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United States Office of Government Ethics, Preventing Conflicts of Interest in the Executive Branch

Ethics Program Reviews

Ethics program reviews are OGE’s primary means of conducting systemic oversight of the executive branch ethics program. The Compliance Division’s Program Review Branch conducts ethics program reviews at each of the more than 130 executive branch agencies to ensure consistent and sustainable ethics program compliance with established executive branch ethics laws, regulations and policies and provide recommendations for meaningful program improvement. Individual reviews identify and report on the strengths and weaknesses of an agency’s ethics program by evaluating (1) agency compliance with ethics requirements as set forth in relevant laws, regulations, and policies and (2) ethics-related systems, processes, and procedures for administering the program. The Ethics in Government Act gives OGE the authority to evaluate the effectiveness of executive agency ethics programs. See title IV of the Ethics in Government Act, 5 U.S.C. app. § 402 and 5 C.F.R. part 2638.

OGE’s current plan calls for the Program Review Branch to conduct a review at each agency at least once every four years. Agencies are selected for review primarily based on this four-year plan. However, OGE may also review an agency’s ethics program if there is an indication that the program may have significant systemic deficiencies.

The Program Review Branch primarily conducts three types of reviews:

  • plenary reviews
  • inspections
  • follow-up reviews
A plenary review examines, in-depth, all elements of an agency’s ethics program and results in a written report providing a narrative description of the ethics program: how it is administered; what model practices are in place; and what deficiencies, if any, were found during the review. Reports also include recommendations directing the agency to correct any deficiencies that were not corrected prior to the conclusion of the review.

Inspections are a streamlined version of the plenary review and focus primarily on results. An inspection report indicates in a summary format whether an ethics program has substantially complied with certain core requirements. Inspection reports also provide brief narrative statements to justify findings of deficiencies, explain any apparent discrepancies and highlight model practices, as appropriate. Additionally, an inspection report, like a plenary review report, may include recommendations directing an agency to correct deficiencies. The results of an inspection may lead the Program Review Branch to conduct a more comprehensive plenary review of an ethics programs. This would occur if the findings of an inspection indicated the ethics program had deficiencies that could be more adequately addressed through a plenary review.

Follow-up reviews are conducted when a plenary review or inspection results in a recommendation. The follow-up report primarily focuses on determining if the agency took action to respond to the recommendation and whether that action was sufficient to resolve the underlying deficiency. However, if new deficiencies are identified during a follow-up review, additional recommendations will be issued and additional follow-up reviews will be conducted, as necessary.

Ethics program review reports are posted to OGE’s website here.

U.S. Office of Government Ethics (OGE) Sample Inspection Reportpdf
The format and criteria OGE uses to produce an Inspection Report.