I am pleased to present the Strategic Plan of the U.S. Office of 

Government Ethics (OGE) for fiscal years 2018 through 2022. This Plan

reflects OGE’s commitment to its important mission of preventing 

conflicts of interest in the executive branch. Government leaders and 

employees take actions and make decisions every day that affect the 

wellbeing of citizens and people around the world. It is critical to our 

democracy that the people trust that those decisions are made based on 

the public interest rather than one’s personal interests. 

To that end, OGE commits to the important strategic goals of:

 • Advancing a strong, uniform executive branch ethics 

 program;

 • Holding the executive branch accountable for carrying 

 out an effective ethics program;

 • Contributing to the continuity of senior leadership in 

 the executive branch; and

 • Engaging the public in overseeing government 

 integrity.

 Ensuring the impartiality of executive branch decisionmaking 

and enabling the public’s trust in its government is imperative and our 

shared responsibility to our democracy. OGE looks forward to working 

with all of its stakeholders to make progress on these important goals 

toward accomplishing its mission. 

Sincerely,

David J. Apol

 Acting Director and General Counsel

A MESSAGE FROM THE

ACTING DIRECTOR
UNITED STATES

OFFICE OF

GOVERNMENT

ETHICS

-

2018

22

FISCAL YEARS

STRATEGIC

PLAN
MISSION

PROVIDE OVERALL 

LEADERSHIP AND 

OVERSIGHT OF THE 

EXECUTIVE 

BRANCH 

ETHICS PROGRAM 

DESIGNED TO 

PREVENT AND 

RESOLVE 

CONFLICTS OF 

INTEREST
1

PART I – OGE’S MISSION i

 The U.S. Office of Government Ethics (OGE), established by the 

Ethics in Government Act of 1978, provides overall leadership and 

oversight of the executive branch ethics program, which is designed to 

prevent and resolve conflicts of interest. OGE’s mission is part of the 

very foundation of public service. The first principle in the Fourteen 

General Principles of Ethical Conduct for Government Officers and 

Employees is, “Public service is a public trust, requiring employees to 

place loyalty to the Constitution, the laws and ethical principles above 

private gain.” 

 Each day, some part of the ethics program is at work in every 

agency in the executive branch. The program ensures that Presidential 

appointees are aware of their ethical obligations and role in creating an 

ethical culture in their organizations as they begin Government service. 

It ensures that public servants at all levels remain free from conflicts of 

interest and even the appearance of conflicts of interest, as they carry out 

the responsibilities the American people have entrusted to them. It 

ensures that employees who are seeking to leave the Government avoid 

conflicts of interest, and, after they leave, it ensures that they do not 

exercise undue influence over their former agencies on behalf of others. 

Above all, it is working to protect the public’s trust in Government.

“Public service is a public 

trust, requiring employees 

to place loyalty to the 

Constitution, the laws and 

ethical principles above 

private gain.” 5 CFR § 2635.101
2

PART II – ORGANIZATIONAL 

STRUCTURE

i

 The Ethics in Government Act charges OGE with leading the effort 

to prevent conflicts of interest in the executive branch. OGE undertakes 

this important prevention mission as part of a framework comprising 

executive branch agencies and entities 

whose work focuses on institutional 

integrity. In addition to Government 

ethics, this framework includes merit 

system protections in the civil service; 

full and open competition in 

procurement; fiscal controls; 

transparency programs; investigation of 

waste, fraud, and abuse; and criminal, 

civil, and administrative enforcement. 

Potential violations of legal authorities 

established under this framework, including Government ethics 

authorities, are primarily investigated by the thousands of Inspectors 

General staff members across the executive branch. In addition, the 

Department of Justice has enforcement authority that includes both civil 

and criminal penalties.

 Within this framework, the ethics program works to ensure that 

public servants impartially carry out the governmental responsibilities 

entrusted to them, and that they serve as good stewards of public 

resources. Toward these goals, the mission of the ethics program centers 

on preventing conflicts of interest and the appearance of conflicts of 

interest that stem from financial interests, business or personal 

relationships, misuse of official position, official time, or public 

resources, and the receipt of gifts.

 Taken together, the systems in place to identify and address 

conflicts of interest establish a foundation on which to build and sustain 

an ethical culture in the executive branch. 

