U.S. OFFICE OF GOVERNMENT eTHICS
sTRATEGIC PLAN
fISCAL YEARS 2007 – 2011
Section 1--Introduction
The Office of Government Ethics (OGE) was established by the Ethics in Government Act of 1978 and charged with providing “overall direction of executive branch policies related to preventing conflicts of interest” for executive branch employees. Working in partnership with agency ethics officials, OGE has built on this foundation and developed a model ethics program. Today, the ethics program is marked by consistent administration and implementation of a basic program structure within the executive branch and uniform interpretation and application of ethics laws and rules.
OGE now seeks to enhance this ethics program and continue to foster public confidence in Government programs and operations. To achieve its mission and ultimately its stated vision, OGE has established the following three strategic goals:
· Strengthening the ethical culture within the executive branch
· Preventing conflicts of interest; and
· Promoting good governance.
Vision:
Achieve a high level of public confidence in the integrity of Government.
Mission:
Provide leadership for the purpose of promoting an ethical workforce, preventing conflicts of interest and supporting good governance initiatives.
OGE Organization
The Office of the Director provides overall direction to the executive branch ethics program and is responsible for ensuring that OGE fulfills its Congressional and Presidential mandates.
The Office of Agency Programs is responsible for monitoring and providing services to Federal executive branch agency ethics programs. This Office has three divisions: Program Services Division, Education Division, and the Program Review Division. The three divisions coordinate their services to assist agencies in carrying out their programs. They work closely with agencies to identify and resolve problem areas, provide educational materials and training, staying abreast of budgetary concerns and identifying the emergent issues to be addressed by OGE. The Office holds an annual ethics conference for government-wide ethics officials, as well as hosting smaller topic specific events quarterly during the year.
The Office of General Counsel and Legal Policy is responsible for establishing and maintaining a uniform legal framework of Government ethics for executive branch employees. This Office develops executive branch ethics program policies and regulations, interprets laws and regulations, assists agencies in legal and policy implementations, and recommends changes in conflicts of interest and ethics statutes. It also responds to requests for information from the media, such as newspapers and wire services, and similar other news organizations. The Office also provides liaison to the Congress and to the Office of Management and Budget.
The Office of International Assistance and Governance Initiatives coordinates the Office's support of U.S. efforts in promoting international ethics, anti-corruption and good governance intitiatives.
The Office of Administration and Information Management provides essential support to all OGE operating programs through two divisions. The Administration Division has program responsibilities for: personnel, payroll, fiscal resource management, facilities and property management, travel, procurement, and the publishing and printing of materials. The Information Resource Management Division responsibilities lie within telecommunications, web graphics, and records management; as well as the program management of information and web site technologies.
SECTION 2--STRATEGIC GOALS AND PERFORMANCE CRITERIA
OGE tracks its progress toward achieving its strategic goals through specific, accountable objectives evaluated by established performance measures. OGE is able to provide baseline data for the majority of measures by merging statistical data from a variety of existing sources such as ethics training surveys, annual ethics program questionnaires, and employee ethics surveys. However, some of the measures identified are new. FY 2006 will be spent gathering new data to determine the baseline for those measures and refining existing evaluation mechanisms to increase the accuracy of all other measures. The objectives and measures in this document demonstrate the value of our work in promoting integrity in Government.
SECTION 3--MANAGEMENT CHALLENGES
OGE’s strategic planning assumes adequate fiscal and human resources and the successful coordination and cooperation of the executive and legislative branches in effecting appropriate changes to existing ethics programs. Because the day to day execution of the executive branch ethics program is the responsibility of each individual agency, the success of OGE’s goals regarding agency ethics programs is largely dependent on agency leadership’s commitment to, and involvement in the program, including agency leadership’s willingness to adequately staff the function. Furthermore, because the vast majority of ethics officials perform ethics-related duties part-time, agency programs are vulnerable to other priorities that may detract from the ethics officials’ ability to administer their ethics programs.
