OGE served as primary lead in researching and writing the U.S. response to 

questionnaires and responding to other calls for information related to good governance. 

OGE also supported U.S. participation, through the provision of technical assistance to or 

service on, U.S. delegations in other multilateral groups and programs. Finally, OGE 

officials served as subject matter expert panelists in several international seminars and 

workshops. 

Priority 2: Harnessing Technology to Promote Transparency, Education, and 

Oversight

In fiscal year 2013, OGE continued to leverage technology in order to promote 

transparency in the executive branch ethics program, to provide training and educational 

materials, and to enhance its oversight function.

Strategic Objective: Implement Executive Branch-Wide Electronic Filing of Public 

Financial Disclosure Reports

 In fiscal year 2013, OGE received funding for and began the development of the 

electronic Federal Ethics and Disclosure System (eFEDS), the electronic filing system 

for executive branch public financial disclosure report filers mandated by the STOCK 

Act. When completed, this system will greatly enhance the filing, review, and program 

management aspects of the executive branch public financial disclosure program. It will 

also increase OGE’s oversight capability by allowing OGE to monitor agencies’ progress 

in administering their individual financial disclosure programs in real time and to 

generate reports identifying trends and weaknesses in their programs. 

A cross-divisional OGE team of attorneys and analysts developed the content for 

eFEDS, which will lead filers through a serious of questions, the answers to which will 

populate the required fields of the public financial disclosure report. This question and 

answer format will simplify the reporting process and will greatly improve the accuracy 

of the reported information. The improved accuracy of reporting will in turn enhance 

ethics officials’ ability to identify and resolve conflicts of interest.

To enhance filer experience, OGE also worked closely with a team of user 

experience professionals. The user experience team is responsible for ensuring that the 

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user interface - i.e., what filers see in any given section of the system - is clear, easily 

understood, and logically leads filers through the reporting process. 

 Throughout the system development process beginning in the fourth quarter of 

fiscal year 2013, OGE has collaborated extensively with financial disclosure report 

filers, executive branch agency ethics officials, and ethics officials and system 

developers from the other branches of government, to share ideas and to ensure that 

eFEDS meets the needs of all stakeholders. This collaboration included dozens of 

meetings and information-sharing events, as well as OGE’s administration of an 

electronic survey of public filers, which was used to gather feedback about their needs 

and expectations. OGE also created an online forum to provide updates to ethics officials 

and to collect input from the ethics community regarding the development of the system. 

Strategic Objective: Leverage Technology to Expand Training Participation

OGE also continued to explore ways to use technology to provide timely 

information to executive branch ethics officials, the vast majority of whom are located 

outside the Washington, DC area. One of OGE’s major accomplishments in this area 

during fiscal year 2013 was the creation of the Institute for Ethics in Government (IEG). 

IEG is a virtual “ethics university” on the MAX.gov website, a government-wide 

collaboration, data collection, and information sharing site. All Federal government 

employees in the executive branch are eligible to register for a MAX Account.

Government employees with a MAX Account can view the course offerings and register 

or apply to participate. Individuals can also access all the materials and recordings for 

OGE’s monthly webinar series on-demand, and can browse and download the education 

and job-related products in the IEG Store. The IEG site also allows ethics officials to 

share their own products with the ethics community.

 OGE further leveraged technology in fiscal year 2013 by launching an official 

agency Twitter account to increase visibility of the executive branch ethics program and 

provide accurate executive branch ethics information to the public and media, thereby 

promoting public confidence. Using its Twitter account, OGE directs its external 

stakeholders to detailed information on its website and provides its external audiences an 

additional way to stay current with OGE’s latest publications as well as changes in 

executive branch ethics laws, regulations, and programs. 

Strategic Objective: Implement Technological Solutions to Agency Information 

Management

OGE also implemented new technical solutions for managing and measuring 

performance in fiscal year 2013. Most notably, OGE developed and launched two new 

electronic information management systems, the Agency Information Management 

System (AIMS) and the Financial Disclosure Tracking System (FDTS).

 AIMS tracks and manages OGE interactions, such as incoming requests for 

guidance and interpretation from over 130 executive branch agencies, Congress, the 

media, and the public. The system also provides OGE officials instant access to ethics 

program-related information about all executive branch agencies. 

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 FDTS tracks the collection, review, and final action on financial disclosure 

reports, ethics agreements, certificates of divestiture, and trust documents for Presidential 

nominees, appointees, and Designated Agency Ethics Officials (DAEOs). This webbased system provides OGE the ability to follow the progress of financial disclosurerelated work throughout the agency and to promptly determine the status of financial 

disclosure reports. 

Priority 3: Ensuring Effective Communications to Enhance Understanding of 

Government Ethics Laws, Policies, and Program Management, and to Promote 

Transparency, Education, and Oversight

 OGE took undertook several initiatives in fiscal year 2013 to enhance its 

communications efforts. These initiatives were targeted at audiences both within and 

outside of the Federal government. 

Strategic Objective: Communicate Effectively Within the Federal Government

 To enhance communication within the Federal government, OGE convened 

numerous meetings and participated in various outreach efforts with a variety of 

audiences in fiscal year 2013. For example, OGE organized regular meetings with the 

most senior ethics practitioners from all three branches of the Federal government in 

order to discuss issues of common interest and to build a professional network dedicated 

to improving ethics government-wide. The relationships and lines of communication

developed in these OGE-led meetings proved invaluable in reaching common 

understandings of ongoing and emerging issues, such as the STOCK Act. Additionally, 

the improved communications facilitated by these meetings contributed to a large 

increase in the number of requests from the legislative branch for technical assistance 

from OGE on a wide range of issues. 

 During fiscal year 2013, OGE also organized a large number of meetings,

conference calls, and webinars with senior executive branch agency ethics officials. For 

instance, OGE held regular meetings with executive branch DAEOs. Through these 

meetings, OGE shared information relevant to managing an effective ethics program, 

discussed current ethics issues facing the executive branch, and received agency input.

 In addition, OGE used the MAX.gov platform to provide information to and 

collaborate with ethics officials. Specifically, in fiscal year 2013, OGE developed the 

Agency Assistance and Outreach Forum on MAX.gov to engage ethics officials in an 

informal exchange of information about a variety of government ethics topics. The forum 

provides up-to-date news on OGE’s latest advisories, programs, and educational 

opportunities; shares ethics-related news articles; and relays information on ethics-related 

legislation that OGE is monitoring. 

