FEDERAL ETHICS 

PROGRAMS

Government-wide 

Political Appointee 

Data and Some Ethics 

Oversight Procedures 

at Interior and SBA

Could Be Improved

Report to Congressional Requesters

March 2019

GAO-19-249

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-19-249, a report to 

congressional requesters

March 2019

FEDERAL ETHICS PROGRAMS

Government-wide Political Appointee Data and Some 

Ethics Oversight Procedures at Interior and SBA

Could Be Improved 

What GAO Found

There is no single source of data on political appointees serving in the executive 

branch that is publicly available, comprehensive, and timely. Political appointees 

make or advocate policy for a presidential administration or support those 

positions. The Office of Personnel Management (OPM) and two 

nongovernmental organizations collect, and in some cases, report data on 

political appointees, but the data are incomplete. For example, the data did not 

include information on political appointee positions within the Executive Office of 

the President. The White House Office of Presidential Personnel (PPO) 

maintains data but does not make them publicly available. 

The public has an interest in knowing the political appointees serving and this 

information would facilitate congressional oversight and hold leaders 

accountable. As of March 2019, no agency in the federal government is required 

to publicly report comprehensive and timely data on political appointees serving 

in the executive branch. OPM is positioned to maintain and make political 

appointee data publicly available on a timely basis but is limited in its ability to 

provide comprehensive data. PPO has more comprehensive data but may not be 

positioned to publish data on a recurring basis. Ultimately, it is a policy decision 

as to which agency is best positioned to report comprehensive and timely data 

on political appointees. 

All three agencies GAO reviewed generally used appropriate internal controls to 

ensure they met basic ethics program requirements, though two of the agencies 

could take actions to strengthen their ethics programs.

• The Departments of Health and Human Services (HHS), and the Interior 

(Interior), and the Small Business Administration (SBA) all have

procedures for administering their financial disclosure systems. HHS and

Interior had procedures for providing initial ethics training as required 

beginning in January 2017. Prior to February 2019 SBA did not have 

written procedures for initial ethics training and did not adequately 

document political appointees’ training dates. SBA’s written procedures 

now reflect the requirements of initial ethics training and SBA developed 

a tracking sheet to indicate appointees completed training. GAO will 

assess the implementation of the tracking sheet to confirm the process is 

sufficient for documenting appointees’ completion of initial ethics training.

• Interior’s ethics program has human capital and workforce continuity 

challenges. Interior reported that four out of 14 full-time positions were 

vacant. Interior officials attributed the vacancies to a recent 

transformation of the ethics program and prioritizing the staffing at 

individual bureaus such as the National Park Service. However, 

vacancies affected the ethics program’s ability to properly document 

policies and procedures as well as file and review financial disclosure 

forms. According to Interior officials, steps are being taken to address 

vacancies and document policies and procedures. However, GAO found 

that a more strategic and documented approach would enable Interior to 

better manage human capital, fill key positions, and maintain institutional 

knowledge.

View GAO-19-249. For more information, 

contact Tranchau (Kris) T. Nguyen at (202) 

512-6806 or NguyenTT@gao.gov.

Why GAO Did This Study

Federal agencies’ ethics programs

seek to prevent conflicts of interest and 

safeguard the integrity of governmental 

decision-making. 

GAO was asked to review compliance 

with ethics requirements for political 

appointees in the executive branch.

This report examines the extent to 

which (1) existing data identify political 

appointees serving in the executive 

branch, and (2) selected agencies use 

internal controls to reasonably ensure 

that their ethics programs are designed 

and implemented to meet statutory and 

regulatory requirements.

GAO reviewed available data on 

political appointees. GAO also 

reviewed three case study agencies

selected to provide a range in agency 

size and number of political 

appointees. GAO reviewed ethics

documentation for a nongeneralizable 

sample of political appointees at the 

three agencies at any point between 

January 2017 and 2018 and 

interviewed officials from the agencies 

and two non-governmental 

organizations.

What GAO Recommends

Congress should consider legislation

requiring the publication of political 

appointees serving in the executive 

branch. GAO also recommends three

actions: SBA should document that 

training was completed; Interior should 

conduct more strategic planning for its 

ethics workforce and document ethics 

program policies and procedures. SBA 

neither agreed nor disagreed with 

GAO’s recommendation, but provided 

documentation that partially addresses

the recommendation. Interior agreed 

with GAO’s recommendations.
Page i GAO-19-249 Ethics

Letter 1

Background 4

No Single Source of Data on Political Appointees Exists That Is 

Comprehensive, Timely, and Publicly Available 10

SBA and Interior Ethics Programs Did Not Meet All 

Documentation Requirements and Interior and HHS Had 

Workforce Continuity Challenges 14

Conclusions 25

Matter for Congressional Consideration 26

Recommendations for Executive Action 26

Agency Comments and Our Evaluation 26

Appendix I Objectives, Scope, and Methodology 29

Appendix II Use of Internal Controls in Reviewed Agencies’ Ethics Programs 33

Appendix III Ethics Provisions Applicable to Political Appointees and Results of 

Political Appointee Ethics Documentation Analysis 34

Appendix IV Comments from the Department of the Interior 36

Appendix V Comments from the U.S. Small Business Administration 38

Appendix VI Comments from the United States Office of Government Ethics 42

Appendix VII GAO Contact and Staff Acknowledgments 44

Contents
Page ii GAO-19-249 Ethics

Tables

Table 1: Filing and Review Timeliness of Public Financial

Disclosure Reports for a Nongeneralizable Sample of 

Political Appointees Serving between January 20, 2017 

and January 28, 2018 16

Table 2: Analysis of Internal Control Principles to Reviewed 

Agencies’ Ethics Programs 33

Table 3: Number of Sampled Political Appointees in Each Agency 

That Addressed Selected Ethics Requirements 34

Figures

Figure 1: Executive Branch Ethics Program Mission, Roles, and 

Selected Responsibilities 6

Figure 2: Most Recently Published Data on the Number and Type 

of Political Appointees Positions, as of June 2016 9
Page iii GAO-19-249 Ethics

Abbreviations

DAEO Designated Agency Ethics Official

DOJ Department of Justice

EHRI Enterprise Human Resources Integration 

EOP Executive Office of the President

FOIA Freedom of Information Act

HHS Department of Health and Human Services

Interior Department of the Interior 

OIG Office of Inspector General

OGE Office of Government Ethics

OMB Office of Management and Budget

OPM Office of Personnel Management

PAS Presidential Appointee with Senate confirmation 

Plum Book United States Government Policy and Supporting Positions

PPO Office of Presidential Personnel

SBA Small Business Administration

SES Senior Executive Service

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately.
Page 1 GAO-19-249 Ethics

441 G St. N.W.

Washington, DC 20548

March 14, 2019

The Honorable Gary C. Peters

Ranking Member

Committee on Homeland Security and Governmental Affairs

United States Senate

The Honorable Thomas R. Carper

Ranking Member

Permanent Subcommittee on Investigations

Committee on Homeland Security and Governmental Affairs

United States Senate

The Honorable Elijah E. Cummings

Chairman

Committee on Oversight and Reform

House of Representatives

The basic obligation of public service is to place loyalty to the 

Constitution, laws, and ethical principles above private gain. By acting 

ethically, government officials can increase public confidence in the 

integrity of the federal government. Federal agencies’ ethics programs 

are to support ethical behavior by seeking to prevent conflicts of interest 

and safeguard the integrity of governmental decision-making. Ethics 

programs establish a foundation on which to build and sustain an ethical 

culture in the executive branch, including among the political appointees 

who can constitute the top management of executive branch agencies.1

You asked us to review compliance with ethics requirements as they 

relate to political appointees in the executive branch. This report 

examines the extent to which (1) existing data identify political appointees 

serving in the executive branch at any point in time, and (2) selected 

agencies use appropriate internal controls to reasonably ensure that their 

ethics programs are designed and implemented to meet statutory and 

regulatory requirements. This report does not assess the overall 

objectives of federal agencies ethics programs and if those objectives are 

being effectively met.

 1

5 C.F.R. § 2638.101. 

Letter
Page 2 GAO-19-249 Ethics

For the first objective, we reviewed relevant laws and standards and the 

United States Government Policy and Supporting Positions (Plum Book).2

We interviewed officials from the Office of Personnel Management (OPM) 

to understand the data they collect on political appointees. We also 

interviewed officials from two nongovernmental organizations, ProPublica 

and the Partnership for Public Service, which track political appointees 

serving in the executive branch at any point in time. We contacted the 

White House Office of Presidential Personnel (PPO) to discuss and 

request information on how it tracks, maintains, and uses data on political 

appointees. PPO redirected our request for information to the White 

House Counsel’s Office. As of March 2019, the White House Counsel’s 

Office had not responded to our requests for information. We interviewed 

two senior PPO officials from the two previous administrations to 

understand how they tracked and used data on political appointees. We 

assessed the information we gathered against principles for internal 

control regarding external communication and directives for the 

transparency and public availability of government data.3

For the second objective, we interviewed officials from the Office of 

Government Ethics (OGE), which sets policy for the executive branch 

ethics program and monitors ethics program compliance. We selected 

four agencies as case studies for review of their ethics programs. We 

selected the four agencies to provide a range in the number and type of 

political appointees in each agency,4 a range in agency size, and a range 

in the strength of their ethics programs, as determined by prior OGE 

program reviews.5 We conducted case studies on three of the agencies 

 2

Every 4 years, just after the Presidential election, the Plum Book is published, alternately, 

by the Senate Committee on Homeland Security and Governmental Affairs, and the 

House Committee on Oversight and Government Reform. The Plum Book lists civil 

service leadership and support positions that may be subject to noncompetitive status. 