Institutional Integrity in the Executive Branch 

IDENTIFICATION

PREVENTION

ENFORCEMENT

EXECUTIVE

AGENCIES

OFFICE OF

GOVERNMENT ETHICS

INVESTIGATION

DEPARTMENT

OF JUSTICE

OFFICES OF

INSPECTOR GENERAL

Figure 1: Institutional Integrity
3

 The executive branch ethics program is a shared responsibility. 

As the supervising ethics office, OGE sets policy for the entire 

executive branch ethics program. The head of each agency is statutorily 

responsible for leading the program. This includes creating an ethical 

culture by demonstrating a personal commitment to ethics and 

providing the necessary resources to implement a strong and effective 

agency ethics program. 

 The agency head is also responsible for selecting a Designated 

Agency Ethics Official (DAEO), the employee with primary 

responsibility for directing the daily activities of an agency's ethics 

program and coordinating with OGE. Often, additional professional 

ethics staff are necessary to effectively carry out important ethics 

program responsibilities. Each agency’s employees, supervisors, 

human resources officials, and Inspectors General also play a 

significant role in maintaining the integrity of Government programs 

and operations. 

OGE and Executive Branch Agencies

Figure 2: OGE and the Executive Branch 

OGE

~75

~5,000

~1,100

~2.7 MILLION

AGENCY ETHICS OFFICIALS

CIVILIAN EXECUTIVE BRANCH EMPLOYEES

AGENCY SENIOR LEADERS
4

 To carry out its vital leadership and oversight responsibilities for 

the executive branch ethics program, OGE:

 • Promulgates, maintains, and advises on enforceable standards of ethical 

 conduct for the nearly 3 million employees in over 130 executive branch 

 agencies, including the White House; 

 • Oversees a financial disclosure system that reaches more than 26,000 

 public and more than 380,000 confidential financial disclosure report 

 filers; 

 • Ensures that executive branch agency ethics programs are in compliance 

 with applicable ethics laws and regulations;

 • Provides education and training to the nearly 5,000 ethics officials 

 executive branch-wide; 

 • Conducts outreach to the general public, the private sector, and 

 non-governmental organizations; and 

 • Provides technical assistance to the Congress, state, local and foreign 

 governments, associations, and international organizations.

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

ethics and financial experts, and other key personnel. OGE is a lean 

organization, operating at fewer than its 80 authorized full-time 

equivalents. OGE is led by a Director who is appointed to a five-year 

term by the President and confirmed by the Senate. As shown in the 

organizational chart, in addition to the Office of the Director, OGE is 

divided into four divisions that work together to carry out OGE’s 

mission.

How OGE Provides Leadership and Oversight

Figure 3: OGE Organizational Chart

DIRECTOR

OFFICE OF THE

CHIEF OF STAFF

Program Counsel

Division

Compliance

Division

Internal

Operations

Division
5

 OGE’s Strategic Plan (Plan) establishes a framework for OGE to 

use when developing planned work to carry out its mission over the 

next five years. OGE’s Plan is structured around four strategic goals, 

nine strategic objectives, and three management objectives. 

 OGE’s four strategic goals are (1) Uniformity; (2) Accountability; 

(3) Continuity; and (4) Engagement. These goals reflect the broad, 

long-term outcomes OGE aspires to achieve in order to fulfill its 

mission of preventing conflicts of interest and its vision of achieving a 

high level of public confidence in the integrity of executive branch 

programs and operations. 

 Nine strategic objectives encompass OGE’s key activities and 

describe the strategies OGE will take towards achieving each of the 

four strategic goals. In addition, three management objectives reflect 

OGE’s management priorities and directly support OGE’s 

accomplishment of its mission. 

Figure 4: Strategic Goals and Objectives Framework

PART III – STRATEGIC GOALS 

AND OBJECTIVES

i

Uniformity Accountability Continuity Engagement

Strategic Objective 1.1:

Provide Expert Guidance and 

Support to Stakeholders

Strategic Objective 1.2:

Strengthen the Expertise of 

Officials Who are Integral to the 

Executive Branch Ethics 

Program 

Strategic Objective 1.3:

Continuously Refine Ethics 

Policy and Issue Interpretive 

Guidance

Strategic Objective 2.1:

Monitor Agency Compliance with 

Executive Branch Ethics 

Program Requirements

Strategic Objective 2.2:

Monitor Senior Leaders’ 