 To further its communication efforts, OGE launched two distance-learning series 

through low cost teleconferences: the Ethics Fundamentals Series and the Advanced 

Practitioner Series. The Ethics Fundamentals Series addresses the basics of government 

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ethics in a format convenient to part-time ethics officials and ethics officials in the field. 

The Advanced Practitioner Series addresses advanced topics in a format that is tailored to 

experienced ethics practitioners and provides a forum for these officials to share their 

experiences and expertise with one another. In fiscal year 2013, OGE hosted six 

Fundamentals Series events and eight Advanced Practitioner events. 

 Additionally, OGE utilized a teleconference format to host five separate 

workshops covering public financial disclosure and outside activities regulations. These 

teleconferences allowed OGE to reach a large number of ethics officials at minimal cost.

Further, OGE received positive feedback from participants regarding the quality of the 

material presented during these teleconferences. 

 OGE continued to provide support to agency ethics officials through its Desk 

Officer program. Desk Officers provide instant access to expert advice in applying the 

ethics laws and regulations. During fiscal year 2013, OGE Desk Officers responded to 

approximately 1,927 requests for guidance. In response to the Annual Survey of Ethics 

Officials, a majority of ethics officials responded positively when asked if OGE Desk 

Officers support helps them perform their job. 

OGE also focused on effective communication and collaboration with specific 

Federal groups, such as Federal advisory committee members, senior managers, and 

administrative law judges. Through these interactions, OGE highlighted ethics issues 

specific to these and other groups, and alerted them to any new ethics laws, regulations, 

policies, or guidance. For example, OGE attended and contributed to the 58th Plenary 

Session of the Administrative Conference of the United States concerning adopting 

recommendations to improve consistency in social security disability adjudication and 

improving administrative rulemaking procedures. OGE also presented on various topics 

at the Interagency Ethics Council, including providing an overview of model practices 

concerning the review of PAS public financial disclosure reports. 

Finally, OGE contributed its expertise and significant support to other Federal 

agency training programs in fiscal year 2013. For example, OGE participated in OPM’s 

Employee and Labor Relations Roundtable by providing attendees an introduction to the 

executive branch ethics program with a focus on helping human resource professionals 

understand the ethics rules and manage risk. OPM broadcasted the event across the 

nation to 550 sites, many of which had multiple attendees. In addition, OGE provided 

ethics training at the General Services Administration’s Federal Advisory Committee Act 

management training course and at the Government Accountability Office’s annual 

Appropriations Forum on “Public Private Partnerships.” OGE also delivered 

presentations on the Procurement Integrity Act and organizational risk identification and 

mitigation at the 2013 Deputy Ethics Counselor Workshop at the Department of Health 

and Human Services. Notably, in April of 2013, OGE provided training at the request of 

the White House on public financial disclosure. The training introduced attendees to the 

critical conflicts of interest and financial disclosure concepts. 

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Strategic Objective: Communicate Effectively with the Public and Other Audiences 

Outside of the Federal Government 

 In fiscal year 2013, OGE substantially increased its efforts to reach audiences 

outside of the Federal government, including members of the general public, state and 

local governments, private sector organizations, professional associations, government 

watchdog groups, the media, and foreign delegations. 

 As part of the agency’s continuing effort to promote transparency and 

accountability, and thereby promote public confidence in government, OGE continued to 

make public records readily available on the OGE website. Specifically, in fiscal year 

2013, OGE posted 1,013 public financial disclosure reports and 505 semiannual agency 

reports of travel payments accepted from non-Federal sources. 

 In addition to proactively sharing information through mechanisms such as its 

website, OGE routinely responded to requests from private sector and other nongovernment organizations asking for assistance in clarifying the application of Federal 

ethics laws and rules to their current employees, or Federal employees who volunteer at 

their organizations. By sharing its expertise with these entities, OGE helps to ensure that 

neither they nor their employees inadvertently violate Federal ethics rules. For example, 

in fiscal year 2013 OGE directly issued advice to the counsel of a university on the 

application of an exemption to the post-employment criminal conflict of interest statute 

and to a publishing company concerning the use of title creating the appearance of 

governmental sanction. In both instances, OGE clarified the application of these laws as 

they applied to former or current government employees associated with each entity.

OGE continued its involvement with private sector and professional 

organizations that focus on ethics, such as the Ethics Resource Center, the Ethics and 

Compliance Officer Association, and the Council for Governmental Ethics Laws. 

OGE’s involvement with these organizations not only fosters communications for its 

own sake, but also leads to innovations in OGE’s practices related to training, program 

management, and performance evaluation. 

OGE also engaged with good governance and watchdog groups in fiscal year 

2013. This direct, proactive communication ensures that these non-Federal organizations 

and, by extension, the general public, understand the executive branch ethics program 

and the reasoning behind various policy decisions. These efforts also help OGE to be 

transparent and responsive to public concerns. 

 Some examples of OGE’s collaboration with non-Federal organizations in fiscal 

year 2013 include OGE’s participation in several programs with representatives from the 

American Bar Association Public Contract Law Section’s Ethics, Compliance, and 

Professional Responsibility Committee; The Partnership for Public Service; and the ABA 

Criminal Justice Section as well as presentations at the First Amendment Center; and the 

“Disclosure about Who is Influencing Politics and Policy” symposium hosted by an 

organization named OpentheGovernment.org. 

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OGE continued to share its legal analysis, programmatic experience, and model 

practices with state and local government agencies involved in administering programs 

that support good governance. Much of that sharing occurred through or because of 

OGE’s active participation with 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. OGE 

exchanged good practices through presentations at COGEL’s annual conference, posted

on the COGEL website, and responded to direct requests for information from state and 

local jurisdictions.

 Finally, OGE continued to meet with foreign public and private sector groups 

traveling under the auspices of the State Department International Visitor Leadership 

Program and other similar programs. These delegations come to OGE to learn about the 

ethics program in the executive branch and how that program fits under the broader 

rubric of good governance and transparency. In fiscal year 2013, OGE briefed 35 foreign 

delegations comprised of 494 individuals representing 65 countries. In addition, at a 

program hosted by Georgetown University, OGE addressed a class of graduate students 

from Salzburg University who were completing studies in public administration on ethics 

and organizational risk management.