3

GAO, Standards for Internal Control in the Federal Government, GAO-14-704G 

(Washington, D.C.: Sept. 2014); and Office of Management and Budget, Open 

Government Directive, M-10-06 (Washington, D.C.: Dec. 8, 2009).

4

The four major types of political appointees include: presidential appointees with Senate 

confirmation, presidential appointees, noncareer Senior Executive Service, and Schedule 

Cs. A Schedule C employee is an employee in a position that is excepted from the 

competitive service because of its policy-determining nature, or because it involves a 

close and confidential working relationship with the agency head or other top appointed 

official.

5

OGE reviews assess individual agency compliance with executive branch ethics laws, 

regulations, and policies and evaluate the agency’s systems, processes, and procedures 

for administering its ethics program. Reviews are generally conducted every 4 to 5 years.
Page 3 GAO-19-249 Ethics

we selected: the Departments of Health and Human Services (HHS), the 

Interior (Interior), and the Small Business Administration (SBA). The 

fourth agency selected was the Executive Office of the President (EOP). 

We contacted the White House Counsel’s Office in February 2018 to 

solicit the EOP’s perspective on the ethics program in place at the White 

House, and oversight of ethics compliance for political appointees in the 

executive branch. As of March 2019, the White House Counsel’s Office 

had not responded to our requests for information. Therefore, we did not 

review the EOP ethics program.

To evaluate the extent to which the three case study agencies have and 

use appropriate internal controls, we reviewed selected principles from 

the Standards for Internal Control in the Federal Government (Standards 

for Internal Control). These standards call for management to design 

control activities, such as policies and procedures to achieve objectives. 

Based on our review, analysis, and professional judgment, we selected 

the internal control principles that were most relevant to effectively 

executing an executive branch ethics program. We provided each agency 

with an identical set of questions based on the selected internal control 

principles and components. We reviewed agency responses to our 

questions and supporting program and appointee documentation to 

evaluate whether agencies’ policies and processes for overseeing ethics 

compliance for political appointees were consistent with these principles.

In addition, we acquired data from HHS, Interior, and SBA, on political 

appointees serving at any point between January 20, 2017 and January 

28, 2018. To assess the reliability of the data, we asked each agency’s 

officials about how the data were obtained, where the data came from, 

and what steps, if any, each agency took to assure the accuracy and 

completeness of the data. Based on responses provided by HHS, Interior, 

and SBA, we determined that those agencies’ data were sufficiently 

reliable to indicate each agency’s political appointees, with start and end 

dates, for use selecting a sample of appointees’ at each agency. Next, we 

used a nongeneralizable random sampling method to select political 

appointees at each agency. We selected 12 political appointees at both 
Page 4 GAO-19-249 Ethics

HHS and Interior, and 10 political appointees at SBA.6 We reviewed 

relevant documentation for these appointees to determine whether 

agency internal controls were sufficient to ensure that certain ethics 

program requirements, such as signing the ethics pledge, completing 

initial ethics training, and submitting a financial disclosure report, were 

met. In addition, we interviewed agency ethics officials, as needed, to 

discuss the documentation and information they provided. Our review of 

political appointees’ documentation was limited to testing the agencies’

ethics program processes and procedures. We did not review individual 

financial disclosure forms with the intent of identifying conflicts of interest 

nor did we perform a conflict of interest analysis. See appendix I for a 

more detailed description of our scope and methodology.

We conducted this performance audit from October 2017 to March 2019 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

The Ethics in Government Act of 1978 was enacted to preserve and 

promote the accountability and integrity of public officials, and the 

institutions of the federal government.7 The act requires political 

appointees and high-ranking government officials to complete a public 

financial disclosure report to help prevent and mitigate conflicts of interest 

for the purpose of increasing public confidence in the integrity of 

 6

To ensure we included certain types of political appointees in our review, we grouped the 

political appointees from each agency into three groups: (1) individuals in PAS positions, 

(2) individuals who left the agency during the time frame of our review, and (3) all 

remaining individuals. We randomly selected three appointees from the first group, three 

appointees from the second group, and six political appointees from the last group. At 

SBA, the total PAS appointees and total individuals who left the agency during our review 

time frame was less than six. As a result, there were fewer total appointees in our SBA 

sample compared to HHS and Interior.

7

Pub. L. No. 95-521, 92 Stat. 1824 (1978), codified, as amended at 5 U.S.C. App. §§ 101–

505 and in scattered sections of titles 2, 5, 18, 28, United States Code.

Background

Executive Branch Ethics 

Program
Page 5 GAO-19-249 Ethics

government. The act also established restrictions on postemployment 

activities of certain employees, and created OGE. 

The primary mission of the executive branch ethics program is to prevent 

conflicts of interest on the part of executive branch employees.8 The 

executive branch ethics program is a shared responsibility across 

government (see figure 1).

• OGE is the supervising ethics office for the executive branch and sets 

policy for the entire executive branch ethics program.

• Executive branch agency heads are responsible for leading their 

agency’s ethics program. Agency leaders are ultimately responsible 

for their organizations’ ethical culture. Their actions can demonstrate 

the level of commitment to ethics and set a powerful example for their 

employees.9

• Designated Agency Ethics Officials (DAEO) and other agency 

ethics staff carry out ethics program responsibilities and coordinate 

with OGE.

• Inspectors General and the Department of Justice are authorized 

to investigate potential violations of criminal statutes pertaining to 

ethics.

• Executive branch employees are individually responsible for 

understanding and complying with the requirements of ethics laws 

and regulations, and are collectively responsible for making ethical 

conduct a standard of government service.

 8

5 C.F.R. § 2638.101(a).

9

OGE Memorandum, The Role of Agency Leaders in Promoting an Ethical Culture, (Oct. 

5, 2017).
Page 6 GAO-19-249 Ethics

Figure 1: Executive Branch Ethics Program Mission, Roles, and Selected Responsibilities
Page 7 GAO-19-249 Ethics

Executive branch employees are ultimately responsible for understanding 

and abiding by the various ethics laws. Generally, executive branch 

employees are prohibited from working on government matters that will 

affect their personal financial interest or the financial interests of a spouse 

or minor child; general partner; any organization in which they serve as 

an officer, director, or trustee; and any person or organization with whom 

they are negotiating or have an arrangement for future employment.10

Executive branch employees are also subject to

• criminal statutes prohibiting bribery and illegal gratuities;

• civil statutes requiring public financial disclosure; and

• employee standards of conduct, such as acting at all times in the 

public’s interest, serving as good stewards of public resources, and 

refraining from misusing their office for private gain.11

Agency Offices of Inspectors General (OIG) have a responsibility to 

investigate potential ethics violations.12 Among our three case study 

agencies, since January 2017, the HHS and Interior OIG have 

investigated potential travel and ethics issues involving political 

appointees while the SBA OIG did not initiate any similar investigations.

The HHS OIG investigated the former Secretary of HHS’s use of 

chartered and commercial aircraft and found that it did not always comply 

with applicable federal travel regulations and HHS policies and 

procedures.13 In response to its OIG’s findings, HHS implemented 

additional steps for political appointees’ travel approval. Since January 

2017, the Interior OIG has initiated five investigations into potential ethics 

violations involving the former Secretary of the Interior.14 As of March 1, 

2019, three investigations related to the former Secretary were 

completed. As a result of the first completed investigation, the Interior 

 1018 U.S.C. § 208; 5 C.F.R. § 2635.402(a), (b)(2).

115 C.F.R. § 2638.102.

125 C.F.R. § 2638.106.

13Office of the Inspector General, U.S. Department of Health and Human Services, The 

Office of the Secretary of Health and Human Services Did Not Comply with Federal 

Regulations for Chartered Aircraft and Other Government Travel Related to Former 

Secretary Price Report No.: A-12-17-00002 (July 2018).

14The Interior OIG initiated an investigation related to the unprofessional behavior of 

another political appointee at Interior. The OIG ended the investigation after the appointee 

resigned. 

Ethics Laws for Executive 

Branch Employees
Page 8 GAO-19-249 Ethics

OIG found that “incomplete information” about the former Secretary’s 

travel and use of chartered flights during 2017 was provided to the DAEO 

for review. The other two completed investigations found no evidence that 

the former Secretary violated ethics laws. Two investigations remained 

open as of March 2019. Interior’s DAEO described multiple strategies that 

were implemented to address issues observed within the ethics program 

after he was hired in April 2018, such as establishing weekly meetings 

with the former Secretary of the Interior to discuss ethics matters.

Executive Branch political appointees are subject to more ethics 

restrictions than other executive branch employees. Appointees make or 

advocate policy for a presidential administration or support those 

positions. Appointees generally serve at the pleasure of the appointing 

authority and do not have the civil service protections afforded to other 

federal employees.