Compliance with Individual 

Ethics Commitments 

Strategic Objective 3.1:

Prepare for a Presidential 

Transition

Strategic Objective 3.2:

Provide Assistance to the 

President and the Senate in the 

Presidential Appointment 

Process

Strategic Objective 4.1:

Inform the Public about OGE 

and the Executive Branch Ethics 

Program

Strategic Objective 4.2:

Make Government Ethics 

Information Publicly Available

Management Objective 5.1:

Sustain a Strong Culture of Performance Management

Management Objective 5.3:

Continuously Enhance OGE’s Information Systems and Processes

Management Objective 5.2:

Strengthen Organizational Compliance and Fiscal Stewardship
6

STRATEGIC GOAL i

 OGE was created to prevent conflicts of interest on the 

part of executive branch employees. The absence of a 

strong, uniform executive branch ethics program with clear 

and consistent rules, guidance, support, and training could 

lead to ethical lapses and a loss of public confidence in 

Government. 

 To achieve its strategic goal of advancing a strong, 

uniform executive branch ethics program, OGE developed 

three strategic objectives. 

 These objectives are: 

 (1.1) Provide Expert Guidance and Support to 

 Stakeholders;

 (1.2) Strengthen the Expertise of Officials Who are Integral 

 to the Executive Branch Ethics Program; and

 (1.3) Continuously Refine Ethics Policy and Issue 

 Interpretive Guidance. 

Advance a Strong, Uniform Executive Branch 

Ethics Program
7

 OGE provides expert guidance and support to stakeholders to 

promote consistent interpretation and application of ethics laws and 

regulations across the executive branch. OGE will accomplish this 

objective through a variety of activities. Through its Desk Officer 

Program, OGE will continue to provide the nearly 5,000 agency 

ethics officials with instant access to expert advice in applying the 

ethics laws and regulations so that they may support the nearly 3 

million federal employees in impartially carrying out their 

Government work. OGE will also continue to provide support to 

agencies and financial disclosure filers that use OGE’s electronic 

financial disclosure system, Integrity, through orientations, training, 

and help desk services. 

 In addition to assisting executive branch ethics officials, OGE 

will continue to respond to requests for expert assistance and to 

direct outreach efforts toward other key stakeholders whose 

activities intersect with the ethics program. These stakeholders 

include the Congress, executive branch investigative and 

enforcement communities, and OGE’s international counterparts.

STRATEGIC OBJECTIVE 1.1:

Provide Expert Guidance and Support to Stakeholders

EVALUATING PROGRESS 

Examples of potential measures and indicators for Strategic Objective

1.1.:

• Percent of ethics officials who believe OGE timely communicates 

 ethics-related information

• Percent of ethics officials who believe OGE Desk Officer assistance helps them 

 perform their job duties

• Number of requests for assistance from ethics officials and the number of 

 requests for technical assistance from other stakeholders

• Percent of agency administrators satisfied with the support provided by OGE 

 on its electronic public financial disclosure filing system
8

 OGE seeks to strengthen the expertise of all officials who are 

integral to the executive branch ethics program. In addition to agency 

ethics officials who are directly tasked with ethics responsibilities, 

other officials such as agency leaders, Inspectors General, and human 

resources professionals each play a significant role in carrying out an 

effective ethics program. 

 To strengthen these officials’ ethics expertise, OGE will 

continue to provide a variety of professional development 

opportunities. In particular, OGE will use high-return, low-cost 

methods of delivery, such as targeted intensive training, distance 

learning technologies, and the National Government Ethics Summit. 

Through these and other events, OGE will provide opportunities for 

ethics officials to collaborate with OGE and to learn from one 

another. In addition, OGE will continue to develop its library of 

ethics learning tools and provide insights on methods to improve 

program effectiveness. 

EVALUATING PROGRESS 

Examples of potential measures and indicators for Strategic

Objective 1.2.: 

• Percent of ethics officials who believe, after participating in an OGE training 

 event that they can more effectively perform their job functions

• Percent of ethics officials who believe, after using a learning tool provided by 

 OGE that they can more effectively perform their job function

• Number of registrants for OGE courses

• Number of online views of OGE’s courses and learning tools

STRATEGIC OBJECTIVE 1.2:

Strengthen the Expertise of Officials Who are Integral to the 

Executive Branch Ethics Program
9

 Executive branch ethics officials rely on OGE to provide clear 

policies and guidance on the laws and regulations, such as the 

criminal conflict of interest laws and Standards of Ethical Conduct 

for Employees of the Executive Branch, that serve as the building 

blocks of the executive branch ethics program. Therefore, OGE will 

continue to review its regulations for necessary revisions, refine its 

policies and guidance to address new requirements, respond to novel 

issues, and adapt to changes in the way government accomplishes its 

mission. OGE will also evaluate requests from agencies to tailor their 

ethics programs.

