Agency Ethics Program Assessment and Benchmarking Insights
The content provides insights into the annual agency ethics program questionnaire for CY19, including evaluation results, benchmarking practices, and examples of assessment outcomes such as training enhancements and technology implementations.
Download Presentation
Please find below an Image/Link to download the presentation.
The content on the website is provided AS IS for your information and personal use only. It may not be sold, licensed, or shared on other websites without obtaining consent from the author. Download presentation by click this link. If you encounter any issues during the download, it is possible that the publisher has removed the file from their server.
E N D
Presentation Transcript
CY19 Annual Agency Ethics Program Questionnaire: Benchmark your Program July 2019 Wendy Pond, Senior Desk Officer Office of Government Ethics
Agenda Background Program Practices: how do other agencies assess and evaluate? Benchmarking: key compliance rates OGE consultation for agency-specific benchmarking
Background Annual Questionnaire fulfills statutory reporting requirement Individual responses posted online Summary posted online
Agenda Background Program Practices: how do other agencies assess and evaluate? Benchmarking: key compliance rates OGE consultation for agency-specific benchmarking
Did you agency evaluate any aspect of the ethics program in 2019? 38% No 62% Yes
Examples of Assessment Results Substantive determinations Considered adoption of a supplemental ethics rule Officials considered whether the current recusal policy is too broad Updates related to the application of 18 USC 205 to agency activities
Examples of Assessment Results Training For the initial ethics training, the plan is to offer the course three times each month (instead of once a month) to ensure new employees receive the training within 90 days For the annual training, the Directorates will conduct "all hands meetings" with leaders assisting representatives from OGC to discuss current ethical concerns and cover the requisite training topics Enterprise risk management assessment that resulted in revisions to the format and content of annual training, and development of a new ethics communication plan for 2020
Examples of Assessment Results Technology Instituted SharePoint tracker to track incoming requests for ethics advice and opinions. Automating ethics programs for easy information storage, retrieval, and utilization. Examples include: greater use of ethics inter and intranet websites, connecting different databases such as HR employee records and ethics records tracking systems IT network access will be disabled for any employee who does not complete mandatory ethics training by the required due date
Examples of Assessment Results Staffing Assigned additional attorneys to assist with OGE 450 reviews again since last year's first time was determined to be a success. The DAEO made policy changes with regard to which attorneys would be identified as ethics counselors. Only those actually attending ethics training and working ethics issues on a consistent basis would be so designated. Agency leadership has agreed to allow the Ethics Office to recruit various employees from other offices to serve in a temporary capacity until we are able to hire full-time staff to replace staff that separated from the Agency
Examples of Assessment Results Intra-Agency Coordination Working to have to have Compliance and Business Integrity staff serve as ethics advisors on basic government ethics issues. This will leverage assets in place at Medical Centers, increasing access to local ethics advisors. OGC ethics officials will remain the primary government ethics advisors. MOU between the DAEO and HR to notify new employees for training and filing, new supervisors and terminations of OGE 278 and appointments of OGE 278. Also implemented a bi-weekly notices from HR to OGC regarding all new employees to ensure we catch all new filers and track all new training requirements. resulted in increasing staffing and resources across the ethics program
Methods for Assessing Risk to Inform Ethics Education & Communication Talked to employees about the ethics concerns they encounter in the workplace. 90 Talked to program managers about risks inherent in their work 59 Reviewed advice logs for common issues 73 Discussed upcoming work and agency priorities with senior staff 64 Conducted surveys to identify common and emerging ethics risks 15 Other 21 My agency did not assess risk 27 Number of Agencies
Methods for Evaluating Effectiveness of Ethics Education & Communication Discussions with within agency: does the training/communications support them in managing ethics risks 54 Reviewed advice logs for increased activity after training and communications 48 Post-training evaluations to assess participants' perceptions of the training 35 Self-assessments to ensure that required employees receive training 90 Other (please describe) 21 My agency did not evaluate the effectiveness of ethics education 32 0 10 20 30 40 50 60 70 80 90 100
Agenda Background Program Practices: how do other agencies assess and evaluate? Benchmarking: key compliance rates OGE consultation for agency-specific benchmarking
* The Questionnaire asks whether 278s were filed, but does not ask whether they were filed timely
* The Questionnaire asks whether 450s were filed, but does not ask whether they were filed timely
Agenda Background Program Practices: how do other agencies assess and evaluate? Benchmarking: key compliance rates OGE consultation for agency-specific benchmarking
Benchmarking what do you want to know? Percent of time A/DAEOs report spending on ethics? Staffing? Use of contractors? For similarly-sized agencies Frequency of waivers? Frequency of financial disclosure extensions, fee waivers? For agencies with similar missions (regulatory, financial, medical, etc.) SGE filing requirements? Something else?
OGE consultation on benchmarking What do you want to know? Wendy Pond Senior Desk Officer wgpond@oge.gov
