Updated SGE Training Materials

Updated September 2, 2008 to correct web links changed during OGE web site upgrade:

Wayne Johnson thoughtfully provided an updated version of his materials for SGE training. Wayne explains:

I have replaced the previously attached files with Internet web links that everyone should be able to use/access.  The other difference is that this template, in addition to covering IEO or AET for an SGE, also sends them the links to complete their OGE 450 form and the HHS Foreign Activities Questionnaire Form.  It of course could be edited down by a user to just cover training or collecting forms.  Although some materials are HHS specific, they could be easily copied and edited for use by another federal agency. 

Other material from Wayne is available in our November 9, 2007 posting. Thanks to Wayne for sharing these useful training documents.

The below EMAIL TEMPLATE is an IEO and AET email for ethics officials to send to committee SGEs.   It was originally created by Wayne L. Johnson to help HHS Division Ethics Officials to train their SGEs in advance of attending committee meetings using only Internet links. 

(Revised August 29, 2008 to replace earlier version on IEC web site due to OGE creating new OGE web site and ethics topic links in August 2008)

Text for Email/Letter for Advisory Committee SGEs for IEO and/or AET AND OGE 450 and HHS 697 Filing Using Internet Web Links:

INTRODUCTION: THE INFORMATION IN THIS EMAIL/LETTER TEMPLATE IS INTENDED TO PROVIDE SPECIAL GOVERNMENT EMPLOYEES (SGEs) ON FEDERAL ADVISORY COMMMITTEES OF THE DEPARTMENT OF HEALTH AND HUMAN SERVICES (HHS) THEIR INITIAL ETHICS ORIENTATION (IEO) OR ANNUAL ETHICS TRAINING (AET).  IT MAY ALSO BE USED TO OBTAIN FROM THE SGE THEIR OGE 450 FORM AND HHS FOREIGN ACTIVITIES QUESTIONNAIRE (HHS FORM 697).  IT ONLY USES INTERNET LINKS SINCE SGEs ON ADVISORY COMMITTEES DO NOT HAVE ACCESS TO THE HHS INTRANET UNLESS THEY ARE AT AN HHS FACILITY.  MOST COMMITTEE SGEs PERFORM THEIR DUTIES LESS THAT 30 DAYS A YEAR. MATERIAL HEREIN THAT IS HHS SPECIFIC SHOULD BE REVIEWED FOR APPLICABILITY AT OTHER AGENCIES.  FEEL FREE TO DELETE HHS SPECIFIC ITEMS OR REPLACE WITH ITEMS THAT ARE MORE SPECIFIC TO YOUR AGENCY.  

(The term SGE includes members of Federal Advisory Committees and Intermittent Workers.  An SGE is defined as an “officer or employee... who is retained, designated, appointed, or employed” by the Government to perform temporary duties, with or without compensation, for not more than 130 days during any period of 365 consecutive days.  See Title 18, U.S. Code, Section 202(a).)

OGE 450 and HHS 697 Forms Section:

As an Special Government Employee (SGE) on the (Name of FACA Committee) you must file with my office a “New Entrant” OGE Form 450, Confidential Financial Disclosure Form, (Revised January 2007) and an HHS 697 Foreign Activities Questionnaire, within 30 days of your appointment as an SGE as well as annually.  Even if you have been board member for more than a year on the same committee, your OGE Form is always a New Entrant. 

The two forms are available on the INTERNET as follows:  OGE 450 Form, http://www.oge.gov/forms/form_450.aspx?AspxAutoDetectCookieSupport=1 or http://www.usoge.gov/forms/form_450.aspx and HHS 697 Form, http://ethics.od.nih.gov/forms/hhs-697.pdf.  You should save these forms to your computer and then fill them out.  That way you can update them next year rather than start from scratch. 

After completing the two forms please sign and date them and mail them to my attention at the below address no later than (date).

Initial Ethics Orientation (IEO) and Annual Ethics Training (AET) Section

As an SGE with Department of Health and Human Services (HHS), the Ethics in Government Act, at 5 CFR Sections 2638.703, .704 and .705, requires HHS to provide Initial Ethics Orientation (IEO) and Annual Ethics Training (AET) to you and for you as an SGE to spend one hour reviewing the material provided below. You are authorized to use official duty time to accomplish this. (If this information is being done by letter, provide the SGE with paper copies of these items or make sure the Internet links are written out.) 