 In addition, OGE will continue to work to ensure that its 

policies are sound and practicable, and that its guidance is 

understandable, clearly communicated, and disseminated widely. 

OGE will accomplish these objectives primarily through the 

publication of legal and program advisories, which provide 

necessary interpretive guidance on legal and program requirements. 

STRATEGIC OBJECTIVE 1.3:

Continuously Refine Ethics Policy and Issue Interpretive 

Guidance

EVALUATING PROGRESS

Examples of potential measures for Strategic Objective 1.3.:

• Percent of ethics officials who believe Legal and Program Advisories help 

 them perform their job duties

• Milestones for regulatory revisions 
10

STRATEGIC GOAL ii

 As the supervising ethics office of the executive 

branch, OGE is responsible for conducting oversight to 

ensure compliance across the more than 130 federal 

agencies. 

 To achieve its strategic goal of holding the executive 

branch accountable for carrying out an effective ethics 

program, OGE has developed two strategic objectives. 

 These objectives are:

 (2.1) Monitor Agency Compliance with Executive Branch 

 Ethics Program Requirements; and

 (2.2) Monitor Senior Leaders’ Compliance with Individual 

 Ethics Commitments. 

Strategic Goal II: Hold the Executive Branch 

Accountable for Carrying Out an Effective 

Ethics Program
11

 OGE monitors agency compliance with executive branch 

ethics program requirements in order to mitigate program 

vulnerabilities at each agency and to identify executive branchwide 

trends. OGE will continue to evaluate agency ethics programs by 

conducting program reviews; and analyzing data collected annually 

from each agency about the administration of its ethics program.

STRATEGIC OBJECTIVE 2.1:

Monitor Agency Compliance with Executive Branch 

Ethics Program Requirements

EVALUATING PROGRESS 

Examples of potential measures and indicators for Strategic Objective

2.1.:

• Percent of cases in which a program weakness identified during an OGE 

 program review results in improvements in the agency’s ethics program

• Percent of agency ethics programs reviewed within established time frames 
12

 OGE monitors senior Government leaders’ compliance with 

individual ethics commitments to ensure that executive branch 

officials at the highest level conduct the Government’s business 

impartially. OGE will continue working to ensure that executive 

branch leaders appointed by the President and confirmed by the 

Senate remain free of conflicts of interest after taking office. 

Specifically, OGE oversees the development of ethics agreements 

between agencies and nominees and tracks compliance with such 

agreements. OGE requires new senior leaders to certify in writing 

that they have taken actions to comply with their ethics agreements. 

After the appointee is nominated and confirmed, OGE also 

conducts second-level reviews of their annual, periodic transaction, 

and termination financial disclosure reports to ensure that agencies 

timely review these disclosures for conflicts of interest and that 

filers continue to comply with their ethics agreements. 

STRATEGIC OBJECTIVE 2.2:

Monitor Senior Leaders’ Compliance with Individual 

Ethics Commitments

EVALUATING PROGRESS 

Examples of potential measures for Strategic Objective 2.2.: 

• Percent of officials who comply with their ethics agreements

• Percent of public financial disclosure reports required to be submitted to OGE 

 for second-level review that are closed within established time frames
13

STRATEGIC GOAL iii

 OGE has a vital role in supporting the President’s 

constitutional duty to nominate and appoint officers to the 

executive branch, and to prevent the highest officials in 

government from having conflicts of interest. 

 To achieve its strategic goal of contributing to the 

continuity of senior leadership in the executive branch, 

OGE has developed two strategic objectives.

 These objectives are:

 (3.1) Prepare for a Presidential Transition; and

 (3.2) Provide Assistance to the President and the Senate

 in the Presidential Appointment Process. 

