To the contrary, the review clearly showed that actual compliance by appointees has most often been timely. The situation is further aggravated by the common agency practice of not notifying OGE until all terms of a particular agreement have been satisfied. The latter practice has been consistent with OGE's policy of not considering an agreement satisfied until all agreed upon actions have been taken. The review also identified other areas of the process which warrant improvement. The fairly common problem of untimely notifications, combined with lax monitoring and follow-up procedures noted during the review at many agencies, demonstrate the need for more formal follow up on unsatisfied ethics agreements.
Few agencies perform systematic monitoring and follow up during the three-month compliance period.
During the review, several agencies indicated a reliance on OGE's telephone call to prompt agency follow up with appointees. They also cited difficulties in getting busy appointees to devote the proper attention to the ethics agreement process. To improve the accuracy of data produced by its automated ethics agreement tracking system, OGE is expanding the system to incorporate compliance-based information. In the future, the system will collect, monitor, and document actual compliance dates as well as OGE notification dates. Accordingly, agencies are advised of the slightly different reporting requirements imposed by the expanded ethics agreement tracking system.