There are four major categories of political appointees: Presidential 

Appointees with Senate confirmation (PAS); presidential appointees; 

noncareer employees in the Senior Executive Service (SES); and 

Schedule C employees. The most recent Plum Book, which was 

published on December 1, 2016, identified about 4,000 political appointee 

positions from these four major categories across the entire executive 

branch as of June 30, 2016 (see figure 2). The Plum Book identifies 

presidentially appointed positions within the federal government using 

data from the Office of Personnel Management. It is published every 4 

years just after the presidential election, alternately, by the Senate 

Committee on Homeland Security and Governmental Affairs and the 

House Committee on Oversight and Government Reform.

Executive Branch Political 

Appointees
Page 9 GAO-19-249 Ethics

Figure 2: Most Recently Published Data on the Number and Type of Political 

Appointees Positions, as of June 2016

In addition to the ethics laws for executive branch employees, several 

recent presidential administrations have issued an order requiring political 

appointees in executive branch agencies to sign an ethics pledge.15

Some of the restrictions in the ethics pledge relate to areas already 

covered under existing ethics provisions, such as restrictions on 

accepting gifts and postemployment restrictions. Political appointees may 

receive an ethics pledge waiver from the President or his designee of 

certain or all ethics restrictions and authorizations enabling them to 

participate in otherwise prohibited activities. Political appointees that sign 

 15President Trump issued Executive Order No. 13770 (EO 13770), “Ethics Commitments 

by Executive Branch Appointees,” on January 28, 2017. 82 Fed. Reg. 9333 (Feb. 3, 

2017). Prior administrations issued their own ethics pledges, including President Obama 

(EO 13490) and President Clinton (EO 12834). 74 Fed. Reg. 4673 (Jan. 26, 2009); 58 

Fed. Reg. 5911 (Jan. 22, 1993). President Clinton revoked EO 12834 effective January 

20, 2001, and President George W. Bush did not issue a new executive order with an 

ethics pledge. 66 Fed. Reg. 679 (Jan. 3, 2001).
Page 10 GAO-19-249 Ethics

the pledge are contractually bound to adhere to its restrictions. If violated, 

the restrictions in the pledge could only be enforced through civil actions.

To foster transparency, federal law permits members of the public to 

access various government records. OGE provides online access to 

certified copies of public financial disclosure reports for PAS and certain 

other executive branch employees, as well as any applicable ethics 

agreements, certification of compliance for the ethics agreement, and 

certificates of divestiture for PAS.16 OGE also provides online access to 

copies of ethics pledge waivers for appointees at agencies.17 Members of 

the public can use this information to assist in holding government 

officials accountable for carrying out their duties free from conflicts of 

interest.

OPM, PPO, and two nongovernmental organizations provide some data 

on political appointees serving in the executive branch, but the data have 

limitations that impede their usefulness. The Senate Homeland Security 

and Governmental Affairs Committee and the House Oversight and 

Government Reform Committee publish OPM data on political appointees 

after each presidential election in the Plum Book.18 Data include name, 

title, type of appointment, salary, and location of employment. The data 

reflect the positions and the individuals who are filling the positions at a 

single point in time, about 5 months prior to the report’s publication. While 

the data are comprehensive and publicly available, they are not timely. 

Because the Plum Book is a snapshot in time, it does not reflect changes 

that occur in between publications, such as changes to who is holding a 

certain position, the position title, and vacancies.

 16Executive branch agencies or OGE can direct an employee to sell, or otherwise divest, 

an asset to avoid a conflict of interest or the appearance of one. If selling the asset will

result in a capital gain, certain persons may be eligible for a certificate of divestiture to 

postpone the tax burden of complying with the government’s conflict of interest 

requirements. 5 C.F.R. § 2635.402(e).

17Copies of ethics pledge waivers granted to Executive Office of the President and Office 

of the Vice President employees are available at https://www.whitehouse.gov/disclosures/, 

accessed Nov. 9, 2018.

18The Plum Book is generally published in December after the presidential election and is 

based on agency data reported to OPM as of the June prior to the election.

Transparency and Ethics

No Single Source of 

Data on Political 

Appointees Exists 

That Is 

Comprehensive, 

Timely, and Publicly 

Available
Page 11 GAO-19-249 Ethics

OPM also maintains more timely data on federal personnel; however, 

these data are not comprehensive or publicly accessible for identifying 

individuals serving in political appointee positions. OPM maintains data in 

the Executive and Schedule C System and the Enterprise Human 

Resources Integration (EHRI) system—the latter serves as OPM’s 

primary repository for human capital data.19 We found both systems have 

limitations, several of which were also identified by OPM officials.20 The 

Executive and Schedule C System is not comprehensive. It includes data 

on Schedule C and noncareer SES political appointees, but generally 

does not include data on presidential appointees or PAS. Publicly 

available EHRI data do not identify political appointees, either at the 

individual or group level. In addition, the EHRI source data is not publicly 

available. Political appointees can be identified from a combination of 

multiple variables, but these combinations are not consistent within or 

across appointee types. OPM provided some data on political appointees 

serving in the executive branch as of June 2018 from the Executive and 

Schedule C System. We reviewed the data and found errors and 

omissions. For example, we found instances in which individuals 

appeared to be holding political appointee positions that they departed 

several months prior and individuals known to currently hold political 

appointee positions were not identified. We also found that the data are 

incomplete. For example, the data did not include information on political 

appointee positions within the EOP. The EOP provides data to OPM only 

every 4 years for inclusion in the Plum Book.

In addition to OPM, the White House maintains timely data on political 

appointees that are likely more comprehensive than OPM’s data but are 

not publicly available. Historically, PPO maintained data on political 

appointees as part of its responsibilities to recruit, vet, and place political 

appointees in positions across the government. PPO data on political 

appointees have not been made publicly available by the Trump, Obama, 

or Bush administrations. According to former officials from the Bush and 

Obama administrations, PPO maintained and used data on political 

appointees to carry out its responsibilities. For example, during the 

Obama administration, PPO established a database to help with filling 

political appointee positions and managing the overall appointee process. 

 19According to OPM officials, the accuracy and timeliness of information in the Executive 

and Schedule C System and EHRI is largely based upon agency input.

20GAO, Federal Human Resources Data: OPM Should Improve the Availability and 

Reliability of Payroll Data to Support Accountability and Workforce Analytics, GAO-17-127 

(Washington, D.C.: Oct. 7, 2016).
Page 12 GAO-19-249 Ethics

The database included preliminary information on candidates, such as 

names, application status, and where the applicant was in the vetting 

process. After a position was filled, the database tracked information such 

as the name of the appointee, position, federal department or agency, 

and start and departure dates. The primary limitation of the data was that 

departure dates of political appointees were unreliable. The former 

Obama administration official attributed this limitation to the lack of a 

process for agencies to formally notify PPO when an appointee left a 

position. To address this gap, PPO met regularly with staff in federal 

agencies to review data for accuracy.

There are requests by members of the public to obtain data on political 

appointees serving in the executive branch. For example, between 

January 2017 and November 2018, OPM received approximately 32 

requests through the Freedom of Information Act (FOIA) for data on 

political appointments across federal agencies. According to OPM 

officials, requests for data on political appointees are common and tend to 

increase at the start of a new administration. Former PPO officials also 

stated that when they served at PPO they received requests for data on 

political appointees serving in the executive branch.

In the absence of comprehensive and timely data on political appointees 

serving in the executive branch, two nongovernmental organizations—the 

Partnership for Public Service and ProPublica—stated that they collect 

and report some data themselves.21 The Partnership for Public Service 

primarily tracks and reports data on PAS appointments, which are 

compiled from publicly available sources such as Congress.gov and 

agency websites. According to the Partnership for Public Service, 

accurately tracking departure dates is the most significant limitation. 

Some PAS departures, such as cabinet level officials, are typically 

reported in the media; however, lower-level PAS departures may not be 

reported.

ProPublica collects and reports data on all types of political appointees 

serving in the executive branch. To obtain and compile its data, 

ProPublica makes FOIA requests to OPM and departments and agencies 

across the executive branch for political appointee staffing lists. 

ProPublica also makes requests for other data, such as financial 

 21The Partnership for Public Service is a nonprofit, nonpartisan organization that seeks to 

improve government. ProPublica is an independent, nonprofit newsroom that produces 

investigative journalism.
Page 13 GAO-19-249 Ethics

disclosure forms through an administrative process required by the Ethics 

in Government Act of 1978. ProPublica said it has had more than 166,000 

unique visitors to its database since it launched in March 2018. According 

to officials at ProPublica, one limitation is that they rely on agency 

responses to FOIA requests and therefore the data may not be 

comprehensive or timely.

The public has an interest in knowing who is serving in the government 

and making policy decisions. The Office of Management and Budget 

(OMB) stated that transparency promotes accountability by providing the 

public with information about what the government is doing. In a 2009

memorandum, OMB directed agencies to make information available 

online and to use modern technology to disseminate useful information, 

rather than waiting for specific requests under FOIA.22 Although some 

data are publicly available on political appointees and FOIA requests can 

be used to varying effect to obtain data on political appointees, neither 

option results in comprehensive, timely, and publicly available data. Until 

the names of political appointees and their position, position type, agency 

or department name, start and end dates are publicly available at least 

quarterly, it will be difficult for the public to access comprehensive and 

reliable information.

