Determining Which Positions Should File A Confidential Financial Disclosure Report: A Worksheet

This job aid is designed to assist ethics officials in determining whether a career employee should file a Confidential Financial 

Disclosure Report (OGE Form 450). Some Special Government Employees and Schedule C employees may also be required to file 

confidential financial disclosure reports. If you have questions about the criteria listed below, contact your agency’s Ethics Office. 

I. Pay

1.  Is the employee’s position classified at or below the GS-15

level?

 OR 

 If the employee is not paid on the GS scale, is the employee’s

rate of basic pay less than 120% of the minimum rate of basic pay for 

the GS-15 level? 

 Basic pay does not include locality payments, bonuses, etc. For 

reemployed annuitants, the rate of basic pay is the employee’s basic pay 

before any salary offset is applied. 

 Yes

Go to question 2. 

 No

Your agency’s Ethics 

Office will determine 

if this employee must 

file a public financial 

disclosure form. 

II. Type of Work Done By the Employee

2. Does the employee’s work involve at least one of the following:

 contracting or procurements above the micro-purchase threshold;

Example: A GS-7 Office Automation Clerk is issued a purchase 

card to buy office supplies for her work unit as needed. Such an 

employee is generally excluded from filing. 

 administering, awarding, monitoring, or making determinations

regarding grants, subsidies, licenses, or other federal benefits;

 regulating, auditing, or inspecting non-federal entities*;

 performing other activities, when those activities will have a direct

and substantial effect on the financial interests of non-federal entities.

*Non-federal entities include, for example, businesses, non-profit

organizations, and state and local governments.

 Yes

Go to question 4. 

 No

Go to question 3. 

3. Is the employee serving in any other position where there is a

potential for conflict of interest, appearance of favoritism or loss of

impartiality?

Examples include:

 investigating or prosecuting violations of criminal or civil law;

 representing the United States in litigation or other proceedings;

 scientific or social science research, when the research will have a

direct and substantial effect on the financial interests of non-federal

entities.

 Yes

Go to question 4.

 No

If you said “no” to 

questions 2 and 3, the 

employee does not 

need to file.
4. Does the employee:

 only provide information?

Example: A GS-13 librarian for the Patent and Trademark Office 

(PTO) shows PTO staff members how to research the uniqueness 

of an invention and design complex search queries of the 

agency’s electronic databases. The librarian does not make 

decisions on the patentability of the invention. 

OR 

 only work on administrative or peripheral matters?

Example: A draftsman prepares the drawings to be used by an 

agency in soliciting bids for construction work on a bridge. He is 

not involved in the contracting process associated with the 

construction. 

Example: An agency has just hired a GS-5 Procurement Assistant 

who is responsible for typing and processing procurement 

documents, answering status inquiries from the public, 

performing office support duties such as filing and copying, and 

maintaining an online contract database. The Assistant has no 

actual contracting or procurement responsibilities. 

 Yes

The employee does 

not need to file a 

confidential financial 

disclosure report. 

 No

Go to question 5. 

III. Employee’s Level of Responsibility

5. Does the employee:

 engage in the work activity identified in Section II by exercising

significant judgment in performing any of the following job functions?

 making decisions;

 approving or disapproving;

 making recommendations;

 conducting investigations;

 rendering advice or opinions.

 OR 

 actively supervise a subordinate’s performance of any of the abovelisted job functions?

 Yes

Go to question 6. 

 No

The employee does 

not need to file a 

confidential financial 

disclosure report. 

6. Does the employee receive substantial supervisory review?

Example: A GS-13 employee at an independent grant making 

agency conducts the initial agency review of grant applications 

from nonprofit organizations and advises the Deputy Assistant 

Chairman for Grants and Awards about the merits of each 

application. Although the process of reviewing the grant 

applications entails significant judgment, the employee’s analysis 

and recommendations are reviewed by the Deputy Assistant 

Chairman, and the Assistant Chairman, before the Chairman 

decides what grants to award. 

 Yes

The employee does 

not need to file a 

confidential financial 

disclosure report. 

 No

The employee should 

file a confidential 

financial disclosure 

report. 

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