Creating and Promoting a Positive Performance Culture 

 In addition to advancing the three priorities discussed above, OGE’s new Director 

emphasized the role of internal communications in promoting a culture of performance 

during fiscal year 2013. As a result, OGE enhanced internal communications through a 

variety of methods such as: 

• Conducting quarterly “all hands” meetings with the entire OGE staff to report 

progress toward goals and to provide clear and direct communication about OGE’s 

priorities and direction; 

• Holding regular Executive and Senior Staff meetings to discuss agency goals, 

priorities, and the status of significant program activities; and

• Holding supervisors accountable for ensuring ongoing communication regarding 

OGE goals and priorities with all staff. 

 

 In addition to emphasizing internal communications, OGE took several other 

steps during fiscal year 2013 to promote a culture of performance, including: 

• Preparing a new strategic plan covering fiscal years 2014 through 2017, with input 

from stakeholders in the executive branch ethics community, Congress, good 

government groups, and the general public; 

• Supporting a variety of flexible work and telework schedules consistent with OGE’s 

team-oriented environment;

14
• Continuing support for the agency’s Equal Employment Opportunity (EEO) and 

Diversity and Inclusion programs; and 

• Encouraging employees to participate voluntarily in direct and consequential 

community service consistent with applicable Executive Orders and Office of 

Personnel Management guidelines.

Conclusion 

In conclusion, the performance highlights described in Part II reflect a crossfunctional staff dedicated to advancing the mission of OGE by using innovative, costeffective, and collaborative solutions. 

15
Part III – Management Discussion & Analysis of Results 

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

performance measures during fiscal year 2013. The following measurements are based on 

statistical data from a variety of existing sources, including post-training evaluations; an

annual ethics program questionnaire, surveys following program reviews, and the Annual 

Survey of Ethics Officials.1

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 survey of agency ethics officials’ 

customer satisfaction focused on three areas: (1) the usefulness of OGE guidance; (2) the 

effectiveness of OGE guidance; and (3) OGE’s responsiveness to emerging ethics 

program issues. 

The results related to Objective 1.1 performance measures show that OGE 

exceeded each of its targets. (See Figures 2, 3, and 4) 

1 Several of these performance measures are based on data collected from the Annual Survey of Ethics 

Officials. The survey is distributed to Designated Agency Ethics Officials, Alternate Designated Agency 

Ethics Officials and the Agency Ethics Points of Contact. The survey responses are anonymous and 

agencies may submit more than one response. The response rate for 2012 survey was 35% (n=112). 

2009 2010 2011 2012 2013

Target 85% 90% 90% 90% 90%

Actual 93% 92% 94% 88% 94%

50%

70%

90%

% of ethics officials who say OGE 

provides the guidance needed to 

perform their ethics duties effectively

2009 2010 2011 2012 2013

Target 80% 80% 85% 85% 85%

Actual 88% 87% 90% 85% 87%

50%

70%

90%

% of ethics officials who rate OGE as responsive to emerging ethics 

program issues

2009 2010 2011 2012 2013

Target 95% 95% 95% 95% 95%

Actual 95% 95% 96% 93% 97%

50%

70%

90%

% of ethics officials who rate OGE 

guidance as useful

Figure 3 Figure 2

Figure 4

16
Objective 1.2: Enhance Assistance to and Oversight of Agency Ethics Programs 

While OGE continually receives a great deal of information about ethics program 

administration, on-site monitoring is OGE’s most effective tool for maintaining and 

improving the quality and consistency of the executive branch’s ethics program. OGE’s

plenary reviews are designed to mitigate program vulnerabilities, disseminate model 

practices, and encourage ongoing dialogue among ethics officials and with OGE Desk 

Officers. In fiscal year 2013, OGE completed plenary reviews and follow-up monitoring 

for more than 35 executive branch agencies. Figure 5 shows that OGE exceeded its target 

to add value to agency ethics program and to share model practices during the program 

review process. 

2009 2010 2011 2012 2013 2009 2010 2011 2012 2013

Target 90% 90% 90% 90% 90% 75% 75% 75% 75% 75%

Actual 94% 100% 85% 94% 91% 69% 71% 74% 90% 91%

50%

70%

90%

% of ethics officials who view 

OGE’s program review process as 

adding value to their own 

% of ethics officials who are 

satisfied with information shared 

on ethics program model practices

Figure 5

17
While OGE continued to 

provide support to ethics officials 

through education and training 

opportunities, OGE missed its 

satisfaction target based on results 

from the Annual Survey of Ethics 

Officials (Figure 6). OGE believes 

this decline may be linked to OGE’s

reredeployment of a revamped 

education and training program that 

focused on expanding access to ethics 

officials across the executive branch 

using new methods of delivery. (See

pages 9, 10, 12, 13, and 14 for 

additional information about OGE’s 

education and training program). OGE 

believes this number will 

increase as ethics officials become more familiar with OGE’s refocused education 

program and new training products. In addition, though OGE missed this target, other 

data sources indicate that OGE’s training is more accessible and effective. For example, 

as a result of these new methods of delivery, OGE increased the number of participants’ 

with access to live training by 254%. Further, 94% of course participants responding to 

post-training evaluations stated that they are better able to do their job after OGE training 

(See Figure 7). 

Objective 1.3: Increase Employees’ Awareness of Their Ethics Responsibilities 

 In fiscal year 2013, OGE 

continued to provide training to agency 

ethics officials to assist them in carrying 

out their responsibilities. Notably, 4,249 

ethics officials registered for OGE 

training courses. As shown in Figure 7, 

ethics officials overwhelmingly reported 

that they are better able to do their jobs as

a result of OGE training.

OGE missed targets regarding 

ethics officials satisfaction and 

incorporation of certain OGE training 

products (Figures 8, 9, and 10). In light of 

sequestration and a significant increase 

(68%) in the workload of the nominee program, OGE shifted resources and 

de-emphasized its prior priority to create training products in fiscal year 2013. However, 

OGE still supported ethics officials through the creation of the IEG site which allows 

ethics officials to share their own training products with the ethics community. Since the 

site’s creation, agencies have posted more than 20 training products. Moving forward, 

OGE will continue to encourage ethics officials to share their training products. In 

2009 2010 2011 2012 2013

Target 80% 80% 80% 80% 80%

Actual 86% 85% 87% 82% 68%

50%

70%

90%

% of ethics officials who are satisfied 

with education and training provided to 

support ethics officials

2009 2010 2011 2012 2013

Target 85% 90% 90% 90% 90%

Actual 94% 96% 96% 96% 94%

50%

70%

90%

% of ethics officials reporting that 

they are better able to do their jobs as 

a result of OGE training

Figure 6

Figure 7

18
addition, OGE established new performance goals for fiscal year 2014 that align better 

with its revamped education and training program. 