Contribute to the Continuity

of Senior Leadership in the Executive Branch
14

 OGE must prepare for the possibility of a full change in 

Administration after a Presidential election every four years. To 

prepare for a Presidential transition, OGE participates in federal 

transition councils, collaborates with other transition service 

providers, updates necessary resources, publishes legal advisories 

on relevant topics, and provides training on transition-related 

topics. OGE also works with representatives of Presidential 

candidates in connection with their financial disclosure reports and 

supports early transition efforts of a newly elected President. 

STRATEGIC OBJECTIVE 3.1:

Prepare for a Presidential Transition

EVALUATING PROGRESS 

Examples of potential measures for Strategic Objective 3.1.: 

• Actively engage and/or coordinate with agencies and organizations focused 

 on preparing for and executing a smooth Presidential transition

• Timely update key transition-related resources

• Provide internal and external training on financial disclosure
15

 Following a Presidential election and throughout an 

Administration, OGE continuously assists the President and the 

Senate in the Presidential appointment process. OGE provides an 

independent review of the financial disclosure reports of 

individuals being considered for the highest-level positions in the 

executive branch. OGE works with the White House and executive 

branch agencies to ensure that these individuals comply with the 

extensive requirements for financial disclosure under the Ethics in 

Government Act. OGE leverages its secure, web-based electronic 

filing system, Integrity, to improve the accuracy of the disclosures 

and the efficiency of the process. When potential financial conflicts 

of interest are detected, OGE identifies remedies to resolve them so 

that the President’s appointees can carry out their duties free from 

those conflicts. Once this process is complete and the individual is 

nominated, OGE certifies the report and transmit the package of 

ethics documents to the Senate. 

STRATEGIC OBJECTIVE 3.2:

Provide Assistance to the President and the Senate in the 

Presidential Appointment Process

EVALUATING PROGRESS 

Examples of potential measures for Strategic Objective 3.2.: 

• Initial comments on draft financial disclosure reports of Presidential 

 nominees for Senate confirmed appointments are provided to the agency 

 within established time frames

• Final financial disclosure reports of Presidential nominees for Senate 

 confirmed appointments are certified by OGE within established time frames
16

STRATEGIC GOAL iv

 OGE’s prevention mission involves engaging the 

public to inform them about the systems in place to detect 

and resolve conflicts of interests of their Government 

leaders. This, in turn, allows the public to engage in 

overseeing the integrity of its Government. 

 To achieve its strategic goal of engaging the public in 

overseeing Government integrity, OGE has developed two 

strategic objectives. 

 These objectives are:

 (4.1) Inform the Public about OGE and the Executive 

 Branch Ethics Program; and

 (4.2) Make Ethics Information Publicly Available. 

Engage the Public in Overseeing Government 

Integrity
17

 OGE informs the public and other key stakeholders about 

OGE and the executive branch ethics program to raise awareness of 

and increase confidence in the systems in place to detect and resolve 

conflicts of interest. In support of this effort, OGE will refine its 

communication strategies, collaborate and engage with a broader 

array of stakeholders, timely respond to external requests for 

information and assistance, and provide relevant, understandable 

information to enable citizens to hold their Government 

accountable. 

STRATEGIC OBJECTIVE 4.1:

Inform the Public about OGE and the Executive Branch 

Ethics Program

EVALUATING PROGRESS 

Examples of potential indicators for Strategic Objective 4.1:

• OGE’s Twitter engagement rate

• Number of page views and unique visitors to OGE’s website

• Number of outreach activities

• Number of requests for assistance 
18

 OGE makes ethics information publicly available to increase 

public confidence in Government decisionmaking. Ethics 

information includes reports and data on agency ethics program 

compliance, the public financial disclosures and ethics agreements 

of senior leaders, and written policy guidance. OGE will direct its 

efforts toward improving existing datasets, identifying potential 

new datasets, streamlining the collection process of ethics 

information, posting documents timely, and making resources and 

information easy to locate and access. OGE will seek to improve 

stakeholders’ understanding of the ethics resources and information 

available to them, as well as how to use these resource and 

information.

STRATEGIC OBJECTIVE 4.2:

Make Government Ethics Information Publicly Available

EVALUATING PROGRESS 

Examples of potential measures and indicators for Strategic Objective 

4.2.: 

• Percent of ethics documents made available within established time frames

• Stakeholder feedback on the clarity of how to access and use ethics materials

• Number of ethics documents requested 
19

MANAGEMENT OBJECTIVE 5.1:

Sustain a Strong Culture of Performance 

Management

 OGE will sustain a culture of performance through 

continuous employee engagement and professional 

development, effective internal communication, creation and 

revision of necessary policies, employee and organizational 

accountability, process improvement, performance 

measurement, and quality human capital. OGE will strive to 

adapt and respond to ever-changing environments.

