November 3, 2022
From: Chip Christopher, Deputy Director of Compliance
OGE’s mission is one of prevention. That doesn’t mean that OGE does not act when it becomes aware of potential ethics risks in executive branch agencies. OGE can become aware of such risks in many ways; sometimes non-profit organizations or the media highlight potential problems. Congress also can make OGE aware that there may be ethics concerns in an agency. Agencies themselves sometimes notify OGE of risks within their own organization.
OGE has always seriously considered and acted upon information that reveals potential ethics risk but, in our new Strategic Plan, we decided to formalize this process in a written policy. Now, when OGE is made aware of an ethics risk, the policy sets a course of action. In this note, we’d like to share with you a summary of that policy.
First, upon being made aware of a potential risk, the appropriate OGE leader must document it in an internal database. Second, the official logging the risk must promptly convene a meeting with other appropriate OGE leadership, where they discuss the nature of the risk, the history of interactions with the agency in question, and the source of the information about the risk. At the end of the meeting, OGE leadership must decide if intervention is necessary and, if so, assign an action officer to carry out that intervention. Finally, whether the meeting results in a decision to intervene or not, the conclusions of the meeting and a summary of factors considered are added to the tracking database.
It is always better to address potential risks early, before there is a serious problem. Even though this will be an internal process, OGE’s new procedure for analyzing and acting upon risks will help protect government integrity and promote public confidence. Moreover, the tracking database will help OGE see trends and patterns. And hopefully, those patterns will help OGE to create better ethics policy and conduct more effective oversight.
Protecting the integrity of government work is a complex job. OGE’s newly formalized commitment to analyzing and mitigating risk is sure to help.
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