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

Programs

OGE recognizes and encourages senior officials to play a significant role in 

promoting an ethical culture and supporting the agency’s ethics program. OGE’s new 

Director is committed to continuing to promote leadership support of ethics programs. In 

fiscal year 2014, OGE will continue to leverage the program review and nominee process 

to highlight the importance of the executive branch ethics program and agency 

leadership’s role in supporting it. Figures 11 and 12 show that OGE essentially met its 

targets for Strategic Objective 1.4. 

% of agencies that incorporate 

OGE education or training 

products into their program

% of agencies that incorporate 

OGE-provided education and 

training products to promote 

employee awareness of their ethics 

responsibilities

2009 2010 2011 2012 2013 2009 2010 2011 2012 2013

Target 80% 80% 80% 80% 80% 80% 80% 80% 80% 80%

Actual 80% 76% 82% 79% 72% 82% 71% 79% 73% 71%

50%

70%

90%

2009 2010 2011 2012 2013

Target 75% 75% 75% 75% 75%

Actual 77% 67% 75% 69% 59%

50%

70%

90%

% of ethics officials who are satisfied 

with employee education and training 

products provided by OGE

2009 2010 2011 2012 2013

Target 80% 80% 80% 80% 80%

Actual 71% 66% 70% 64% 62%

50%

70%

90%

% of ethics officials who are satisfied 

with employee education and training 

products designed to promote 

employee awareness of their ethics 

responsibilities

Figure 8

Figure 9 Figure 10

19
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. 

45 PAS officials entered into ethics 

agreements that required compliance 

documentation in fiscal year 2013. As 

reported by DAEOs, 96 percent of ethics 

agreements were satisfied within statutory 

deadlines. (See Figure 13) 

 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 5 days 

after a nomination is made. OGE 

continues to demonstrate a high level of 

success in this area. (See Figure 14) 

2009 2010 2011 2012 2013

Target 90% 90% 90% 90% 90%

Actual 93% 95% 93% 91% 88%

50%

70%

90%

% of ethics officials who indicate that 

their agency's leaders pay attention to 

ethics

2009 2010 2011 2012 2013

Target 90% 90% 90% 90% 90%

Actual 90% 90% 93% 90% 88%

50%

70%

90%

% of ethics officials who indicate that 

their agency's leaders demonstrate 

support for the ethics program

2009 2010 2011 2012 2013

Target 95% 95% 95% 95% 95%

Actual 91% 88% 100% 94% 96%

50%

70%

90%

Compliance with ethics agreements 

within required timeframes

2009 2010 2011 2012 2013

Target 95% 95% 95% 95% 95%

Actual 91% 95% 100% 100% 99%

50%

70%

90%

Resolution of conflicts and technical 

reporting issues for nominee financial 

disclosure reports no later than five 

days after a nomination is made

Figure 11 Figure 12

Figure 13

Figure 14

20
Objective 2.2: Monitor Continued Compliance with Conflict of Interest Laws; and 

Objective 2.3: Administer an Effective Confidential Financial Disclosure System

Financial disclosure is the primary tool executive branch agencies use to identify 

and resolve potential conflicts of interest. Through monitoring and oversight, OGE 

ensures that agencies have implemented effective financial disclosure processes. 

Specifically, as part of the review process, OGE 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 2013, OGE exceeded its targets in 

this area. (See Figure 15) 

 

 

 In furtherance of Objectives 2.2 

and 2.3, OGE continued to encourage 

agencies to use alternative procedures 

for handling confidential financial 

disclosure in fiscal year 2013. 

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, advice 

and counsel, and training. The figure to the right shows continued positive results. 

(See Figure 16) 

2009 2010 2011 2012 2013

Target 90% 95% 95% 95% 95%

Actual 100% 100% 100% 100% 100%

50%

70%

90%

Alternative forms judged by 

compliance division to be effectively 

managed 

% of agencies reviewed that 

provide public filers with feedback 

after reports have been reviewed

2009 2010 2011 2012 2013 2009 2010 2011 2012 2013

Target 90% 95% 95% 85% 85% 90% 90% 90% 85% 85%

Actual 100% 95% 93% 87% 88% 99% 91% 87% 98% 92%

50%

70%

90%

% of agencies reviewed that have 

written procedures for followingup with delinquent filers

Figure 15

Figure 16

21
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 

 During fiscal year 2013, OGE actively coordinated and cooperated with other 

Federal, state, and local government 

agencies that have complementary 

missions and programs. During the 

fiscal year, OGE exceeded its target 

goals for programs and projects with 

other Federal, state, and local agencies 

both in terms of numbers and 

usefulness (See Figure 17). OGE

evaluates the usefulness of its actions 

to others, 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. 

 

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

Groups 

During fiscal year 2013, OGE 

exceeded its target to conduct outreach 

to the public, private sector, and good 

governance groups (See Figure 18). 

OGE’s website is its primary tool for 

communicating with the public. OGE’s 

website saw a 32% increase in unique 

visits during the fiscal year. In addition 

to conducting outreach, OGE responded 

to over 200 requests for assistance from 

these groups. Additional examples of 

specific outreach conducted by OGE to 

the public, private sector, and good 

governance groups are described in Part I. (See information on pages 13-16) 

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

Initiatives

 In fiscal year 2013, OGE continued to receive and fulfill requests to participate in 

substantial programs and projects that help support U.S. foreign policy anti-corruption 

and good governance initiatives. Below is a list of some of the international organizations 

and programs with and in which OGE participated as expert evaluator in mutual 

2009 2010 2011 2012 2013

Target 12 13 13 13 13

Actual 12 21 27 27 22

0 

5 

10 

15 

20 

25 

30 

# of Outreach activities with Federal, 

state, and local entities

2010 2011 2012 2013

Target 14 15 15 15

Actual 12 18 15 17

0 

5 

10 

15 

20 

# of Outreach activities with public, 

private sector, and good governance 

groups 

Figure 17

Figure 18

22
evaluation mechanisms, as a subject-matter panelist, through provision of behind-thescenes technical assistance, or through similar service: 

• 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; and

• Organization of American States (OAS): the follow-up mechanism of the 

Inter-American Convention Against Corruption (MESICIC). 

Figure 19 

OGE also 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 and other similar programs. 