EVALUATING PROGRESS 

Examples of potential indicators for Strategic Objective 5.1.:

• OGE’s score on the Employee Engagement Index on the Federal 

 Employee Viewpoint Survey

• Number of standard operating procedures updated or created

MANAGEMENT

OBJECTIVES
20

MANAGEMENT OBJECTIVE 5.2.:

Strengthen Organizational Compliance and Fiscal 

Stewardship

 OGE strengthens its organizational compliance and fiscal stewardship 

by continuously evaluating its practices and systems to identify areas in 

need of improvement. OGE will remain a responsible steward of taxpayer 

dollars as reflected by its existing track record of strong financial 

management. OGE will continue to pursue efficiencies, such as the 

economies of scale resulting from its use of shared service centers for a 

significant number of support services. OGE will also strive to remain 

compliant with the wide array of requirements applicable to federal 

agencies. 

EVALUATING PROGRESS

Examples of potential measures and indicators for Strategic Objective 5.2.:

• Percent of OGE employees who take required training (i.e., records, security, privacy, 

 ethics)

• Results of annual financial audit

• Results of Cybersecurity Risk Management Assessment
21

MANAGEMENT OBJECTIVE 5.3.:

Continuously Enhance OGE’s Information Systems 

and Processes

 OGE prioritizes its activities to continuously enhance and secure its 

information systems and processes. These systems and processes include 

OGE’s executive branchwide electronic financial disclosure filing system, 

Integrity, as well as numerous internal applications, policies, and operating 

procedures. OGE will also maintain a strong, secure IT infrastructure, 

which is necessary to mitigate risk and to allow OGE to conduct its 

mission-critical work. 

EVALUATING PROGRESS 

Examples of potential measures and indicators for Strategic Objective 5.3.:

• Percent of downtime of Integrity, OGE’s network, and website

• Results of Cybersecurity Risk Management Assessment

• Feedback from Integrity and website users
22

 OGE’s Strategic Plan assumes adequate levels of fiscal and 

human resources. From experience, OGE knows that the agency will 

face certain external factors and, to the extent possible, has factored 

those into this Plan. For example, prior to and immediately after a 

Presidential election, regardless of the outcome, OGE experiences a 

particularly large and varied workload, requiring it to shift resources to 

support the Administration in the Senate confirmation process. OGE 

must balance its vital role in ensuring that Presidential nominees for 

civilian positions requiring Senate confirmation are free of conflicts of 

interest with its mission-critical work that is not directly related to a 

transition. In addition, in fiscal 2017, OGE and the executive branch 

ethics program experienced a significant increase in stakeholder interest 

and resulting workload. It is uncertain whether these demands will 

continue in a manner that would affect the Plan. 

 OGE will use its available resources to make progress toward its 

objectives while navigating these and other external factors that may 

arise between 2018-2022. 

PART IV – EXTERNAL FACTORS i
23

 OGE has long understood the importance of using evidence and 

evaluation to measure the effectiveness of both the executive branch 

ethics program and OGE’s mission activities in support of the executive 

branch ethics program. Historically, OGE has gathered evidence 

through direct feedback from executive branch agency ethics officials 

and stakeholders in written and verbal form, including:

 • Conducting reviews of agency ethics programs;

 • Surveying ethics officials annually to assess their satisfaction with OGE’s 

 guidance, training, and overall efforts; 

 • Surveying employees through the Merit Systems Protection Board 

 employee surveys to assess their understanding of the executive branch 

 ethics rules;

 • Collecting information annually from each agency about their ethics 

 program to gain insight into their operations; 

 • Collecting written evaluations from participants after OGE’s training 

 events to ensure that training is effective and useful; 

 • Conducting research on academic practices related to managing ethics 

 programs;

 • Analyzing requests for assistance from agency ethics officials and the 

 public to identify trends;

 • Utilizing metrics gathered from OGE’s website to gauge public interest; 

 and

 • Assessing responses by OGE employees to OPM’s Employee Viewpoint 

 Survey to measure employee engagement, among other things. 

