OGE rolls out Integrity public disclosure filing system

The Office of Government Ethics (OGE) launched Integrity, a new electronic financial disclosure program to help streamline public filings at executive branch agencies, on Jan. 1. Nineteen agencies have already begun using Integrity and more than two dozen others are working with OGE to implement the program.

“Integrity significantly enhances the filing, review, and program management aspects of the executive branch public financial disclosure program,” OGE Director Walter M. Shaub Jr. wrote in a March 2 program advisory. “A combination of data-entry tables and context dependent questions helps filers to identify all of their reportable financial interests and to disclose those interests correctly. Integrity also enables agency ethics officials to assign, review, track, and manage reports electronically.”

President Barack Obama signed the Stop Trading on Congressional Knowledge Act of 2012 (STOCK Act) on April 4, 2012, which outlined new financial reporting requirements for federal agencies, executives, the President and Congress. The law amended the 1978 Ethics in Government Act to allow the public more access to government officials’ financial dealings.

Under the STOCK Act, these feds were required to file reports of new transactions in stocks, bonds, commodities or other securities that exceed $1,000 to the OGE — information that would eventually wind up on a publicly searchable database.

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In April 2013, Congress repealed the STOCK Act reporting requirements for senior execs. Despite this change, the financial-disclosure requirements still apply to the President, Vice President, members of Congress and executive-branch officials requiring Senate confirmation.

“From the start, OGE’s two primary objectives for this project have been to increase the accuracy of public financial disclosure and to reduce the burden on filers,” Shaub said. “Toward these ends, a cross-divisional team of OGE analysts and attorneys with expertise in financial disclosure developed the content for Integrity, and OGE worked closely with a team of user-experience professionals to make the system user friendly. Throughout Integrity’s development, OGE collaborated with agency ethics officials, who provided input and tested the system extensively.”

Agencies, which can implement Integrity at no cost, are not required to implement the program in 2015. Each agency can make its own determination of how employees must file the public financial disclosure reports, with OGE acting as the supervising ethics office.

If an agency decides to adopt Integrity this year, it is responsible for directing either all or subsets of its public filers to file and also which of the various public reports they must file in calendar 2015.

OGE will begin on Jan. 1, 2016, to collect public reports via Integrity from Senate-confirmed appointees and all Designated Agency Ethics Officials (DAEO), who also submit their reports to OGE.

“OGE is currently finalizing a processing sequence (‘workflow’) in Integrity for Presidential nominees whose public reports are submitted to OGE and is coordinating with appropriate officials regarding those reports,” Shaub said. “As of this time, OGE has not made a determination that other public financial disclosure reports must be filed through Integrity in calendar year 2016; however, executive branch agencies are strongly encouraged to use Integrity for all other public financial disclosure reports, except for reports covered by 5 U.S.C. app. § 105(a)(1) and (2), in calendar year 2016.”

In addition, OGE redesigned its public financial disclosure report form. OGE Form 278e (Executive Branch Personnel Public Financial Disclosure) will now be used instead of the old OGE Form 278.

“OGE has received approval to begin using the OGE Form 278e immediately,” Shaub said. “Through December 31, 2015, executive branch public filers may use either the OGE Form 278e or the old OGE Form 278. Beginning January 1, 2016, executive branch public filers will use only the OGE Form 278e.”

OGE will start collecting status updates in May 2016 on the financial disclosure programs on a recurring basis at each agency to determine how many filers are required to make disclosures and the number of disclosure reports completed.

“This data will enhance OGE’s oversight of the executive branch ethics program by allowing OGE to monitor each agency’s progress in administering its individual financial disclosure program,” Shaub said. “When consolidated with data from other agencies, this data will enable OGE to evaluate the strength of the overall executive branch-wide ethics program. It will also facilitate data-driven decisions in selecting agencies for program reviews.”

With the launch of Integrity, OGE is also rescinding previous authorizations that allowed agencies to develop their own electronic filing systems for public or confidential financial disclosure reports, Shaub said. OGE is doing this “to reduce fragmentation, eliminate the duplication of cost and effort, and increase the uniformity of public financial disclosure in the executive branch.”

Agencies that are already using electronic filing systems for public disclosure reports can request provisional authorization from OGE to keep those systems going. However, they must file their requests by July 1, 2015.

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