Making such information available would promote transparency. The 

public, including independent researchers, the media, and 

nongovernmental organizations, can use these data to perform 

independent analyses to identify gaps and challenges for filling political 

appointee positions or to identify potential conflicts of interest. Such 

analyses would also facilitate congressional oversight of executive branch 

appointees by providing a comprehensive and timely source of 

information on political appointees.

As of March 2019, no agency in the federal government was required to 

publicly report comprehensive and timely data on political appointees 

serving in the executive branch. As the leader of human resources and 

personnel policy, OPM is positioned to collect, maintain, and make 

political appointee data publicly available on a frequent and recurring 

basis. However, OPM is limited in its ability to provide comprehensive 

data, in part because it does not regularly receive data from each agency 

that has political appointees, such as the EOP, which has approximately 

 22Office of Management and Budget Open Government Directive, M-10-06 (Dec. 8, 2009).
Page 14 GAO-19-249 Ethics

225 political appointee positions based on the 2016 Plum Book. PPO is 

positioned to make more comprehensive data on political appointees 

publicly available. However, PPO is reestablished with each new 

presidential administration, which could be a barrier to establishing a 

consistent process for maintaining and publishing data on a recurring 

basis. Ultimately, it is a policy decision as to which agency is best 

positioned to report comprehensive and timely data on political 

appointees.

All three agencies we reviewed—HHS, Interior, and SBA—generally used 

appropriate internal controls to ensure they met basic ethics program 

requirements, such as financial disclosure, though two of the agencies—

Interior and SBA—could do more to strengthen their ethics programs. 

SBA and Interior had not fully documented some of their procedures for 

ethics training and the ethics pledge, respectively. In implementing their 

ethics programs, each agency addressed human capital issues and 

workforce continuity challenges; however, we found that vacancies and 

staff turnover had negative effects on Interior’s ethics program. For the 

full results of our assessment of agencies’ internal controls, see appendix 

II.

All three agencies we reviewed met the minimum statutory and regulatory 

requirement to have written procedures for financial disclosure.23 Federal 

 23We did not conduct an independent evaluation of the content of each agency’s 

procedures to determine whether they comply with relevant requirements. OGE evaluates 

agencies’ written procedures for financial disclosure during its program reviews to ensure 

that the agency procedures are in conformance with all relevant laws, regulations, and 

executive orders. 

SBA and Interior 

Ethics Programs Did 

Not Meet All 

Documentation 

Requirements and 

Interior and HHS Had 

Workforce Continuity 

Challenges

Reviewed Agencies 

Generally Met Basic 

Requirements for 

Financial Disclosure and 

Ethics Training, but Interior 

and SBA Did Not 

Document Some 

Procedures

Financial Disclosure
Page 15 GAO-19-249 Ethics

law requires agencies to develop written procedures to collect, review, 

and evaluate financial disclosure reports (see sidebar).24

Each agency established financial disclosure processes in addition to 

what is required to reduce the risk of political appointees performing 

agency work while they may have conflicts of interest. For example, prior 

to an HHS political appointee’s first day, the HHS process requires the 

appointee’s financial disclosure report to be submitted and reviewed, and 

any potential conflicts be either resolved or identified, and an ethics 

agreement put in place with a timeline for conflict of interest resolution. 

This process aims to ensure that appointees are in compliance with ethics 

laws and regulations when they begin government service, rather than 30 

days or more into their appointment.

HHS and SBA have additional processes that include written procedures 

which reflect OGE’s guidance for reviewing reports, such as following up 

with appointees when a financial disclosure report appears incomplete. 

OGE officials told us that engaging with an appointee during the review 

process allows agencies to confirm that the appointee understands and 

completes each required item. These interactions are also an opportunity 

to provide ethics counseling and establish a relationship with appointees 

who may be new to government service. Interior instituted a process in 

June 2018 that requires ethics officials to interview new appointees, 

review their financial disclosure report, and complete a financial 

disclosure checklist prior to certification.

In reviewing a nongeneralizable sample of political appointees at each of 

the three agencies, we found that nearly all political appointees filed 

financial disclosure reports on time, with four exceptions of non-PAS 

appointees from our Interior and SBA samples (see table 1).25 In one 

case, an Interior appointee who was required to file both a new entrant 

and termination report did not do so. According to Interior ethics officials, 

the office mistakenly determined that the appointee was excluded from 

public filing requirements. An individual who does not serve more than 60 

days in a calendar year is not required to file a new entrant or a 

termination financial disclosure report; however, this political appointee 

served for 63 days.

 245 U.S.C. App. § 402(d)(1); 5 C.F.R. § 2638.104(c)(8)(i).

25For the complete results of our political appointee ethics requirement analysis, see 

appendix III.

Financial Disclosure Requirements

Agencies:

• Administer public and confidential 

financial disclosure systems.

• Establish written procedures for 

collecting, reviewing, evaluating, and 

where applicable, making available to 

the public financial disclosure reports 

filed by the agency’s employees.

Political Appointees:

• File a new entrant public financial 

disclosure report within 30 days of 

assuming a public filing position.

• If appointed to a position requiring 

Senate confirmation, file a nominee 

report within 5 days of transmittal of the 

President’s nomination to the Senate for 

confirmation.

• File a termination report within 30 days 

of leaving office.

Source: GAO analysis of financial disclosure statues and 

regulations. | GAO-19-249
Page 16 GAO-19-249 Ethics

Table 1: Filing and Review Timeliness of Public Financial Disclosure Reports for a Nongeneralizable Sample of Political 

Appointees Serving between January 20, 2017 and January 28, 2018

Department of Health and 

Human Services Department of the Interior

Small Business 

Administration

Type of report filed

New entrant

or nominee Termination

New entrant

or nominee Termination

New entrant

or nominee Termination

Number of political appointees required 

to file 10a 3 12 1 10 1

Number of reports filed timely 10 3 10b 0b 8 1

Number of reports filed 0-5 days late 0 0 1 0 2 0

Number of reports filed >5 days late 0 0 0 0 0 0

Number of reports reviewed timely by 

agency ethics official 10 3 10 0 9 1

Source: GAO analysis of timeliness of public financial disclosure report filing (Office of Government Ethics Form 278e). | GAO-19-249

Note: In general, individuals nominated by the President to positions requiring Senate confirmation 

must file a nominee financial disclosure report within 5 days of transmittal of the President’s 

nomination to the Senate for confirmation. Other appointees must file a new entrant report within 30 

days of assuming their position. In general, all appointees must file a termination report within 30 

days of leaving office. Reports must be reviewed by agency ethics officials within 60 days of receipt. 

26 C.F.R. §§ 2634.201(b), (c), (e); 2634.605(a).

a

Two of the political appointees in our HHS sample were incumbents from previous administrations. 

Due to records retention schedule, we were unable to evaluate the nominee financial disclosure 

reports filed by those two appointees.

b

One appointee at Interior did not file a new entrant or a termination financial disclosure report. 

According to Interior ethics officials, the office mistakenly determined that the appointee was excluded 

from public filing requirements.

Three appointees—two from SBA and one from Interior—filed new 

entrant reports past their due dates. Late filing heightens the risk of 

appointees performing agency work while having conflicts of interest; 

however, none of the three appointees filed more than 30 days after the 

due date or the last day of an extension, and therefore were not subject to 

a late filing fee.26 For example, one Interior appointee received a 30-day 

extension to file a new entrant report, but filed it 4 days late. One SBA 

appointee received an extension exceeding the maximum time—90 

days—that an agency may grant to any filer and consequently filed 2 

days late.27 According to SBA ethics officials, the appointee was given a 

 26Unless granted a waiver for “extraordinary circumstances,” an official who files any 

public financial disclosure report more than 30 days after the due date, or more than 30 

days after the last day of an extension, whichever occurs later, must pay the United States 

a $200 late filing fee. 5 U.S.C. App. § 104(d); 5 C.F.R. § 2634.704.

27An agency may grant any filer an extension to file a financial disclosure report for “good 

cause shown,” provided such extensions do not exceed 90 days. 5 U.S.C. App. § 

101(g)(1); 5 C.F.R. § 2634.201(f).
Page 17 GAO-19-249 Ethics

92-day extension because the due date was miscalculated. A second 

SBA appointee filed a report 1 day past the due date. We did not find 

timeliness issues with any reports filed by appointees at HHS or filed by 

PAS appointees at Interior or SBA.

Agency ethics officials generally reviewed appointees’ financial disclosure 

reports in a timely manner. However, agencies followed up with non-PAS 

political appointees’ to varying degrees when their financial disclosure 

reports were potentially missing information. For example, SBA followed 

up with an appointee to confirm that the appointee had not inadvertently 

omitted information, such as a retirement plan, from the financial 

disclosure report because the appointee reported having previous longterm employment. HHS asked for and received clarifying information from 

an appointee who reported compensation for legal work but did not report 

individual clients. However, Interior ethics officials told us they did not 

follow up with two appointees in our sample who reported having no 

previous outside employment. Interior officials acknowledged that the 

reports were neither reviewed nor certified properly. According to 

Interior’s new Designated Agency Ethics Official (DAEO), the June 2018 

update to Interior’s review process was implemented in response to 

deficiencies within its financial disclosure program.