OGE plays a significant role during a transition from one Presidential administration to the next. At that time, OGE experiences a particularly large and varied workload requiring it to shift its resources to better serve the incoming President and the ethics program. For example, the number of nominee public financial disclosure reports increases dramatically as does the number of reports filed by those employees who terminate their Government service. At the same time, more employees must receive advice and counseling to orient them on Government ethics rules. As a result, OGE will be particularly challenged to balance the immediate needs of the new administration and matters not directly related to the transition.
SECTION 4--PRESIDENT’S MANAGEMENT AGENDA
OGE will continue to actively explore ways to improve how it conducts the activities discussed in this document. By the very nature of its function, OGE’s primary capital resource is its staff. Thus, OGE must continually strive for a skilled, knowledgeable, diverse, and high performing workforce. By maximizing its human resources, OGE will be able to improve its financial accountability and business processes and better integrate its human and fiscal resources to overcome obstacles, focus on results, and achieve better performance of our stated goals and objectives.
Section 5--OGE’s Strategic Goals:
Strategic Goal 1--Strengthening the ethical culture and promoting an ethical workforce within the executive branch
Introduction
To strengthen the ethical culture and promote an ethical workforce within the executive branch, OGE must develop and disseminate effective and timely ethics policy and provide assistance and oversight to executive branch agencies. Employees must be afforded adequate opportunities to become knowledgeable about their responsibilities and senior level officials must be committed to the success of their agencies ethics program.
How well OGE performs in ensuring that the ethical culture is strengthened will be assessed by reaching out to our customers to ensure that our resources are being used effectively and, as necessary, shifting those resources as dictated by our customer satisfaction surveys.
Objectives
The following four objectives support Strengthening the Ethical Culture.
Objective 1.1 Improve the effectiveness of ethics policy.
Objective 1.2 Enhance assistance to and oversight of agency ethics programs.
Objective 1.3 Increase employee awareness of their ethics responsibilities.
Objective 1.4 Increase OGE’s focus on senior officials’ role in implementing the ethics program.
Objective 1.1 Improve the effectiveness of ethics policy.
OGE was established to develop executive branch-wide ethics policy that ensures consistent interpretation and implementation of the ethics laws, rules and program requirements across the executive branch. The strategic challenge for OGE is to ensure that its policies are sound and practicable and that the guidance developed to implement the policies is understandable, clearly communicated and as widely disseminated as possible.
Strategies for Objective 1.1
Anticipate and target emerging ethics program issues.
OGE will maintain an active network of communication with ethics officials and other interested parties, including Congress and the White House, to identify executive branch-wide and crosscutting issues where policy guidance or advice is necessary. OGE’s senior managers will host meetings regularly with senior ethics and other officials to discuss issues of concern, and OGE staff will become active participants in the Interagency Ethics Council, a forum for discussing emerging ethics issues. In addition, OGE will evaluate information collected from a variety of other sources, such as surveys, program reviews, and requests for advice. OGE will prioritize and develop a plan to address emerging ethics program issues.
Evaluate the effectiveness of guidance and update as necessary.
OGE will establish a schedule to examine all existing policy guidance to ascertain if it contains information that has been superseded by subsequent developments and will provide timely notice to users.
Assess the format, scope and usefulness of periodic guidance.
OGE will evaluate the effectiveness of the means used to disseminate policy guidance to users and will make appropriate changes as warranted.
Performance Measures
Note: Click on Object 1.1 to view a text version of the Improve the effectiveness of ethics policy table.
|
Performance Measures |
Performance Targets |
Baseline
|
FY 2007 |
FY 2008 |
FY 2009 |
FY 2010 |
FY 2011 |
|
Percent of customers who rate OGE as responsive or very responsive to emerging issues. |
5% |
40% |
60% |
70% |
75% |
80% |
|
Percent of customers who rate guidance as useful or very useful. |
70% |
75% |
80% |
80% |
85% |
90% |
|
Percent of customers who say they receive the guidance they need to do their job effectively. |
75% |
80% |
80% |
80% |
85% |
90% |
Objective 1.2 Enhance assistance and oversight of agency ethics programs.
