Validating Interior’s Unprecedented Ethics Initiatives, Office of Government Ethics Program Review Contains Zero Findings or Recommendations

Last edited 02/15/2023

Date: Monday, Aug. 31, 2020

WASHINGTON – In stark contrast to the 14 recommendations issued in 2016 to the Department of the Interior, the U.S. Office of Government Ethics (OGE) issued no findings or recommendations for Interior’s ethics program. This is the first time in the Department’s history that it has received such a report after a Program Review by the OGE.

Since the day he arrived at Interior as the Deputy Secretary on August 1, 2017, now U.S. Secretary of the Interior David L. Bernhardt has been laser focused upon improving Interior’s ethics program, prioritizing and investing significant resources into the Departmental Ethics Office (DEO) to establish a culture of ethical compliance. This 2020 Ethics Program Review recognizes the progress of the Department’s transformational efforts.

Reform efforts started with elevating the position of the Designated Agency Ethics Official (DAEO) to report directly to the Solicitor, and with Secretary’s Order 3375, Improving the Department of the Interior’s Ethics Programs Through Consolidation, Interior increased the number of career ethics officials, restructured the ethics program by unifying 13 disparate Bureau programs into a centrally-managed office and streamlined the reporting structure for ethics personnel.

“We have great people at the Department of the Interior. They were let down by the unwillingness of the prior administration’s leadership to invest in the ethics program, which undermined public trust,” said Secretary Bernhardt. “Many dedicated employees of the Department have made incredible strides to improve our ethics program since I arrived.”

“The rotten stench from the blatant failure of the prior administration to invest in the ethics program has been replaced with a culture of ethical compliance. Our employees are now seeking and receiving ethics guidance. The fantastic results of OGE’s program review demonstrate the merits of our actions,” Secretary Bernhardt continued.

Heather Gottry, a career official with more than 20 years of legal and ethics experience, is serving as the Acting Director of the Departmental Ethics Office (DEO) and Designated Agency Ethics Official (DAEO) and oversees ethics operations for Interior. Immediately prior to joining the Department, Heather Gottry held senior ethics roles at the U.S. International Trade Commission and the U.S. Commodity Futures Trading Commission. From 2009 through 2012, she worked in the Office of White House Counsel as Associate Counsel to the President and as an ethics advisor. In her White House roles, she created highly regarded trainings for White House officials on a wide variety of ethics-related issues

“Secretary Bernhardt has instituted an unprecedented expansion and restructuring of the Departmental Ethics Office that supports the Department and its staff in building and maintaining public trust and confidence in the integrity of Interior’s operations” said Ms. Gottry. "Today’s report from the Office of Government Ethics recognizes the good work of dedicated career ethics officials as well as ethics program improvements that directly help Interior employees in carrying out their duties with the highest ethical standards.” 

Before the ethics program was restructured, the heads of each of the Department’s Bureaus and Offices, not the DAEO, operated 13 disparate ethics programs with varying staffing and operational standards. At times, some programs operated without any ethics officials in place at all. As recognized by the Office of Government Ethics, the new structure enhances the delivery of ethics services to employees; ensures that program operations are legally sufficient and compliant with ethics laws and regulations; and implements best practices.

As a direct result of Secretary Bernhardt’s leadership, the DEO successfully increased consistency in the standards and quality of ethics advice and counseling, financial disclosure reviews, identification of conflicts of interest and training and education provided to all Department employees; reduced unnecessary structural barriers, enhancing accountability and increasing compliance with ethics statutes and regulations; developed governmental ethics expertise among ethics personnel; and enhanced the independence of ethics officials and the ethics program.

Notable achievements include:

  • Increasing the number of full-time ethics professionals by an unprecedented 250 percent since April of 2018, now having 74 officials in place with additional staff anticipated to join by 2021;
  • Internally restructuring the DEO leadership and using data and metrics to hold the ethics program accountable for results;
  • Focusing on building an ethics community of practice with internal policies, including formal designations, program advisories, legal advisories, standard operating procedures, onboarding process for ethics officials and internal training opportunities;
  • Positioning nearly half of all ethics officials in 14 states outside of the Washington, D.C. metro area, where a majority of Interior employees are located, in order to provide better and more direct ethics services;
  • Deploying new modes of employee engagement, including updates to the DEO ethics page, DOI Ethics Mobile Application and web-based training modules;
  • Updating interactive ethics forms and supporting materials for common ethics requests;
  • Conducting pre-employment ethics reviews for senior career and political appointees; and
  • Improving regulatory compliance rates and addressing oversight concerns.

The OGE reviews cabinet-level agencies’ ethics programs every four years and has only issued a report with zero recommendation one time in the past decade. The OGE’s 2016 Ethics Program Review for Interior highlighted that some politically appointed employees:

  • didn’t submit financial disclosure reports;
  • provided new entrant reports in some cases up to almost a year after the filing deadline; and
  • didn’t receive ethics training of any kind, or if they did, it didn’t cover the required content.

Other notable recommendations included the need to provide annual ethics training to covered employees; improve the filing timeliness of new entrant and termination public financial disclosure reports; develop concrete measures to improve the DEO’s coordination with HR offices; and destroy reports that exceed the retention period.

The 2020 OGE Ethics Program Review is available online.

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