HHS and Interior had written procedures for initial ethics training as 

required, but SBA did not until February 2019. Federal regulation requires 

agencies to establish written procedures for providing initial ethics training 

beginning in January 2017 (see sidebar).28

 28On November 2, 2016, OGE published a final rule revising the elements and procedures 

of the executive branch ethics program, including establishing the requirement for 

agencies to develop written procedures for initial ethics training. These changes had an 

effective date of January 1, 2017. 5 C.F.R. § 2638.304(f); 81 Fed. Reg. 76,271 (Nov. 2, 

2016).

Ethics Training
Page 18 GAO-19-249 Ethics

HHS’s and Interior’s written procedures reflect the requirements of initial 

ethics training. For example, both agencies’ procedures describe time 

frames for providing initial ethics training to political appointees no later 

than 3 months after their appointment date, as well as the method for 

doing so. Prior to February 2019, SBA did not have adequate written 

procedures in place to address the requirement that became effective in 

January 2017. SBA’s written procedures now reflect the requirements of 

initial ethics training. Now that SBA officials have formally documented

procedures, they can have reasonable assurance that the procedures are 

implemented as intended and that all required appointees are provided 

initial ethics training. 29

Interior’s and HHS’s ethics programs track and maintain documentation of 

dates that political appointees received initial ethics training. During the 

time of our review, SBA did not adequately document political appointees’

training dates.30 For example, ethics officials at Interior manually record 

training dates in a spreadsheet shared between Interior’s ethics office, 

Office of Human Resources, and the White House Liaison. HHS requires 

appointees to confirm in writing that they completed initial ethics training. 

According to SBA ethics officials, the previous Alternate DAEO informally 

documented the dates that political appointees received training in her 

personal notes. Standards for internal control state that management 

should document significant events, and that documentation and records 

should be properly managed, maintained, and readily available for 

examination. Allowing one individual to control all key aspects of 

documenting an event puts the program at risk of errors.31 As of February 

2019, SBA officials had developed a tracking sheet and a certificate for 

appointees to sign that indicates they completed initial ethics training. We 

plan to assess the implementation of the tracking sheet to confirm that 

SBA is using the tracker to hold appointees accountable by documenting 

their completion of initial ethics training requirements. By developing and 

implementing a mechanism, such as a tracking sheet, SBA can have 

 29Standards for internal control state that management should document its control 

policies and conduct periodic reviews to ensure controls are effective. See GAO-14-704G.

30Political appointees are also required to complete annual ethics training before the end

of a given calendar year. Because the majority of appointees in our sample received initial 

ethics training in 2017, they were not required to receive annual ethics training until the 

end of calendar year 2018, which was outside the time frame of our review. Therefore, we 

did not assess compliance with annual training requirements. For the full results of our 

political appointee ethics documentation analysis, see appendix III.

31GAO-14-704G.

Ethics Training Requirements

Agencies:

• Carry out an ethics education program to 

teach employees how to identify 

government ethics issues and obtain 

assistance in complying with ethics laws 

and regulations.

• Establish written procedures, which the 

DAEO must review each year, for 

providing initial ethics training.

Political Appointees:

• Complete initial ethics training within 3 

months of appointment.

• If appointed to a position requiring 

Senate confirmation, complete an 

additional live ethics briefing on 

immediate ethics obligations within 15 

days.

Source: GAO analysis of ethics training statutes and 

regulations. | GAO-19-249
Page 19 GAO-19-249 Ethics

reasonable assurance that political appointees meet the requirement to 

take initial ethics training.

Our review of agency documentation, including SBA’s informal 

documentation, found that political appointees completed required initial 

ethics training on time. Also, all three agencies provided the required 

additional live ethics briefing for PAS appointees together with initial 

ethics training.

In addition to required training, all three agencies provided examples of 

other ways they have reminded appointees about their personal ethical 

responsibilities. For example:

• In advance of the holiday season, Interior provided supplementary 

training to political appointees on restrictions on accepting gifts.

• SBA used its agency-wide newsletter during the March Madness 

college basketball tournament to remind employees that they are 

prohibited from gambling in the workplace.

• HHS updated its ethics website to highlight Hatch Act rules in 

preparation for upcoming elections.32

 32The Hatch Act limits certain political activities of federal employees, as well as some 

state, D.C., and local government employees who work in connection with federally 

funded programs. 5 U.S.C. §§ 1501–1508, 7321–7326.
Page 20 GAO-19-249 Ethics

Political appointees we reviewed at each agency had signed the required 

ethics pledge prescribed in Executive Order 13770, “Ethics Commitments 

by Executive Branch Appointees.” However, nine Interior appointees’ and 

one HHS appointee’s pledges were not timely signed.33 For example, the 

former Secretary of the Interior signed the pledge 19 days after his 

appointment. According to an Interior ethics official, the political 

appointees were directed to sign the pledge at the start of their 

appointments, but did not do so. Interior’s new DAEO told us in October 

2018 that Interior now requires all appointees to sign the pledge on their 

first day as a condition of continuing their employment; however, this 

procedure has not been formally documented. The non-PAS HHS 

appointee signed the pledge 9 days after his permanent appointment 

date. While the restrictions under the pledge are enforceable by civil 

action, there are no legal consequences, such as fines or penalties, for 

failing to timely sign the pledge.

The President or his designee may grant a waiver of any of the 

restrictions contained in the executive order. As of March 2019, 32

executive branch appointees—not including White House appointees—

received limited waivers of the pledge.34 Interior’s then acting solicitor and 

principal deputy solicitor signed a limited waiver of certain restrictions on 

lobbying activities for one appointee in our sample upon the appointee’s 

departure from the agency in July 2017.35 However, according to Interior 

ethics officials, the official from the Solicitor’s Office did not have authority 

to grant a waiver. Furthermore, Interior’s ethics office was not included in 

the decision to grant the waiver, although Interior ethics officials ultimately 

notified the appointee when they became aware that the waiver was 

legally invalid. According to the DAEO, Interior is updating and 

documenting its ethics program processes and procedures, including new 

processes to sign ethics pledges and grant waivers, but did not provide a 

 33OGE guidance states PAS appointees must sign ethics pledges between Senate 

confirmation and beginning their appointment. Non-PAS appointees are required to sign 

the pledge when they are appointed. According to OGE officials, ethics pledge signed by 

non-PAS appointees within a few days of the appointment are generally still considered 

timely signed. For the purpose of our analyses, we considered any pledge signed after the 

first 3 days of a non-PAS appointee’s appointment to not be timely signed.

34Copies of any waivers granted to White House appointees pursuant to Executive Order 

13770 are available on the White House website: 

https://www.whitehouse.gov/disclosures/. 

35Paragraph 3 of the ethics pledge states that political appointees will not engage in any 

lobbying activities with respect to any covered executive branch official or noncareer 

Senior Executive Service appointee for the remainder of the administration.

Ethics Pledge

Ethics Pledge Restrictions

Political Appointees:

• President Trump issued Executive Order 

13770, “Ethics Commitments by 

Executive Branch Appointees,” which 

requires political appointees to sign an 

ethics pledge.

• Under the pledge, appointees are 

contractually bound to adhere to 

specified restrictions, including (but not 

limited to):

• for all appointees, a 2-year ban on 

involvement in “particular matters” 

involving former employers and 

clients;

• for former lobbyists, a 2-year ban on 

involvement on particular matters on 

which he or she lobbied; and

• for appointees who leave 

government service, a 5-year ban on 

lobbying agencies in which they 

served.

Source: GAO analysis of Executive Order 13770. | 

GAO-19-249
Page 21 GAO-19-249 Ethics

time frame for completion. We discuss Interior’s efforts to document 

overall ethics program processes and procedures later in this report.

We found that all of the agencies we reviewed are addressing human 

capital issues and workforce continuity challenges to varying extents to 

achieve the goals and objectives of the ethics program. Standards for 

internal control state that management can help ensure operational 

success by having the right personnel for the job on board and 

maintaining a continuity of needed skills and abilities. Standards for 

internal control also state that management has a responsibility to obtain 

the workforce necessary to achieve organizational goals. HHS and 

Interior reported challenges to recruiting and retaining ethics staff with the 

necessary knowledge, skills, and abilities. All of the reviewed agencies 

reported varying levels of effort to address vacancies, skills gaps, and 

succession planning.

HHS reported vacancies in its ethics program as well as challenges in 

recruiting and hiring; however ethics program officials took actions to 

mitigate negative effects of the vacancies. As of October 1, 2018, HHS’s 

Ethics Division had six vacancies out of 32 full-time positions (a vacancy 

rate of approximately 19 percent), including the Alternate DAEO position.

HHS officials told us that a senior attorney was assigned to assume the 

duties of the Alternate DAEO position for six months in 2018. HHS ethics 

officials told us that the 2017 government-wide hiring freeze and 

workforce reduction plan affected their efforts to fill vacancies.36 However, 

ethics officials also told us that, as of October 1, 2018, four people had 

tentatively accepted offers to fill vacancies. HHS ethics officials told us 

that applicants for ethics attorneys and specialist positions generally do 

not have a background in federal government ethics laws. As a result, 

Ethics Division officials said that it must invest time and resources to train 

new hires, who attend and review OGE trainings, participate in monthly 

interagency ethics meetings, and take HHS-specific ethics training.