Each executive branch agency has a Designated Agency Ethics Official who serves as the cornerstone of the ethics program. Through the programs they administer, OGE promotes an ethical culture and strengthens the public’s confidence that the Government’s business is conducted with impartiality and integrity.
Strategies for Objective 1.2
Ensure that ethics officials have the knowledge required to effectively carry out their duties by (1) expanding the number and type of training and education opportunities and (2) developing and maintaining a database of informal ethics program advice.
OGE provides training and education opportunities to all ethics officials through classroom instruction, educational materials and an annual conference. OGE will increase training opportunities offered to ethics officials by developing basic web-based courses and advanced instructor-led training. In addition, OGE will provide informal opportunities to exchange information such as lunch time seminars and speakers programs. Utilizing technology, such as satellite broadcast and video conferences, OGE will more widely distribute training and education opportunities and materials.
With the growing dependence on telephone and email communication, OGE receives an increasing number of inquiries from agencies for informal guidance on ethics issues. The guidance provided often has broad application and would benefit the ethics program if it were shared with the entire ethics community. OGE will develop and maintain a system to centrally collect the informal advice it provides to agency ethics officials and identify an appropriate mechanism to disseminate advice to the ethics community as appropriate.
Focus education and training programs on new ethics officials.
Approximately 90 percent of ethics officials perform ethics program services part-time. Additionally, there is a high rate of staff turnover in the ethics program because it is often a collateral duty. As a result, OGE needs to focus greater attention on new ethics officials who are expected to provide sound advice soon after assuming ethics responsibilities. OGE will develop a two-day orientation program for new ethics officials. OGE will also develop an Ethics Program Administration Manual that incorporates the use of technology and e-learning tools along with more traditional training and education methods, specifically for new ethics officials.
Improve ethics program evaluation techniques.
The success of well-established ethics programs can be jeopardized with changes in agency resource priorities. Therefore, it is important for OGE to accurately assess whether (1) agencies are adequately staffing the ethics program, (2) ethics officials are carrying out their duties and responsibilities and (3) agencies are moving beyond basic regulatory compliance and inserting ethics into the fabric of agency processes. OGE will increase its interactions with the Inspector General community and the Government Accountability Office to identify best practices in the area of program evaluation techniques. Additionally, OGE will develop a program of self-assessment for agencies to use in years that OGE is not scheduled to perform a program review.
Identify and disseminate agency ethics program best practices.
Through its program review function, OGE is in a unique position to observe successes and innovations in agency ethics program administration. OGE will also solicit best practices from agencies in years in which they are not subject to a program review. OGE will then utilize technology to more widely disseminate innovative and successful ethics program strategies.
Performance Measures
Note: Click on Object 1.2 to view a text version of the Enhance assistance and oversight table.
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Performance Measures |
Performance Targets |
|||||
|
Baseline |
FY 2007 |
FY 2008 |
FY 2009 |
FY 2010 |
FY 2011 |
|
|
Percent of ethics officials who are satisfied or very satisfied with education and training opportunities. |
85% |
90% |
90% |
90% |
90% |
90% |
|
Percent of ethics officials who are satisfied or very satisfied with OGE produced education and training materials and job aids. |
85% |
90% |
90% |
90% |
90% |
90% |
|
Percent of ethics officials who view OGE’s program review as adding value to their own programs. |
85% |
85% |
90% |
90% |
90% |
90% |
|
Percent of agencies using a self-assessment tool to evaluate their programs |
15% |
25% |
50%
|
70% |
75% |
85% |
|
Percent of agencies using a self-assessment tool that report it was useful. |
70% |
70%
|
80% |
80% |
90% |
100% |
|
Percent of customers who are satisfied or very satisfied with information shared on ethics program best practices. |
TBD |
|
|
|
85% |
85% |
Objective 1.3 Increase employee awareness of their ethics responsibilities.