The below three items and their web links apply specifically to SGEs (including advisory committee members and intermittent employees).  In addition to reviewing them for at least one hour, please save this email and the first three items to your computer or print them off for future reference. 

1.  HHS OGC Ethics Division October 2004 Memo for SGEs - "Ethics Rules for Advisory Committee Members and Other Individuals Appointed as Special Government Employees" http://www1.od.nih.gov/cmo/ethics/SGETRAININGOCT2004.pdf

2.  HHS OGC Ethics Division 2005 Pamphlet for SGEs - “Overview of the Ethics Rules for Special Government Employees Serving on Advisory Committees" http://www1.od.nih.gov/cmo/ethics/SGE3.pdf. 

3.  Office of Government Ethics (OGE) 2008 Booklet –To Serve With Honor: A Guide on the Ethics Rules that Apply to Advisory Committee Members Serving as Special Government Employees (2008)

(PDF) http://www.usoge.gov/training/training_materials/booklets/bkServeHonor.pdf or

(TEXT) http://www.usoge.gov/training/training_materials/booklets/bkServeHonor.txt 

This booklet highlights some of the ethics rules that are most likely to affect these committee members, in addition to providing them with a game plan of eight general principles that will help promote peak ethical performance.

NOTE: IN LIEU OF, OR IN ADDITION TO, ETHICS OFFICIALS MAY USE THIS TRAINING MODULE FOR SGE AET/IEO

OGE 2007 Online Training Module
Ethics Training for Special Government Employees WBT (2007)

An interactive web-based training module designed to be completed in about one hour and is intended for use by Special Government Employees (SGEs). The course contains a summary of ethics laws and rules that apply to SGEs and may be used as part of your initial or annual ethics training program. (Begin Module) http://www.usoge.gov/training/module_files/ogesge_wbt_07/10.html 

PRIMARY ETHICS MATERIALS

In addition to the above items, you can access the primary ethics regulations upon which they are based by going to the following web links on the Internet.  

1. The Standards of Ethical Conduct: 

http://www.usoge.gov/laws_regs/regulations/5cfr2635.aspx or http://www.usoge.gov/ethics_docs/publications/reference_publications/rfsoc_02.pdf or http://www.usoge.gov/ethics_docs/publications/reference_publications.aspx 

2.  The full HHS Supplemental Ethics Regulations (As of August 2005) Note 5 CFR Section 5501 subsections .104, .106, .109, .110, .111 and .112 and 5 CFR 5502 do NOT apply to SGEs:   http://www.fda.gov/opacom/ethics/5CFR5501-5502compilation.pdf or http://www.access.gpo.gov/nara/cfr/waisidx_08/5cfr5501_08.html and http://www.access.gpo.gov/nara/cfr/waisidx_08/5cfr5502_08.html . Other Federal Agencies that have supplemental ethics regulations can obtain for their’s at http://www.usoge.gov/laws_regs/agency_supp_standards.aspx .

3.  Roster of Department of Health and Human Services (HHS) Ethics Officials:  http://www.hhs.gov/ogc/hhsethics/contacts.html or http://www.hhs.gov/ogc/contact/contacts.html .  If you have any questions about the ethics materials use this roster to find the appropriate ethics official to contact for assistance. 

4.  The 14 Principles of Ethical Conduct [Codified at 5 CFR Section 2635.101(b)]:   http://www.usoge.gov/ethics_guidance/daeograms/dgr_files/2001/do01004a.pdf  or http://www.usda-ethics.net/science/training/14PRINC.DOC  or http://www.usoge.gov/laws_regs/exec_orders/eo12731.aspx  or http://www.usda-ethics.net/rules/rule2.htm 

5. The Federal Conflict of Interest Statutes:  http://www4.law.cornell.edu/uscode/18/usc_sup_01_18_10_I_20_11.html and http://www.fda.gov/opacom/ethics/criminaldig.html 

6. HHS Residual Standards of Conduct: http://ethics.od.nih.gov/lawreg/hhs-resid-std.htm.

If you have any questions regarding the above, please contact me.

(Here provide the name and contact information of the sender which is usually the Deputy Ethics Counselor, Ethics Coordinator, or the Committee Management Officer.)