 36On January 23, 2017, the President issued a memorandum imposing a federal hiring 

freeze to halt the growth of the federal workforce until a “long-term plan to reduce the size 

of the federal government’s workforce” is put in place. The freeze prohibited agencies to 

hire for vacant or new positions as of January 22, 2017, except in limited circumstances 

such as military or public safety personnel. On April 12, 2017, OMB issued guidance on 

implementing the hiring freeze as well as guidance for a government-wide reform plan that 

included reducing the federal workforce.

Reviewed Agencies’ Ethics 

Programs Face Human 

Capital and Workforce 

Continuity Challenges
Page 22 GAO-19-249 Ethics

HHS ethics officials told us that new ethics program hires are assigned 

work from across the spectrum of ethics subject matter and trained oneon-one by senior staff. To address staffing shortages and prepare for 

potential attrition, the HHS ethics officials said they cross-train staff 

members and assign back-up team members to support HHS’s operating 

and staff divisions. In addition, to track potential staff attrition or 

retirement, the ethics officials told us that the Ethics Division uses OPM’s 

Federal Employee Viewpoint Survey data collected from HHS 

employees.37 However, the data only give the Ethics Division a general 

sense of the number of personnel that are planning to leave or retire. 

HHS Ethics Division officials said they use survey data because there is a 

general sensitivity related to asking about retirement and delays in 

planned retirements that could affect recruiting and hiring replacements.

Interior’s ethics office also reported vacancies and challenges in recruiting 

and hiring that contributed to the issues in the ethics program. As of 

November 2018, the Interior ethics office reported that out of 14 full-time 

positions, four were vacant (a 29 percent vacancy rate). All vacancies 

were ethics attorney positions.38 Interior reported an ongoing 

transformation of the department’s ethics program and officials said that 

the vacancies resulted from prioritizing the staffing at individual bureaus—

such as the National Park Service and Fish and Wildlife Service—instead 

of the department-level ethics office, which is responsible for overseeing 

the bureaus’ ethics programs and providing ethics services to employees 

at the Office of the Secretary, the Office of the Solicitor, and to all of 

Interior’s political appointees. Interior’s ethics officials said that the high 

vacancy rate in their ethics office affected its ability to properly collect and 

review financial disclosure forms—one of the main responsibilities of the 

federal ethics program. According to Interior’s new DAEO, the office 

received an influx of financial disclosure reports during the presidential 

transition, but was unprepared to handle them. Furthermore, during 2017 

one official was responsible for reviewing and certifying more than 300 

public financial disclosure forms. The official was unable to balance 

 37The Federal Employee Viewpoint Survey measures employees’ perceptions of whether, 

and to what extent, conditions characteristic of successful organizations are present in 

their agencies. The survey serves as a tool for employees to share their perceptions in 

many critical areas including their work experiences, their agency, and leadership. The 

results provide agency leaders insight into areas where improvements have been made, 

as well as areas where improvements are needed.

38Interior ethics offices submitted and received approval to restructure its ethics program 

in 2018. Previously, the program did not have a formal organizational chart.
Page 23 GAO-19-249 Ethics

proper and timely review of forms with other responsibilities that also 

included reviewing and certifying more than 800 confidential disclosure 

forms. In the Interior Inspector General’s 2018 report on Interior’s Major 

Management Challenges, ethics staffing was identified as a limitation, as 

staffing shortages could lead to delays in reviewing appointees’ financial 

disclosure documentation.39

While the single Interior official was experienced in reviewing financial 

disclosure forms, Interior officials stated that there was not enough 

management support, training, or resources provided to properly review 

financial disclosure forms in 2017. According to the DAEO, a new 

supervisory ethics official for financial disclosure forms was hired in 

September 2018 as part of a proposed and ongoing organizational 

restructuring of Interior’s ethics office. In addition, Interior posted a job 

announcement for a second ethics attorney and now has two ethics 

specialists for financial disclosures. The DAEO stated that the ethics 

program also plans to increase the number of ethics officials that review 

and certify financial disclosures, and has established new program goals, 

such as improving ethics staff competencies for technical review of 

financial disclosure reports.

Interior ethics officials also reported that the government-wide hiring 

freeze affected their ability to hire staff and address ethics program staff 

continuity. To build capacity within the ethics program and create a strong 

ethical culture at the agency and bureau levels, the Acting Deputy 

Secretary recommended in May 2017 that Interior develop a structure 

and staffing plan to have a full-time ethics official for every 500 

employees by fiscal year 2020. On October 26, 2018, Interior officials 

stated that the ethics program was implementing the Acting Deputy 

Secretary’s staffing plan. However, OGE benchmarking guidance states 

that there is no “right” ratio for the number of ethics staff per employee, 

and that agencies should determine their ratio based on certain aspects 

of individual ethics programs, such as the scope of potential conflicts and 

the complexity of financial disclosure reports.

Interior officials could not explain how the ratio was determined nor 

provide a strategy for achieving the goal or evaluating whether the ratio is 

meeting the needs of the department in the future. We have previously 

 39Inspector General’s Statement Summarizing the Major Management and Performance 

Challenges Facing the U.S. Department of the Interior for Fiscal Year 2018. Report No. 

2018-ER-041, November 2018. 
Page 24 GAO-19-249 Ethics

identified leading practices for human capital management; these 

practices include that agencies should determine the workforce skills and 

competencies needed to achieve current and future goals and objectives 

as well as identify and develop strategies to address gaps. In addition, 

agencies should continually assess and improve human capital planning 

and investment, and assess the impact on accomplishing the mission. 

Without having a better understanding of resource needs and 

documenting how to properly allocate and determine needed resources, 

Interior may not accurately estimate its needs and may not be best 

positioned to assess and strengthen its ethics workforce to achieve 

program goals and objectives.

Moreover, staff turnover at the Interior ethics office also reduced 

institutional knowledge. For example, Interior’s ethics office could not 

produce the documentation of the policies and procedures that support its 

ethics program—an internal control requirement—such as documenting 

and providing written responses to ethics queries and the tools used to 

ensure short and long-term continuity of operations. However, the ethics 

office previously provided documented evidence of some of these policies 

and procedures in its response to OGE’s 2016 program review. Interior 

ethics officials stated that the OGE response was produced prior to the 

DAEO retiring and drafted by staff who no longer work at Interior.

Standards for Internal Control also require agencies to document key 

processes and procedures to retain organizational knowledge and 

mitigate the risk of having that knowledge limited to a few personnel, as 

well as a means to communicate that knowledge as needed to external 

parties, such as external auditors. Both HHS and SBA provided 

documentation of ethics program policies and procedures while Interior 

did not provide documentation. Since there was no formal documentation 

of the ethics program’s policies and procedures, Interior ethics officials 

stated that the ethics office will document them as part of its 

organizational restructuring plans. As of March 2019, Interior officials had 

not provided this documentation. For example, the ethics program is to 

ensure that all ethics related advice, legal analyses, and conclusions are 

documented. However, without Interior completing the documentation of 

its policies and procedures and making them accessible to staff, 

institutional knowledge may be lost, and there is greater risk of not 

achieving the goals and objectives of the ethics program.

SBA did not report challenges to recruiting or staff continuity in part 

because of the small size of the ethics program. SBA’s ethics program is 

administered by three full-time officials and during our review, the DAEO 
Page 25 GAO-19-249 Ethics

position was vacant for more than 3 months due to the retirement of the 

previous DAEO. However, the Alternate DAEO assumed the 

responsibility for managing the ethics program until a new DAEO was 

hired in August 2018. Ethics officials reported that the program could 

draw upon a pool of field attorneys previously designated to perform

collateral ethics duties to temporarily address disruptions in staffing. To 

address continuity and succession, SBA ethics officials reported that a 

headquarters staff attorney was detailed to the ethics program to prepare 

for the possible retirement of its current Alternate DAEO.

Strong ethics programs are critical to ensuring public trust in government 

and the integrity of actions taken on the public’s behalf. The executive 

branch ethics program is a shared responsibility across government. 

Political appointees, in particular agency heads, have a personal 

responsibility to exercise leadership in ethics. Some data are available on 

political appointees serving in the Executive Branch but the data have 

limitations that impede their usefulness. To facilitate independent review 

and analysis related to political appointees, members of the public need 

access to information on who is serving in political appointee positions. 

Otherwise, they are limited in their ability to discern whether appointees 

are performing their duties free of conflict. Information on the political 

appointees serving in the executive branch at any point in time would also 

facilitate congressional oversight. Both OPM and PPO are positioned to 

report these data, but there are some benefits and drawbacks of each 

agency’s current capacity that will need to be considered. Ultimately, it is 

a policy decision as to which agency is best positioned to report 

comprehensive and timely data on political appointees.

Further, a robust internal control system is critical for agency ethics 

programs to achieve their mission of preventing conflicts of interest on the 

part of their employees. Without effective internal controls, agency ethics 

programs cannot reasonably assure that they are mitigating the risk—or 

the appearance of—public servants making biased decisions when 

carrying out the governmental responsibilities entrusted to them. During 

the course of our review SBA took steps to establish written procedures 

for initial ethics training, but still needs to complete the implementation of

procedures to track and verify that all political appointees meet ethics 

training requirements.