While employees bear ultimate responsibility for complying with ethics laws and regulations and ensuring the public’s trust, OGE has a leadership responsibility to ensure workers are aware of and understand these responsibilities. The long term outcome of this objective is to have employees incorporate ethics into their decision-making when carrying out their official responsibilities.
Strategies for Objective 1.3
Develop educational support for various sectors of the executive branch workforce.
One of the real strengths of the executive branch ethics program is the systematic training of employees on the regulatory standards and conflict of interest statutes. Once a year, agencies are required to provide training to the highest level officials. New employees must be made aware of the standards of conduct when entering Government service. Educating public servants about conflict-of-interest standards is a key component of preventing conflicts of interest. OGE will use information collected from agencies to identify the subject areas where OGE support of employee training is most useful. Once identified, OGE will consult with agencies to determine the most effective and practical methods for providing appropriate support in those areas.
Encourage agencies to demonstrate consistency between ethics rules and agency practices by utilizing administrative sanctions to enforce laws and regulations.
Research shows that, without appropriate follow up on violations, employees may perceive that leadership is not committed to maintaining an ethical workplace. Demonstrated enforcement of the ethics rules complements the training employees receive on the rules themselves. OGE will use data collected on administrative sanctions to reinforce the significance of the ethics program and encourage agencies to pursue administrative sanctions where appropriate. Additionally, OGE will use the information to effectively focus education and outreach efforts.
Performance Measures
Note: Click on Object 1.3 to view a text version of the Increase employee awareness and understanding table.
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Performance Measures |
Performance Targets |
|||||
|
Baseline |
FY2007 |
FY 2008 |
FY 2009 |
FY 2010 |
FY 2011 |
|
|
Percent of agencies that incorporate OGE education or training products into their program. |
30% |
50% |
70% |
80% |
90% |
90% |
|
Percent of customers whose knowledge of the ethics rules increased after participating in OGE developed training. |
60% |
80% |
90% |
100% |
100% |
100% |
|
Percent of employees who are satisfied or very satisfied with OGE developed education or training programs. |
50% |
60% |
70%
|
70% |
80% |
80% |
|
Percent of employees who indicate they are familiar with ethics rules. |
50% |
60% |
70% |
70% |
80% |
80% |
|
Percent of employees who indicate that they recognize ethics issues when they arise. |
55% |
65% |
70% |
75% |
80% |
80% |
|
Percent of employees who believe that if violations of the ethics rules are reported to the agency follow-up is prompt and effective. |
45% |
55% |
65% |
70% |
75% |
75% |
|
Percent of employees who believe that employees who are caught violating ethics rules are disciplined. |
40% |
40% |
45% |
50% |
55% |
60% |
Objective 1.4 Increase OGE’s focus on senior officials’ role in implementing the ethics program.
The ethical culture of an organization starts at the top. Research shows that there is a strong relationship between leaders “paying attention” to ethics and desirable program results such as employee willingness to seek ethics advice when needed. In FY 2005, OGE began assessing executive branch employee perceptions of whether agency leadership and supervisors pay attention to ethics. OGE will continue these assessments, and will increase its efforts to provide specialized services to agency leaders and supervisors.
Strategy for Objective 1.4
Promote agency leadership support in ensuring an ethical culture within the agency.
OGE must promote the ethics program to all senior agency officials. OGE will reach out to these senior officials prior to or at the time they enter public service by providing educational materials and, where appropriate, opportunities for discussion, focused on ethics issues that are unique to high-level positions of authority as well as the general ethics issues faced by all executive branch employees.
Performance Measures
Note: Click on Object 1.4 to view a text version of the Promoting agency leadership table.