This past fiscal year, 40 delegations comprised of 543 individuals representing 74 

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 fiscal year 2013, OGE provided some 

form of technical assistance in support of U.S. 

foreign policy interests-- whether through 

international technical assistance briefings hosted 

domestically or through international 

presentations –to the countries highlighted in 

blue in figure 20. 

Figure 20

23
24
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.

25
1101 MERCANTILE LANE, SUITE 122 ● LARGO, MD 20774 

PHONE: (240) 770-4900 ● FAX: (301) 773-2090 ● mail@brownco-cpas.com ● www.brownco-cpas.com

INDEPENDENT AUDITOR'S REPORT 

U.S. Office of Government Ethics 

Washington, D.C. 

Report on the Financial Statements 

We have audited the accompanying balance sheets of the U.S. Office of Government Ethics (USOGE) 

as of September 30, 2013 and 2012, and the related statements of net cost, changes in net position, and 

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

the related notes to the financial statements. 

Management’s Responsibility for the Financial Statements 

Management is responsible for the preparation and fair presentation of these financial statements in 

accordance with accounting principles generally accepted in the United States of America; this includes 

the design, implementation, and maintenance of internal control relevant to the preparation and fair 

presentation of financial statements that are free from material misstatement, whether due to fraud or 

error. 

Auditor’s Responsibility

Our responsibility is to express an opinion on these financial statements based on our audit. We 

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

America and the standards applicable to financial audits contained in Government Auditing Standards, 

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

(OMB) Bulletin No. 14-02, Audit Requirements for Federal Financial Statements, as amended. Those 

standards and OMB Bulletin No. 14-02, require that we plan and perform the audit to obtain reasonable 

assurance about whether the financial statements are free from material misstatements. 

An audit involves performing procedures to obtain audit evidence about the amounts and disclosures in 

the financial statements. The procedures selected depend on the auditor’s judgment, including the 

assessment of the risks of material misstatement of the financial statements, whether due to fraud or error. 

In making those risk assessments, the auditor considers internal control relevant to the entity’s preparation 

and fair presentation of the financial statements in order to design audit procedures that are appropriate in 

the circumstances, but not for the purpose of expressing an opinion on the effectiveness of the entity’s 

internal control. Accordingly, we express no such opinion. An audit also includes evaluating the 

appropriateness of accounting policies used and the reasonableness of significant accounting estimates 

made by management, as well as evaluating the overall presentation of the financial statements. 

We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for 

our audit opinion. 

26
2

Opinion on the Financial Statements 

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

financial position of the USOGE as of September 30, 2013 and 2012, and its net costs, changes in net 

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

generally accepted in the United States of America. 

Other Matters 

Accounting principles generally accepted in the United States of America require that the information in 

the Management’s Discussion and Analysis (MD&A) and Required Supplementary Information (RSI) 

sections be presented to supplement the basic financial statements. Such information, although not a part 

of the basic financial statements, is required by the Federal Accounting Standards Advisory Board, who 

considers it to be an essential part of financial reporting for placing the basic financial statements in an 

appropriate operational, economic, or historical context. We have applied certain limited procedures to 

the required supplementary information in accordance with auditing standards generally accepted in the 

United States of America, which consisted of inquiries of management about the methods of preparing the 

information and comparing the information for consistency with management's responses to our inquiries, 

the basic financial statements, and other knowledge we obtained during our audit of the basic financial 

statements. We do not express an opinion or provide any assurance on the information because the limited 

procedures do not provide us with sufficient evidence to express an opinion or provide any assurance. 

Report on Internal Control Over Financial Reporting 

In planning and performing our audit of the financial statements, we considered the USOGE’s internal 

control over financial reporting (internal control) to design audit procedures that are appropriate in the 

circumstances for the purpose of expressing an opinion on the financial statements, but not for the 

purpose of expressing an opinion on the effectiveness of USOGE’s internal control. Accordingly, we do 

not express an opinion on the effectiveness of USOGE’s internal control.

A deficiency in internal control exists when the design or operation of a control does not allow 

management or employees, in the normal course of performing their assigned functions, to prevent, or 

detect and correct, misstatements on a timely basis. A material weakness is a deficiency, or combination 

of deficiencies, in internal control, such that there is a reasonable possibility that a material misstatement 

of the entity’s financial statements will not be prevented, or detected and corrected on a timely basis. A 

significant deficiency is a deficiency, or a combination of deficiencies, in internal control that is less 

severe than a material weakness, yet important enough to merit attention by those charged with 

governance. 

Our consideration of the internal control was for the limited purpose described in the first paragraph of 

this section and was not designed to identify all deficiencies in internal control over financial reporting 

that might be deficiencies, significant deficiencies or material weaknesses. In our fiscal year 2013 audit, 

we did not identify any deficiencies in internal control that we consider to be a material weakness. 

However, material weaknesses may exist that have not been identified. 

27
3

Report on Compliance and Other Matters 

As part of obtaining reasonable assurance about whether USOGE’s financial statements are free from 

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

regulations, contracts and grant agreements, noncompliance with which could have a direct and material 

effect on the determination of financial statement amounts. However, providing an opinion on 

compliance with those provisions was not an objective of our audit, and accordingly, we do not express 

such an opinion. The results of our tests disclosed no instances of noncompliance or other matters that 

are required to be reported under Government Auditing Standards or OMB Bulletin No. 14-02. 

Management’s Responsibility for Internal Control and Compliance 

USOGE’s management is responsible for (1) evaluating effectiveness of internal control over financial 

reporting based on criteria established under the Federal Managers Financial Integrity Act (FMFIA), (2) 

providing a statement of assurance on the overall effectiveness of internal control over financial reporting, 

(3) ensuring USOGE’s financial management systems are in substantial compliance with FFMIA 

requirements, and (4) ensuring compliance with other applicable laws and regulations. 

Auditor’s Responsibilities

We are responsible for: (1) obtaining a sufficient understanding of internal controls over financial 

reporting to plan the audit, (2) testing compliance with certain provisions of laws and regulations that 

have a direct and material effect on the financial statements and applicable laws for which OMB Bulletin 

14-02 requires testing, and (3) applying certain limited procedures with respect to the MD&A and other 

RSI. 

We did not evaluate all internal controls relevant to operating objectives as broadly established by the 

FMFIA, such as those controls relevant to preparing statistical reports and ensuring efficient operations. 