As Interior continues to reorganize its ethics program, improved strategic 

workforce planning can help to accurately assess its needs, maintain 

continuity, and achieve program goals and objectives. Finally, ensuring 

Conclusions
Page 26 GAO-19-249 Ethics

that Interior’s ethics processes and procedures are fully documented and 

easily accessible to staff can help mitigate the risk of reduced institutional 

knowledge, and can improve the ability to communicate with external 

parties.

Congress should consider legislation requiring comprehensive and timely 

information on political appointees serving in the executive branch to be 

collected and made publicly accessible. (Matter for Consideration 1)

We are making a total of three recommendations, including one to SBA, 

and two to Interior.

The Administrator of the Small Business Administration should implement 

procedures to track and verify that required employees complete initial 

ethics training and that completion of this training is documented. 

(Recommendation 1)

The Secretary of the Interior should direct the Departmental Ethics Office, 

in conjunction with the Chief Human Capital Officer, to develop, 

document, and implement a strategic workforce planning process that 

aligns with its ongoing departmental reorganization and that is tailored to 

the specific needs of the ethics program. As part of this process, Interior 

should monitor and assess the critical skills and competencies that its 

ethics program needs presently and is projected to need in the future. 

(Recommendation 2)

The Secretary of the Interior should ensure that the department’s ethics 

program policies and procedures are documented and easily accessible 

to program staff. (Recommendation 3)

We provided a draft of this report for comment to the Department of 

Justice (DOJ), the White House Counsel’s Office at the Executive Office 

of the President (EOP), the Department of Health and Human Services 

(HHS), the Department of the Interior (Interior), the Inspector General of 

the Department of the Interior (OIG), the Office of Government Ethics 

(OGE), the Office of Personnel Management (OPM), and the Small 

Business Administration (SBA). 

Matter for 

Congressional 

Consideration

Recommendations for 

Executive Action

Agency Comments 

and Our Evaluation
Page 27 GAO-19-249 Ethics

Interior, SBA, and OGE provided written comments, which are 

reproduced in appendixes IV, V, and VI respectively. Interior officials 

concurred with our recommendations and described steps they are taking 

to begin addressing them. 

In our draft report, we made two recommendations to SBA. Our first 

recommendation was that SBA establish written procedures for initial 

ethics training as required. SBA officials did not agree or disagree with 

this recommendation, but during their review of the draft report, they 

provided documentation to show that they had established written 

procedures in line with our draft recommendation. As such, we revised 

our final report to include the actions taken by SBA in February 2019 and 

to delete our recommendation to establish written procedures for initial 

ethics training. 

With regard to our second draft recommendation to SBA, which remains 

in our final report as our first recommendation, SBA again did not agree 

or disagree with the recommendation. SBA officials provided 

documentation to support that they have taken initial steps to address our 

recommendation to implement procedures to track and verify completion 

of initial ethics training by political appointees. We plan to assess the 

implementation of these new procedures to confirm that, in operation, 

these procedures meet the intent of our recommendation.

In addition to the written comments we received, SBA, HHS, OGE, and 

OPM provided technical comments, which we incorporated as 

appropriate.

DOJ and the Interior OIG had no comments on the draft report. 

EOP did not respond to our request for comments.

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 1 day from the 

report date. At that time, we will send copies to the appropriate 

congressional committees, the Acting Attorney General of DOJ, the White 

House Counsel, the Secretary of HHS, the Acting Secretary of the 

Interior, the Acting Inspector General at the Interior, the Director of OGE, 

the Acting Director of OPM, the SBA Administrator, and other interested 

parties. In addition, the report is available at no charge on the GAO 

website at http://www.gao.gov.
Page 28 GAO-19-249 Ethics

If you or your staff have any questions about this report, please contact 

me at (202) 512-6806 or nguyentt@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. GAO staff who made key contributions to this 

report are listed in appendix VII.

Tranchau (Kris) T. Nguyen

Acting Director

Strategic Issues
Appendix I: Objectives, Scope, and 

Methodology

Page 29 GAO-19-249 Ethics

Our objectives were to evaluate the extent to which (1) existing data 

identify political appointees serving in the executive branch at any point in 

time, and (2) selected agencies use appropriate internal controls to 

reasonably ensure that their ethics programs are designed and 

implemented to meet statutory and regulatory requirements.

To evaluate the extent to which data identifying political appointees 

serving in the executive branch at any point in time exist, we first 

synthesized requirements for reporting and developed criteria for 

comprehensive and timely reporting. We reviewed relevant laws and 

standards, and the United States Government Policy and Supporting 

Positions (Plum Book).1 We used the Office of Management and Budget’s 

Open Government Directive (M-10-06) memorandum to develop criteria 

for transparency and public availability.

We interviewed officials from the Office of Personnel Management (OPM) 

to understand the extent to which data they collect on current political 

appointees are comprehensive, timely, and reportable. OPM provided 

data on the political appointees serving in the federal government 

between January 2017 and June 2018. We also requested and obtained 

information from OPM on the volume of Freedom of Information Act 

requests for data on political appointees to assess demand for this type of 

data. To further evaluate public demand for political appointee data, we 

interviewed two nongovernmental organizations that track political 

appointees in the executive branch, ProPublica, and the Partnership for 

Public Service. We gathered information on the public’s demand for 

information regarding political appointees, and the use and limitations of 

data. Both organizations provided statistics quantifying public demand, 

including number of unique visitors to their website and media 

impressions. Media impressions are any viewing of or interaction with a 

piece of content. We requested information or interviews with the Office of 

Presidential Personnel (PPO) and several White House Liaisons to 

understand how they track, maintain, and use data on political appointees 

serving in the executive branch. A senior leader at PPO and one White 

House Liaison acknowledged our request for an interview but deferred to

the White House Counsel’s Office. As well, an ethics officer indicated they 

would be unable to facilitate the exchange of information with the White 

House Liaison Office in their agency. The White House Counsel’s Office 

 1

The Plum Book is published after each presidential election. It lists federal civil service 

leadership and support positions in the legislative and executive branches of the federal 

government that may be subject to noncompetitive appointment.

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 30 GAO-19-249 Ethics

did not acknowledge requests for information or interviews. We 

interviewed former senior PPO officials from the two previous 

administrations to understand how they tracked, maintained and used 

data on political appointees.

To identify internal control processes and determine the extent to which 

selected agencies use appropriate controls to ensure their ethics 

programs are designed and implemented to meet statutory and regulatory 

requirements, we first identified four case study agencies. We selected a 

range of case study agencies based on the number and type of political 

appointees as well as the strength of their ethics programs, as 

determined by Office of Government Ethics (OGE) reviews. Using data 

from the 2016 Plum Book, we identified the total number of political 

appointee positions within each agency or department across the 

following four categories: presidential appointees with Senate 

confirmation (PAS), presidential appointees, noncareer members of the 

Senior Executive Service, and Schedule C appointees. We selected the 

Executive Office of the President (EOP) as a case study agency because 

EOP has the largest number of presidential appointees, and because 

OGE has not recently conducted a program review of EOP. According to 

OGE, ethics program reviews are a primary means of conducting 

systematic oversight of executive branch ethics programs. OGE 

completed a review of each agency between January 2014 and January 

2018.2 Since the White House Counsel’s Office did not acknowledge 

receipt of our notification letter we could not review EOP’s practices.

To allow for more comparability among case studies, we excluded 

agencies and departments that did not have at least one PAS, and one 

presidential appointee or noncareer member of the Senior Executive 

Service. From the remaining list of departments and agencies, we 

excluded those with nine or fewer total political appointee positions. We 

divided the remaining agencies into two groups: large agencies with more 

than 100 political appointees and small agencies with fewer than 100 

political appointees. To ensure we observed a range of practices, we 

selected a large agency with no recommendations in its most recent OGE 

program review—the Department of Health and Human Services and an 

agency with multiple unaddressed recommendations from its most recent 

OGE program review—the Department of the Interior.

 2

See https://oge.gov/web/oge.nsf/Program%20Review. 
Appendix I: Objectives, Scope, and 

Methodology

Page 31 GAO-19-249 Ethics

To select our final case study, we used human resources data from 

OPM’s FedScope tool to determine the number of employees at each 

agency as of September 2017. We limited our selection to noncabinet 

agencies with between 2,000 and 10,000 employees. Out of the four 

remaining agencies, we randomly selected the Small Business 

Administration.

To evaluate the extent to which the three reviewed agencies have and 

use appropriate internal controls to reasonably ensure that the objectives 

of their ethics programs are achieved, we reviewed selected principles 

from Standards for Internal Control in the Federal Government based on 

our review, analysis and professional judgment as to which were relevant 

to effectively execute an executive branch ethics program. Selected 

internal control principles included:

• 3.01: Management should establish an organizational structure, 

assign responsibility, and delegate authority to achieve the entity’s 

objectives;

• 4.01: Management should demonstrate a commitment to recruit, 

develop, and retain competent individuals;

• 10.01: Management should design control activities to achieve 

objectives and respond to risks; and

• 14.01: Management should internally communicate the necessary 

quality information to achieve the entity’s objectives.

Reviewed agencies confirmed that these internal control principles were 

relevant to effectively execute their ethics program. We provided each 

agency with an identical set of questions based on the selected internal 

control principles and components. We used agency responses to 

questions and supporting documentation to evaluate whether agencies’

policies and processes to oversee ethics compliance for political 

appointees were consistent with the internal control principles.