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Objective 1.4 Promoting agency leadership |
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Performance Measures |
Performance Targets |
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|
Baseline |
FY 2007 |
FY 2008 |
FY 2009 |
FY 2010 |
FY 2011 |
|
|
Percent of employees who believe their agency leaders pay attention to ethics |
60% |
65% |
70% |
75% |
75% |
80% |
|
Percent of employees who believe their immediate supervisors pay attention to ethics |
55% |
60% |
70% |
75% |
80% |
80% |
Strategic Goal 2--Preventing conflicts of interest
Introduction
Many of OGE’s responsibilities are directed at preventing employee conflicts of interest. Financial disclosure is the primary tool OGE uses for identifying and resolving potential conflicts of interest. Financial disclosure contributes significantly to the goal of maintaining the integrity of Government operations and programs by providing a mechanism for conflict of interest reviews. Making the financial disclosure reports submitted by the highest level officials publicly available ensures outside scrutiny, which contributes to public confidence in Government and helps to deter officials from becoming involved in official matters in which they have conflicting financial interests.
Because the financial disclosure system is so extensive and requires the expenditure of substantial resources by both OGE and the agencies, it is important for OGE to ensure that the process of filing, collecting and reviewing reports is as efficient as possible and does not unduly impede agency operations.
The following three Objectives support Preventing Conflict of Interest.
Objective 2.1 Enhance assistance to the President and the Congress in the Presidential appointments process.
Objective 2.2 Monitor continued compliance with conflict of interest laws.
Objective 2.3 Administer an effective confidential financial disclosure system.
Objective 2.1 Enhance assistance to the President and the Congress in the Presidential appointments process.
The public financial disclosure process provides assurance to the President and Congress that appointees to the highest level Government positions will be free from conflicts of interest. OGE reviews draft public financial disclosure reports filed by individuals selected by the President for these positions in the executive branch. Potential conflicts of interest are identified and the individual agrees to take the steps necessary to resolve any conflicts. OGE is responsible for informing the appropriate Senate committee that the individual will be in compliance with applicable ethics rules and laws. In addition to preventing conflicts of interest, the review process also provides an opportunity to familiarize the prospective nominee with the ethics program.
Strategies for Objective 2.1
Use technology to improve the financial disclosure reporting and review process.
OGE will improve the administration of the financial disclosure system. One of the primary initiatives in this area is using technology to make the filing and reviewing of financial disclosure forms more efficient by reducing the need for paper filing and evaluation. OGE has formed a partnership with the Department of the Army to develop an electronic filing system. The system will allow for on-line completion and submission of the report, as well as on-line certification. Once the electronic system is fully tested, it will be made available to all agencies for use by public financial disclosure filers.
Promote proposed improvements to the financial disclosure law.
OGE has issued two reports to Congress (April 2001 and March 2005) recommending improvements to simplify the public financial disclosure reporting requirements. In the reports, OGE concluded that the current public financial disclosure system requires reporting more detailed information than is useful or necessary to achieve its fundamental goals of preventing conflicts of interest and maintaining the public’s confidence in Government. Such unnecessary detail could be eliminated without reducing compliance with applicable conflict of interest requirements and without harming the public interest in disclosure. OGE will continue to pursue proposed legislation to implement these improvements.
Ensure timely compliance with ethics agreements.
OGE monitors compliance by Presidential appointees with ethics agreements entered during the nominee review process. The agreements outline the steps an appointee must take to insulate himself and protect the agency processes from conflict of interest. This system not only aids the appointee and the agency, but it assures the public and the Senate committee responsible for holding the confirmation hearing, that potential conflicts will be resolved. OGE will establish mechanisms to ensure timely compliance with ethics agreements by all Presidential appointees.
Performance Measures
Note: Click on Object 2.1 to view a text version of the Enhance assistance to the President and the Congress table.
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Performance Measures |
Performance Targets |
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|
Baseline |
FY 2007 |
FY 2008 |
FY 2009 |
FY 2010 |
FY 2011 |
|
|
Number of agencies using the new electronic filing system |
TBD |
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