We limited our internal control testing to testing controls over financial reporting. Because of inherent 

limitations in internal control, misstatements due to error or fraud, losses, or noncompliance may 

nevertheless occur and not be detected. We also caution that projecting our audit results to future periods 

is subject to risk that controls may become inadequate because of changes in conditions or that the degree 

of compliance with controls may deteriorate. In addition, we caution that our internal control testing may 

not be sufficient for other purposes. 

We did not test compliance with all laws and regulations applicable to USOGE. We limited our tests of 

compliance to certain provisions of laws and regulations that have a direct and material effect on the 

financial statements and those required by OMB Bulletin 14-02 that we deemed applicable to USOGE’s 

financial statements for the fiscal year ended September 30, 2013. We caution that noncompliance with 

laws and regulations may occur and not be detected by these tests and that such testing may not be 

sufficient for other purposes. 

28
4

Purpose of the Report on Internal Control over Financial Reporting and the Report on Compliance 

and Other Matters 

The purpose of the Report on Internal Control over Financial Reporting and the Report on Compliance 

and Other Matters sections of this report is solely to describe the scope of our testing of internal control 

and compliance and the result of that testing, and not to provide an opinion on the effectiveness of 

USOGE’s internal control or on compliance. These reports are an integral part of an audit performed in 

accordance with Government Auditing Standards in considering USOGE’s internal control and 

compliance. Accordingly, these reports are not suitable for any other purpose. 

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

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

Largo, Maryland 

December 11, 2013 

29
Fiscal Year 2013 Financial Statements 

UNITED STATES OFFICE OF GOVERNMENT ETHICS

BALANCE SHEET

AS OF SEPTEMBER 30, 2013 AND 2012

(In Dollars)

2013 2012

Assets:

Intragovernmental

Fund Balance With Treasury (Note 2) $ 4,996,548 $ 2,461,083 

Accounts Receivable (Note 3) 108,244 53,371 

Total Intragovernmental 5,104,792 2,514,454 

Accounts Receivable, Net (Note 3) 141 352 

Property, Equipment, and Software, Net (Note 4) 719,411 575,734 

Total Assets $ 5,824,344 $ 3,090,540 

Liabilities:

Intragovernmental

Accounts Payable $ 194,162 $ 458,465 

Other (Note 7) 116,894 194,110 

Total Intragovernmental 311,056 652,575 

Accounts Payable 27,662 119,689 

Federal Employee and Veterans' Benefits (Note 6) 412,377 401,523 

Other (Note 7) 902,642 1,254,880 

Total Liabilities (Note 5) $ 1,653,737 $ 2,428,667 

Net Position:

Unexpended Appropriations - Other Funds $ 4,656,283 $ 1,293,834 

Cumulative Results of Operations - Other Funds (485,676) (631,961)

Total Net Position $ 4,170,607 $ 661,873 

Total Liabilities and Net Position $ 5,824,344 $ 3,090,540 

30
UNITED STATES OFFICE OF GOVERNMENT ETHICS

STATEMENT OF NET COST

FOR THE FISCAL YEARS ENDING SEPTEMBER 30, 2013 AND 2012

(In Dollars)

2013 2012

Program Costs: (Note 9)

Salaries and Expenses

Gross Costs $ 14,905,188 $ 14,540,418 

Less: Earned Revenue (143,443) (505,711)

Net Cost of Operations $ 14,761,745 $ 14,034,707 

31
UNITED STATES OFFICE OF GOVERNMENT ETHICS

STATEMENT OF CHANGES IN NET POSITION

FOR THE FISCAL YEARS ENDING SEPTEMBER 30, 2013 AND 2012

(In Dollars)

2013 2012

Cumulative Results of Operations:

Beginning Balances $ (631,961) $ (908,040)

Budgetary Financing Sources:

Appropriations Used 14,327,643 13,701,202 

Imputed Financing Sources (Note 10) 580,387 609,584 

Total Financing Sources 14,908,030 14,310,786 

Net Cost of Operations (14,761,745) (14,034,707)

Net Change 146,285 276,079 

Cumulative Results of Operations $ (485,676) $ (631,961)

Unexpended Appropriations:

Beginning Balances $ 1,293,834 $ 1,567,097 

Budgetary Financing Sources:

Appropriations Received 18,664,000 13,664,000 

Other Adjustments (973,908) (236,061)

Appropriations Used (14,327,643) (13,701,202)

Total Budgetary Financing Sources 3,362,449 (273,263)

Total Unexpended Appropriations $ 4,656,283 $ 1,293,834 

Net Position $ 4,170,607 $ 661,873 

32
UNITED STATES OFFICE OF GOVERNMENT ETHICS

STATEMENT OF BUDGETARY RESOURCES

FOR THE FISCAL YEARS ENDING SEPTEMBER 30, 2013 AND 2012

(In Dollars)

2013 2012

Budgetary Resources:

Unobligated Balance Brought Forward, October 1

$ 

452,333 

$ 

533,611 

Recoveries of Prior Year Unpaid Obligations

 

109,354 

 

63,310 

Other changes in unobligated balance

 

(3,380)

 

(236,060)

Unobligated balance from prior year budget authority, net

 

558,307 

 

360,861 

Appropriations

 

17,693,472 

 

13,664,000 

Spending authority from offsetting collections

 

172,857 

 

484,581 

Total Budgetary Resources

$ 

18,424,636 

$ 

14,509,442 

Status of Budgetary Resources:

Obligations Incurred (Note 12)

$ 

18,000,752 

$ 

14,057,109 

Unobligated balance, end of year:

 Apportioned (Note 2)

 

81,357 

 

200,306 

 Unapportioned (Note 2)

 

342,527 

 

252,027 

Total unobligated balance, end of year

 

423,884 

 

452,333 

Total Budgetary Resources

$ 

18,424,636 

$ 

14,509,442 

Change in Obligated Balance

 Unpaid Obligations:

Unpaid Obligations, Brought Forward, October 1

$ 

2,110,447 

$ 

2,553,021 

Obligations Incurred (Note 12)

 

18,000,752 

 

14,057,109 

Outlays (gross)

 

(15,279,492)

 

(14,436,372)

Recoveries of Prior Year Unpaid Obligations

 

(109,354)

 

(63,310)

Unpaid Obligations, End of Year (Gross)

 

4,722,353 

 

2,110,447 

Uncollected payments:

Uncollected Customer Payments, Federal Sources, Brought Forward, October 

1

 

(101,697)

 

(86,677)

 

33
Change in Uncollected Customer Payments, Federal Sources (47,992) (15,021)

Uncollected Customer Payments, Federal Sources, End of Year

 

(149,689)