We used a nongeneralizable random sampling method to select political 

appointees whose documentation we would review for compliance with 

certain ethics requirements. Agencies provided data detailing the political 

appointees within the agency at any point in time beginning January 20, 

2017 and as of January 28, 2018. To assess the reliability of the data, we 

asked each agency’s officials about how the data were obtained, where 

the data came from, and what steps, if any, they each took to assure the 

accuracy and completeness of the data. Officials at each agency 

knowledgeable about their data provided responses. Based on those 
Appendix I: Objectives, Scope, and 

Methodology

Page 32 GAO-19-249 Ethics

responses, we determined that the data were sufficiently reliable to 

indicate each agency’s political appointees, with start and end dates, for 

use in selecting a sample of appointees at each agency. Within each 

agency, we used random sampling to identify up to three PAS appointees 

and up to nine non-PAS appointees, including up to three appointees that 

separated from the agency during the time frame above. Each case study 

agency completed a data collection instrument that identified the 

applicable ethics requirements for each selected appointee.3 Each 

agency provided documentation to communicate how those requirements 

were met for each appointee. We reviewed the documentation to 

determine whether agency internal controls were sufficient to ensure that 

certain ethics program requirements were met. In addition, we conducted 

interviews with agency ethics officials, as needed, to discuss 

documentation provided. We also conducted several interviews with OGE 

officials to inform how we developed the data collection instrument and 

evaluate appointee compliance in alignment with OGE’s principles and 

practices. Our review of political appointees’ documentation was limited to 

testing the sufficiency of the agencies’ ethics program processes and 

procedures. We did not review financial disclosure forms with the intent of 

identifying conflicts of interest nor did we perform a conflict of interest 

analysis. Also, because we used a nongeneralizable sample of political 

appointees, results from the sample cannot be used to make inferences 

about all the agencies’ political appointees.

We conducted this performance audit from October 2017 to February 

2019 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

 3

Applicable ethics requirements included Executive Order 13370 and sections 2634.201-

2638.205, 2634.601, 2634.605, 2634.801-2634.805, 2638.304-2638.305, and 2638.308-

2638.309 of title 5, Code of Federal Regulations.
Appendix II: Use of Internal Controls in 

Reviewed Agencies’ Ethics Programs

Page 33 GAO-19-249 Ethics

Table 2: Analysis of Internal Control Principles to Reviewed Agencies’ Ethics Programs

Selected Internal Control Components 

and Principles Ethics Program Evaluative Questions

Reviewed Agency 

Results

Control Environment HHS SBA Interior

Management should establish an 

organizational structure, assign 

responsibility, and delegate authority to 

achieve the entity’s objectives.

Has the agency established an organizational structure for its 

ethics program? ● ● ◐

Management should demonstrate a

commitment to recruit, develop, and retain 

competent individuals.

Are agency ethics program staff evaluated? ● ● ◐

Are agency ethics program staff’s expectations developed and 

documented?

● ● ◐

Does the agency commit resources to the ethics program? ● ● ◐

Does the agency recruit, develop, and train ethics program 

staff?

● ● ○

Does the agency prepare alternate or contingency plans for 

ethics program staff attrition, succession, or other potential 

disruptions to staff levels?

● ● ○

Control Activities

Management should design control activities 

to achieve objectives and respond to risks.

Does the agency have goals and objectives for the ethics 

program?

● ● ●

Are these goals and objectives documented? ● ● ●

Does the agency have processes and procedures in place to 

support the goals and objectives of the ethics program?

● ● ◐

Does the agency have processes and procedures in place to 

ensure political appointees who are not Presidential Appointees 

with Senate Confirmation do not undertake an activity that 

represents an actual or apparent conflict of interest?

● ● ◐

Does the agency have processes and procedures in place to 

ensure that political appointees receive required training?

● ◐ ●

Information and Communication

Management should internally communicate 

the necessary quality information to achieve 

the entity’s objectives.

Does the agency communicate ethics program related 

information to political appointees? ● ● ●

Legend: ●= Met; ◐ = Partially Met; ○ = Not Met

Source: GAO analysis of ethics program documentation. | GAO-19-249

Appendix II: Use of Internal Controls in 

Reviewed Agencies’ Ethics Programs
Appendix III: Ethics Provisions Applicable to 

Political Appointees and Results of Political 

Appointee Ethics Documentation Analysis

Page 34 GAO-19-249 Ethics

Table 3: Number of Sampled Political Appointees in Each Agency That Addressed Selected Ethics Requirements

Number of political appointees in each agency sample that the

requirement applied to, and the number that met the requirement

Selected Ethics Requirements

Small Business 

Administration

Department of Health and 

Human Services Department of the Interior

REQUIRED MET REQUIRED MET REQUIRED MET

Signed the Executive Order 13770, “Ethics 

Pledge”

10 10 11 11 12 12

Presidential Appointee with Senate 

confirmation (PAS) nominee financial 

disclosure report filed no later than 5 days 

after nomination by the President

2 2 1a 1 3 3

PAS nominee signed an Ethics Agreement 

to address identified conflicts of interest

2 2 3 3 3 3

Non-PAS new entrant financial disclosure 

report filed within 30 days of assuming the 

duties of the position, or within extension of 

time for filing

8 6 10 10 9 8d

Completed initial ethics training within 3 

months of appointment

10 10 11b 11 12 12

Received live ethics briefing within 15 days 

of appointment (PAS only)

2 2 1c 1 3 3

Termination financial disclosure report filed 

within 30 days of leaving government (if 

appointee departed from the agency)

1 1 3 3 1 0

Source: GAO analysis of ethics documentation for a sample of political appointees. | GAO-19-249

Notes: We reviewed ethics documentation for a randomly selected nongeneralizable sample of 10 

political appointees in positions at SBA and 12 political appointees in positions at HHS and Interior in 

place between January 20, 2017 and January 28, 2018. To ensure we included certain types of 

political appointees in our review, we grouped the political appointees from each agency into three 

groups: individuals in presidentially appointed, Senate confirmed (PAS) positions, individuals who left 

the agency during the time frame of our review, and all remaining individuals. We randomly selected 

three, three, and six political appointees from each target group, respectively. At SBA, the total PAS 

appointees and total individuals who left the agency during our review time frame was less than the 

target. As a result, there were fewer appointees in our SBA sample compared to the other agencies.

Because we used a nongeneralizable sample of political appointees, results from the sample cannot 

be used to make inferences about all of the agencies’ political appointees.

a

Two of the three PAS appointees in our HHS sample were incumbents from previous 

administrations. Due to records retention schedule, we were unable to evaluate the nominee reports 

filed by those two appointees.

b

As noted, two PAS appointees in our HHS sample were incumbent appointees. Due to records 

retention schedule we were unable to review documentation and assess whether one of the 

incumbent appointees received the training. However, HHS provided email documentation to support 

that the other incumbent appointee received initial ethics training.

c

The requirement for PAS appointees to receive an additional ethics briefing was not applicable at the 

time of appointment for two incumbent appointees from HHS.

Appendix III: Ethics Provisions Applicable to 

Political Appointees and Results of Political 

Appointee Ethics Documentation Analysis
Appendix III: Ethics Provisions Applicable to 

Political Appointees and Results of Political 

Appointee Ethics Documentation Analysis

Page 35 GAO-19-249 Ethics

d

One appointee at Interior did not file a new entrant or a termination financial disclosure report. 

According to ethics officials at Interior, they mistakenly determined that the appointee was not 

required to file because she did not serve in her position for more than 60 days. Based on our 

analysis of the appointees’ appointment and departure dates, the appointee served for 63 days and 

should have been required to file.
Appendix IV: Comments from the Department 

of the Interior

Page 36 GAO-19-249 Ethics

Appendix IV: Comments from the 

Department of the Interior

Now recommendation 3.

Now recommendation 2.
Appendix IV: Comments from the Department 

of the Interior

Page 37 GAO-19-249 Ethics
Appendix V: Comments from the U.S. Small 

Business Administration

Page 38 GAO-19-249 Ethics

Appendix V: Comments from the U.S. Small 

Business Administration
Appendix V: Comments from the U.S. Small 

Business Administration

Page 39 GAO-19-249 Ethics
Appendix V: Comments from the U.S. Small 

Business Administration

Page 40 GAO-19-249 Ethics
Appendix V: Comments from the U.S. Small 

Business Administration

Page 41 GAO-19-249 Ethics
Appendix VI: Comments from the United 

States Office of Government Ethics

Page 42 GAO-19-249 Ethics

Appendix VI: Comments from the United 

States Office of Government Ethics
Appendix VI: Comments from the United 

States Office of Government Ethics

Page 43 GAO-19-249 Ethics
Appendix VII: GAO Contact and Staff 

Acknowledgments

Page 44 GAO-19-249 Ethics

Tranchau (Kris) T. Nguyen, (202) 512-6806 or NguyenTT@gao.gov

In addition to the above contact, Melissa Wolf and Carol Henn (Assistant 

Directors), Erinn L. Sauer (Analyst-in-Charge), Caitlin Cusati, Ann 

Czapiewski, Robert Gebhart, Travis Hill, James Lager, Brittaini Maul, 

Steven Putansu, Mary Raneses, Andrew J. Stephens, and Mackenzie D. 

Verniero made major contributions to this report.

Appendix VII: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(102344)
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