 OGE consistently looks for opportunities through its mission 

activities to gather valuable information and evaluate the effectiveness 

of its programs. OGE prioritizes work by continuously analyzing data 

sources and conducting outreach to the ethics community and other 

external stakeholders. This approach ensures that OGE allocates its 

resources according to areas with the greatest demand, such as the need 

for additional guidance, support, education, oversight, or outreach. 

PART V – EVIDENCE BUILDING
24

Organizational Structure

OFFICE OF THE DIRECTOR

 The Director is appointed to a five-year term by the President and is confirmed by 

the Senate. The Office of the Director provides overall direction to the executive branch 

ethics program and is responsible for ensuring that OGE fulfills its mission. The Director 

also serves as a member of the Council of Inspectors General for Integrity and Efficiency 

(CIGIE); CIGIE’s Integrity Committee, and the Administrative Conference of the United 

States.

PROGRAM COUNSEL DIVISION

 The Program Counsel is the chief legal officer for the agency and the Chief of Staff 

with responsibility for managing all of OGE’s operations and career personnel. The 

Program Counsel Division (PCD) is responsible for: (1) conducting outreach to OGE’s 

stakeholders and the public; (2) overseeing executive branchwide strategic initiatives, 

such as the electronic filing system for financial disclosure; (3) directly supporting agency 

ethics officials through OGE’s Desk Officers; (3) training agency ethics officials; (4) 

providing internal legal support to OGE; and (5) managing OGE’s budget, performance, 

compliance, and legislative affairs programs.

 The Legal, External Affairs, and Performance Branch (LEAP) provides 

agency-specific legal support to OGE. LEAP is responsible for strategic initiatives and 

manages OGE’s budget, performance, compliance, and legislative affairs programs. LEAP 

oversees OGE’s Freedom of Information Act, Privacy Act, and records management 

programs. LEAP also develops and delivers substantive government ethics training to 

agency ethics officials throughout the executive branch and to OGE’s staff. In addition, 

LEAP conducts OGE’s Annual Agency Ethics Program Questionnaire.

 The Agency Assistance Branch (AAB) provides direct assistance to agency ethics 

officials throughout the executive branch. Through its Desk Officer program, AAB 

provides timely and accurate advice to ethics officials in response to questions regarding 

unique or emerging ethics issues they encounter. In addition to responding to requests for 

advice, AAB Desk Officers actively communicate with the executive branch ethics 

community to address issues and challenges that are of common interest in order to arrive 

at and share collaborative solutions. 

 AAB also manages OGE’s quarterly meetings with agency ethics program leaders 

and other forms of outreach to support agency ethics programs.

APPENDIX I 
25

GENERAL COUNSEL & LEGAL POLICY DIVISION

 The General Counsel is the chief legal officer supporting the Director with regard to

the legal authorities for government ethics in the executive branch. The General Counsel 

and Legal Policy Division (GCLPD) is responsible for: (1) establishing and maintaining a 

legal framework for the executive branch ethics program through regulations and 

executive branchwide policy issuances; (2) providing interpretive guidance regarding 

Government ethics authorities to the executive branch; and (3) providing assistance to the 

President and Senate in the Presidential appointment process.

 The Ethics Law and Policy Branch (ELPB) develops and issues the executive 

branch’s ethics regulations. ELPB also reviews and authorizes agency-specific 

supplemental ethics regulations. ELPB publishes written guidance in the form of Legal 

Advisories, assists stakeholders in resolving complex ethics form of Legal Advisories, 

assists stakeholders in resolving complex ethics issues, and supports enforcement 

authorities—including the Department of Justice and Inspectors General—with regard to 

the consistent application of Government ethics laws and regulations. When appropriate, 

ELPB also drafts recommendations for changes in the conflicts of interest laws and other 

ethics statutes.

 The Presidential Nominations Branch (PNB) works closely with the White House, 

the Senate, agency ethics officials, nominees, and nominees’ representatives with regard to 

the ethics review of Presidential nominees for Senate-confirmed positions. PNB ensures 

compliance with financial disclosure requirements and assists in the resolution of potential 

conflicts of interest.

