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Federal Ethics Programs: Government-wide Political Appointee Data and Some Ethics Oversight Procedures at Interior and SBA Could Be Improved

GAO-19-249 Published: Mar 14, 2019. Publicly Released: Mar 15, 2019.
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Fast Facts

Federal ethics programs seek to safeguard the integrity of governmental decision-making. That includes oversight of political appointees serving in the executive branch.

We reviewed information available on executive branch political appointees and examined 3 agencies' ethics programs. We found

There is no single source of publicly available, comprehensive, and timely data on appointees

2 of the 3 agencies we examined could strengthen their programs

We made recommendations to improve the ethics programs in 2 of the agencies we reviewed, and also asked Congress to consider requiring the collection and publishing of information on appointees.


A compass with the dial pointed toward the word "ethics"

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What GAO Found

There is no single source of data on political appointees serving in the executive branch that is publicly available, comprehensive, and timely. Political appointees make or advocate policy for a presidential administration or support those positions. The Office of Personnel Management (OPM) and two nongovernmental organizations collect, and in some cases, report data on political appointees, but the data are incomplete. For example, the data did not include information on political appointee positions within the Executive Office of the President. The White House Office of Presidential Personnel (PPO) maintains data but does not make them publicly available.

The public has an interest in knowing the political appointees serving and this information would facilitate congressional oversight and hold leaders accountable. As of March 2019, no agency in the federal government is required to publicly report comprehensive and timely data on political appointees serving in the executive branch. OPM is positioned to maintain and make political appointee data publicly available on a timely basis but is limited in its ability to provide comprehensive data. PPO has more comprehensive data but may not be positioned to publish data on a recurring basis. Ultimately, it is a policy decision as to which agency is best positioned to report comprehensive and timely data on political appointees.

All three agencies GAO reviewed generally used appropriate internal controls to ensure they met basic ethics program requirements, though two of the agencies could take actions to strengthen their ethics programs.

  • The Departments of Health and Human Services (HHS), and the Interior (Interior), and the Small Business Administration (SBA) all have procedures for administering their financial disclosure systems. HHS and Interior had procedures for providing initial ethics training as required beginning in January 2017. Prior to February 2019 SBA did not have written procedures for initial ethics training and did not adequately document political appointees' training dates. SBA's written procedures now reflect the requirements of initial ethics training and SBA developed a tracking sheet to indicate appointees completed training. GAO will assess the implementation of the tracking sheet to confirm the process is sufficient for documenting appointees' completion of initial ethics training.
  • Interior's ethics program has human capital and workforce continuity challenges. Interior reported that four out of 14 full-time positions were vacant. Interior officials attributed the vacancies to a recent transformation of the ethics program and prioritizing the staffing at individual bureaus such as the National Park Service. However, vacancies affected the ethics program's ability to properly document policies and procedures as well as file and review financial disclosure forms. According to Interior officials, steps are being taken to address vacancies and document policies and procedures. However, GAO found that a more strategic and documented approach would enable Interior to better manage human capital, fill key positions, and maintain institutional knowledge.

Why GAO Did This Study

Federal agencies' ethics programs seek to prevent conflicts of interest and safeguard the integrity of governmental decision-making.

GAO was asked to review compliance with ethics requirements for political appointees in the executive branch. This report examines the extent to which (1) existing data identify political appointees serving in the executive branch, and (2) selected agencies use internal controls to reasonably ensure that their ethics programs are designed and implemented to meet statutory and regulatory requirements.

GAO reviewed available data on political appointees. GAO also reviewed three case study agencies selected to provide a range in agency size and number of political appointees. GAO reviewed ethics documentation for a nongeneralizable sample of political appointees at the three agencies at any point between January 2017 and 2018 and interviewed officials from the agencies and two non-governmental organizations.


Congress should consider legislation requiring the publication of political appointees serving in the executive branch. GAO also recommends three actions: SBA should document that training was completed; Interior should conduct more strategic planning for its ethics workforce and document ethics program policies and procedures. SBA neither agreed nor disagreed with GAO's recommendation, but provided documentation that partially addresses the recommendation. Interior agreed with GAO's recommendations.