 

(101,697)

Obligated Balance, End of Year (Note 2)

$ 

4,572,664 

$ 

2,008,750 

Budget Authority and Outlays, Net:

Budget authority, gross

$ 

17,866,329 

$ 

14,148,581 

Actual offsetting collections

 

(124,865)

 

(469,560)

Change in uncollected customer payments from Federal sources

 

(47,992)

 

(15,021)

Budget Authority, net

$ 

17,693,472 

$ 

13,664,000 

Outlays, gross

$ 

15,279,492 

$ 

14,436,372 

Actual offsetting collections

 

(124,865)

 

(469,560)

34
NOTE 1. SUMMARY OF SIGNIFICANT 

ACCOUNTING POLICIES

A. Reporting Entity

The United States Office of Government 

Ethics (OGE) was established by the Ethics in

Government Act of 1978. To carry out its 

leadership and oversight responsibilities over 

the executive branch ethics program, OGE 

promulgates and maintains enforceable

standards of ethical conduct for

approximately 2.7 million civilian employees 

in over 130 executive branch agencies and the

White House; oversees a financial disclosure 

system that reaches more than 28,000 public

and 325,000 confidential financial disclosure 

report filers; ensures that executive branch 

ethics programs are in compliance with

applicable ethics laws and regulations; 

provides education and training to the more 

than 5,600 ethics officials executive branchwide; conducts outreach to the general public, 

the private sector, and civil society; and shares 

model practices with state, local, and foreign 

governments, and international organizations.

OGE’s greatest resource is its multidisciplinary staff of attorneys, ethics and

financial experts, and support staff. OGE is

a lean organization, with approximately 80

full-time equivalents, and accomplishes its 

responsibilities by organizing cross-functional 

teams to perform such diverse tasks as 

working with Presidential nominees for 

appointments requiring Senate confirmation

to resolve potential financial conflicts of

interest, training executive branch ethics 

officials, and enhancing oversight of

executive branch ethics programs. 

 

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 nonrecurring activity, such as fines, penalties, fees 

and other miscellaneous receipts for services 

and benefits.

OGE has rights and ownership of all assets 

reported in these financial statements. OGE

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 OGE. The Balance Sheet 

presents the financial position of the agency.

The Statement of Net Cost presents 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 Resources presents the sources, 

status, and uses of the agency’s resources and 

follows 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 

OGE in accordance with the hierarchy of 

accounting principles generally accepted in the 

United States of America, standards issued by 

the Federal Accounting Standards Advisory 

Board (FASAB), Office of Management and 

Budget (OMB) Circular A-136, Financial 

Reporting Requirements, as amended, and

OGE accounting policies which are 

summarized in this note. These statements, 

35
with the exception of the Statement of 

Budgetary Resources, are different from 

financial management reports, which are also 

prepared pursuant to OMB directives that are 

used to monitor and control OGE’s use of 

budgetary resources. The 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 the OGE’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. 

OGE 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 OGE 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 expensed as incurred. OGE’s

capitalization threshold is $50,000 for 

individual purchases and $500,000 for bulk 

purchases. Property, equipment, and software 

acquisitions that do not meet the capitalization 

criteria are expensed upon receipt. 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 OGE as a result of transactions or 

events that have already occurred.

36
OGE reports its liabilities under two 

categories, Intragovernmental and With the 

Public. Intragovernmental liabilities represent 

funds owed to another government agency. 

Liabilities with the Public represent 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 other types of vested leave, 

including compensatory, restored leave, and 

sick leave in certain circumstances, are accrued 

at year-end, based on latest pay rates and 

unused hours of leave. Funding will be 

obtained from future financing sources to the 

extent that current or prior year appropriations 

are not available to fund annual and other 

types of vested leave earned but not taken. 

Nonvested leave is expensed when used. Any 

liability for sick leave that is accrued but not 

taken by a Civil Service Retirement System 

(CSRS)-covered employee is transferred to the 

Office of Personnel Management (OPM) upon 

the retirement of that individual. Credit is 

given for sick leave balances in the 

computation of annuities upon the retirement 

of Federal Employees Retirement System 

(FERS)-covered employees effective at 50% 

beginning FY 2012 and 100% in 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 OGE 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 OGE 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

OGE employees participate in either the CSRS 

or the FERS. The employees who participate 

in CSRS are beneficiaries of 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. 

Both CSRS and FERS employees may 

participate in the federal Thrift Savings Plan 

(TSP). FERS employees receive an automatic

agency contribution equal to one percent of 

pay and OGE matches any employee 

contribution up to an additional four percent of 

37
pay. For FERS participants, OGE also 

contributes the employer’s matching share of 

Social Security.

FERS employees and certain CSRS 

reinstatement employees are eligible to 

participate in the Social Security program after 

retirement. In these instances, OGE remits the 

employer’s share of the required contribution.

OGE recognizes the imputed cost of pension 

and other retirement benefits during the 

employees’ active years of service. OPM 

actuaries determine pension cost factors by 

calculating the value of pension benefits 

expected to be paid in the future and 

communicate these factors to OGE for current 

period expense reporting. OPM also provides 

information regarding the full cost of health 

and life insurance benefits. OGE recognized 

the offsetting revenue as imputed financing 

sources to the extent these expenses will be 

paid by OPM.

OGE does not report on its financial statements 

information pertaining to the retirement plans 

covering its employees. Reporting amounts 

such as plan assets, accumulated plan benefits, 

and related unfunded liabilities, if any, is the 

responsibility of the OPM, as the 

administrator. 

L. Other Post-Employment Benefits

OGE 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 OGE

with certain cost factors that estimate the true 

cost of providing the post-retirement benefit to 

current employees. OGE 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 OGE 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. OGE

recognized imputed costs and financing 

sources in fiscal years 2013 and 2012 to the 

extent directed by accounting standards. 

O. Reclassification

Certain fiscal year 2012 balances have been 

reclassified, retitled, or combined with other 

financial statement line items for consistency 

with the current year presentation.

38
NOTE 2. FUND BALANCE WITH TREASURY

Fund balance with Treasury account balances as of September 30, 2013 and 2012, were as 

follows: 

2013 2012

Fund Balances:

Appropriated Funds $ 4,996,548 $ 2,461,083 

Total $ 4,996,548 $ 2,461,083 

Status of Fund Balance with Treasury:

Unobligated Balance

 Available $ 81,357 $ 200,306 

 Unavailable 342,527 252,027 

Obligated Balance Not Yet Disbursed 4,572,664 2,008,750 

Total $ 4,996,548 $ 2,461,083 

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 

fund balance on hand (see also Note 13). 