 PNB carefully evaluates nominees’ financial disclosure reports and works with 

agency ethics officials to prepare individualized ethics agreements. PNB also reviews new 

entrant disclosures by the most senior White House officials, as well as disclosures by 

major party candidates for the offices of President and Vice President.
26

COMPLIANCE DIVISION

 The Deputy Director for Compliance is responsible for monitoring executive 

branch agencies for compliance with statutory and regulatory requirements for agency 

ethics programs. The Compliance Division (CD) monitors agency ethics programs to 

ensure compliance with applicable ethics requirements established by statutes, rules, 

regulations, Executive Orders, and policies. CD issues Program Advisories regarding the 

requirements for agency ethics programs. CD also conducts reviews of individual agency 

ethics programs and manages the executive branch-wide public financial disclosure 

program for Senate-confirmed Presidential appointees. In addition, CD evaluates requests 

from agencies regarding various discretionary program elements and serves as a 

repository for certain executive branch ethics documents.

 The Program Review Branch (PRB) exercises systemic oversight of the executive 

branch ethics program through reviews of agency ethics programs. PRB’s program review 

reports make specific recommendations to agencies for meaningful ethics program 

improvement, and PRB monitors agencies’ implementation of those recommendations. 

PRB tracks individual compliance with ethics agreements and tracks criminal referrals to 

the Department of Justice. In addition, PRB makes determinations on requests for 

exclusions from public financial disclosure requirements and for alternate confidential 

financial disclosure procedures.

 The Financial Disclosure Branch (FDB) ensures that senior government leaders are 

free of conflicts of interest by reviewing and analyzing their public financial disclosure 

reports following certification by agency ethics officials. These reports include new entrant, 

periodic transaction, annual, and termination public financial disclosure reports. In 

addition to reviewing these reports, FDB is responsible for releasing these reports to the 

public upon request and for publishing on OGE’s website the reports of officials paid at 

Levels I and II of the Executive Schedule.

INTERNAL OPERATIONS DIVISION

 The Associated Director for Internal Operations is responsible for providng overall 

technological, administrative and legal compliance support to OGE. The Internal 

Operations Division (IOD) is responsible for: (1) maintaining OGE’s information 

technology systems, equipment, and security; (2) creating and operating network 

applications; (3) ensuring compliance with administrative requirements for agencies; (4) 

overseeing human resources functions; (5) purchasing and contracting; and (6) property 

management and other administrative programs.

 The Assistant Director is supported by a Human Resources Officer and specialists 

in the Department of Treasury’s Bureau of Fiscal Service and other agencies that perform 

services through interagency shared services agreements.
27

Definition of Strategic Planning Terms

MISSION STATEMENT

A brief, easy-to understand narrative, usually no more than a sentence long. It defines the 

basic purpose of the agency and is consistent with the agency’s core programs and 

activities expressed within the broad context of national problems, needs, or challenges.

STRATEGIC GOALS

Statements that articulate general long-term outcomes that an agency hopes to achieve for

the major functions and operations of the agency. They should address the broader 

impact desired by the organization.

STRATEGIC OBJECTIVES

Statements that reflect the specific impact the agency aims to achieve under a certain goal.

Objectives are tied to a set of performance goals and indicators established to help the 

agency monitor and understand progress.

STRATEGIES

Statements that describe the approaches or practices an agency plans to employ to make 

progress on strategic objectives.

INDICATORS

Broad-based metrics that show whether desired outcomes are trending in the desired 

direction.

MEASURES

Metrics that help determine the impact or influence activities have on outcomes. Specific

targets are associated with them. They can be quantitative or qualitative in nature.

EXTERNAL FACTORS

Situations and circumstances (environments) that can influence program results and 

outcomes, not within the control of the agency.

EXTERNAL PARTNERS

Foreign and domestic government and private agencies, organizations, or entities that 

contribute to the achievement of an agency objective.

APPENDIX II 
28

Summary of Consultation Efforts

 To develop the Strategic Plan (Plan), OGE utilized a participatory and inclusive 

process to develop the Plan that included input from a wide array of key stakeholders.

 The agency conducted focus groups with staff and senior leadership to develop 

the goals, objectives, and strategies in the Plan. The agency also sought feedback from the 

Congress, executive branch ethics officials, the American public, and Government 

watchdog groups.

 A preliminary draft of the Plan was posted on OGE’s public website and a Federal 

Register notice was issued. The current Plan reflects feedback provided to OGE by these 

external stakeholders. 

APPENDIX III 
www.oge.gov