Matter for Congressional Consideration

Matter Status Comments
Congress should consider legislation requiring comprehensive and timely information on political appointees serving in the executive branch to be collected and made publicly accessible. (Matter for Consideration 1)
Closed – Implemented
On December 23, 2022, the president signed the Periodically Listing Updates to Management Act of 2022 (the PLUM Act of 2022) into law as part of H.R. 7776, the James M. Inhofe National Defense Authorization Act for Fiscal Year 2023. This law directs the Director of the Office of Personnel Management (OPM) to establish and maintain a public website containing information on each political appointee position in the federal government, including vacant positions. For each position, the law directs that the website include: the name of the individual occupying the position (if any); the name of the agency in which the position is located; and the level, grade, or rate of pay, among other information. The law requires executive branch agencies, including the Executive Office of the President, among other agencies to provide any information on political appointees that the Director of OPM determines necessary to establish and maintain the website. The head of each agency is required to provide updated information on the political appointee positions and the individuals occupying them on an annual basis. Establishing such a process for maintaining and publishing comprehensive data on political appointees on a recurring basis will promote transparency, facilitate congressional oversight, and hold leaders accountable.

Recommendations for Executive Action

Agency Affected Recommendation Status
Small Business Administration The Administrator of the Small Business Administration should implement procedures to track and verify that required employees complete initial ethics training and that completion of this training is documented. (Recommendation 1)
Closed – Implemented
In a letter dated December 2019 , SBA provided documentation that they implemented procedures in the form of a training log to track and document the training completion dates for 9 political appointees since February 2019 . Additionally, SBA provided signed pledges that they used to verify training completion. By developing and implementing a mechanism, such as the training log, SBA can have reasonable assurance that political appointees meet the requirement to take initial ethics training .
Department of the Interior The Secretary of the Interior should direct the Departmental Ethics Office, in conjunction with the Chief Human Capital Officer, to develop, document, and implement a strategic workforce planning process that aligns with its ongoing departmental reorganization and that is tailored to the specific needs of the ethics program. As part of this process, Interior should monitor and assess the critical skills and competencies that its ethics program needs presently and is projected to need in the future. (Recommendation 2)
Closed – Implemented
Interior's Departmental Ethics Office (DEO), in collaboration with the Office of the Solicitor and Chief Human Capital Officer, conducted a strategic workforce analysis to determine the proper level of resources necessary to support the ethics program's range of services, including: the provision of ethics advice and counsel services, the collection, review, and certification of financial disclosure reports, the delivery of ethics training and education, and other support. According to Interior officials, this analysis supported a proposed reorganization of the ethics program, as set forth in Secretarial Order 3375. In the fall of 2019, Interior consolidated all of its ethics functions and staff within the DEO and under the direction of Interior's Designated Agency Ethics Official. In addition, In November 2019, the DEO worked with human resources officials to recruit for additional full-time ethics officials, prioritizing those responsible for reviewing financial disclosures and providing training. As of February 2022, Interior reported it had also established standardized position descriptions and employee performance appraisal plans with defined duties and responsibilities, knowledge, and skill requirements. As a result, such information can help the agency continuously monitor and assess critical skills and competencies, as well as help the DEO with identifying and addressing skills gaps and critical needs now and in the future. Now that Interior has documented how it allocated and determined needed resources, it is better positioned to assess and strengthen its ethics workforce to achieve program goals and objectives.
Department of the Interior The Secretary of the Interior should ensure that the department's ethics program policies and procedures are documented and easily accessible to program staff. (Recommendation 3)
Closed – Implemented
In September 2019, Interior officials told us they began developing policies and procedures relevant to its ethics program. As of February 2022, Interior's Departmental Ethics Office (DEO) documented and issued standard operating procedures for the collection, review, and certification of financial disclosures and the provision of ethics training to employees, as well as other program and legal advisories. This information is made available to all employees on a shared drive and new policies and guidance are distributed by DEO senior leadership via an all employee email list. By completing the documentation of its ethics policies and procedures and making them accessible to staff, Interior now has reasonable assurance that institutional knowledge will be maintained, improving its ability to achieve the goals and objectives of the ethics program.

Full Report

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AccountabilityCompliance oversightConflict of interestsFinancial disclosureFreedom of informationGovernment employeesInternal controlsPersonnel managementPolitical appointeesHuman capital management