 

39
NOTE 3. ACCOUNTS RECEIVABLE

Accounts receivable balances as of September 30, 2013 and 2012, were as follows:

2013 2012

Intragovernmental

Accounts Receivable $ 108,244 $ 53,371

Total Intragovernmental Accounts Receivable $ 108,244 $ 53,371

With the Public

Accounts Receivable $ 141 $ 352

Total Accounts Receivable $ 108,385 $ 53,723

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, 2013 and 2012. 

NOTE 4. PROPERTY, EQUIPMENT, AND SOFTWARE

Schedule of Property, Equipment, and Software as of September, 30, 2013 

Major Class

Acquisition 

Cost

Accumulated 

Amortization/

Depreciation

Net Book 

Value

Software-in-Development 719,411 $ $ - $ 719,411

Total $ 719,411 $ - $ 719,411

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

40
NOTE 5. LIABILITIES NOT COVERED BY BUDGETARY RESOURCES

The liabilities for OGE as of September 30, 2013 and 2012, 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. 

2013 2012

Intragovernmental – FECA $ 76,818 $ 78,289

Intragovernmental – Unemployment Insurance - 12,341

Unfunded Leave 717,166 729,341

Actuarial FECA 412,377 401,523

Total Liabilities Not Covered by Budgetary Resources $ 1,206,361 $ 1,221,494

Total Liabilities Covered by Budgetary Resources 447,376 1,207,173

Total Liabilities $ 1,653,737 $ 2,428,667

FECA liabilities represent the unfunded liability for actual workers compensation claims paid on

OGE’s behalf and payable to the DOL. OGE 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 beneficiaries of employees whose 

death is attributable to a job-related injury or occupational disease. Claims incurred for benefits 

under FECA for OGE’s employees are administered by the DOL and ultimately paid by OGE

when funding becomes available.

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

method of determining the liability uses historical benefits payment patterns for a specific 

incurred period to predict the ultimate payments for the period. Based on the information 

provided by the DOL, OGE’s liability as of September 30, 2013 and 2012, was $412,377 and 

$401,523 respectively.

41
NOTE 7. OTHER LIABILITIES

Other liabilities account balances as of September 30, 2013 were as follows:

Current Non Current Total

Intragovernmental

FECA Liability $ 34,538 $ 42,280 $ 76,817

Payroll Taxes Payable 40,077 - 40,077

Total Intragovernmental Other Liabilities $ 74,615 $ 42,280 $ 116,894

With the Public

 Payroll Taxes Payable $ 6,852 $ - $ 6,852

 Accrued Funded Payroll and Leave 178,623 - 178,623

 Unfunded Leave 717,167 - 717,167

Total Public Other Liabilities $ 902,642 $ - $ 902,642

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

 

42
NOTE 8. LEASES

Operating Leases

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

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

February 1, 2014:

Operating Lease:

Fiscal Year Office Space

2014 $ 478,711 

Total Future Payments $ 478,711 

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 OGE 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:

2013 2012

Program Costs

 Intragovernmental Costs $ 5,361,483 $ 5,168,336

 Public Costs 9,389,244 9,372,082

 Total Program Costs $ 14,750,727 $ 14,540,418

 Intragovernmental Earned Revenue (107,027) (491,925)

 Public Earned Revenue (36,416) (13,786)

 Net Program Costs $ 14,607,284 $ 14,034,707

NOTE 10. IMPUTED FINANCING SOURCES

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

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

responsibility of the administering agency, OPM. For the year ended September 30, 2013 and 

2012, imputed financing was $425,926 and $609,584 respectively 

NOTE 11. BUDGETARY RESOURCE COMPARISONS TO THE BUDGET OF THE 

UNITED STATES GOVERNMENT

The President’s Budget that will include fiscal year 2013 actual budgetary execution information 

has not yet been published. The President’s Budget is scheduled for publication in February 2014 

and can be found at the OMB Web site: http://www.whitehouse.gov/omb/. The 2014 Budget of 

the United States Government, with the "Actual" column completed for 2012, has been 

reconciled to the Statement of Budgetary Resources and there were no material differences. 

43
NOTE 12. APPORTIONMENT CATEGORIES OF OBLIGATIONS INCURRED

Obligations incurred and reported in the Statement of Budgetary Resources in 2013 and 2012 

consisted of the following:

2013 2012

Direct Obligations, Category A $ 13,075,764 $ 13,563,869

Direct Obligations, Category B 4,740,000 -

Reimbursable Obligations, Category A 184,987 493,240

Total Obligations Incurred $ 18,000,752 $ 14,057,109

 Category A apportionments distribute budgetary resources by fiscal quarters.

Category B apportionments typically distribute budgetary resources by activities, projects, objects 

or a combination of these categories.

NOTE 13. UNDELIVERED ORDERS AT THE END OF THE PERIOD

For the fiscal years ended September 30, 2013 and 2012, budgetary resources obligated for 

undelivered orders amounted to $4,760,901 and $890,934, respectively.

NOTE 14. CUSTODIAL ACTIVITY

OGE’s custodial collection primarily consists of Freedom of Information Act requests. While 

these collections are considered custodial, they are neither primary to the mission of OGE nor

material to the overall financial statements. OGE’s total custodial collections are $0 and $(663)

for the years ended September 30, 2013, and 2012, respectively. 

44
NOTE 15. RECONCILIATION OF NET COST OF OPERATIONS TO BUDGET 

OGE has reconciled its budgetary obligations and non-budgetary resources available to its net 

cost of operations.

2013 2012

Resources Used to Finance Activities:

Budgetary Resources Obligated

Obligations Incurred $ 18,000,752 $ 14,057,109

Spending Authority From Offsetting Collections and Recoveries (282,211) (547,891)

Net Obligations 17,718,541 13,509,218

Other Resources

Imputed Financing From Costs Absorbed By Others 425,926 609,584

Net Other Resources Used to Finance Activities 425,926 609,584

Total Resources Used to Finance Activities 18,144,467 14,118,802

Resources Used to Finance Items Not Part of the Net Cost of Operations (3,548,250) (110,168)

Total Resources Used to Finance the Net Cost of Operations 14,596,217 14,008,634

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

Generate Resources in the Current Period: 11,067 26,073

Net Cost of Operations $ 14,607,284 $ 14,034,707

45