Ethics Due Dates

The following items are due each year, some on the exact date, others at approximately the same time. The third column indicates who or which office responds/submits the final product. See the "Responsible Party" column for who is responsible for that item. See bottom list for activities occurring on an ongoing basis without an exact due date. See also, the OGE schedule of important due dates (OGE website) and the 2014 Ethics Calendar (HHS intranet).

IC Ethics Officials' Management Reports

Due Date Item Due Responsible Party
1st week January Annual Agency Questionnaire (Annual Report of workload statistics). May be due in December; watch for notice. Ethics Officials
January 15

Initiate Confidential Financial Disclosure Report (OGE-450) cycle. Reporting period for incumbent (annual) filers: previous calendar year.

NEES notice sent to each employee designated as OGE-450 incumbent filer who has not already submitted his or her report. If January 15 falls on weekend or holiday, notice goes out on prior business day.

Ethics Officials
January 31

Initiate Annual Report of Outside Activity (HHS-521) cycle. Covers all employees who had an approved outside activity during any portion of previous calendar year, and all employees who engaged in an outside activity for which they should have received prior approval.

NEES notice sent to each employee with approved outside activity (HHS-520) which covered any portion of prior calendar year, i.e., ends in the covered calendar year, regardless of when it was approved. If January 31 falls on weekend or holiday, notice goes out on prior business day.

Ethics Officials
January 31 NIH-2802 Annual Report of Employee Referrals (Summary of Form NIH-2850) due. Submit completed NIH-2802 report and copy of each referral to NEO. NIH-2802 can be produced in EMIS. Ethics Officials
February 15 OGE-450 due, unless an extension is granted. If February 15 falls on a weekend or holiday, the report is due on the next business day.

Submit the OGE-450 using the NIH Enterprise Ethics System (NEES) at https://nees.nih.gov/.

Employees who file the OGE-450

Ethics Officials

February 28 HHS-521 Annual Report of Outside Activity due, unless an extension is granted. If February 28 falls on a weekend or holiday, the report is due on the next business day.

Submit the HHS-521 using the NIH Enterprise Ethics System (NEES) at https://nees.nih.gov/.

Ethics officials are encouraged to review and certify HHS-521s in concert with the review and certification of OGE-450s and OGE-278s.

Employees who engaged in an Outside Activity, with or without advance approval, during the previous calendar year

Ethics Officials

April 15

Initiate Public Financial Disclosure Report (OGE-278) Cycle. Reporting Period for incumbent (annual) filers: Predominantly the previous calendar year, with additional covered time for some sections, e.g., outside positions.

NEES notice sent to each employee designated as OGE-278 incumbent filer who has not already submitted his or her report. If April 15 falls on weekend or holiday, notice goes out on prior business day.

Ethics Officials
May 15 OGE-278 due, unless extension granted. If May 15 falls on a weekend or holiday, the report is due on the next business day.

Submit the OGE-278 using the NIH Enterprise Ethics System (NEES) at https://nees.nih.gov/.

Employees who file the OGE-278

Ethics Officials

December 31st

Submit all certified OGE-278 reports to OGC via email at ethics.financialdisclosure@hhs.gov.. Ensure all applicable attachments are included with each report.

Ethics Officials
December 31st (approx) Ethics Program Questionnaire, submit to NEO. Ethics Officials
December 31st

Annual Ethics Training must be completed. Visit the training page for more details: http://ethics.od.nih.gov/training.htm

All NIH Employees

Ongoing Activities

Due Date Item Due Responsible Party
90 days after starting work at NIH New Employee Ethics Orientation. See web page. All employees new to NIH.
Ethics officials will track and remind employees.
30 days after starting work in covered position Employees designated as confidential filers (file the OGE-450). Ethics officials will inform the employees subject to the requirement. (New public filers (OGE-278) are pre-cleared and submit their new entrant report prior to coming on board.) Employees designated as New Entrant Confidential (OGE-450) filer.
Ongoing Check recusal end dates. Ensure employees are aware of continuing recusals. Ethics Officials
Ongoing Review and certification of OGE-450s and OGE-278s, to be completed within 60 days of receipt unless additional information is needed. Ethics Officials
Ongoing Late fee for any OGE-278 filers who submit their report more than 30 days after latest due date. Employees designated as public (OGE-278) filers who submit their report late.
Ongoing Late fee for any OGE-278T filers who submit their report more than 30 days after latest due date. (OGE-278T's are due on or before the 15th of every month in which a reportable transaction occurs) Employees designated as public (OGE-278) filers who meet certain criteria (make certain transactions) and submit their report late.
Ongoing Track compliance with annual ethics training; send reminders, and involve supervisors as needed. Ethics Officials
 

Updated: 2/3/14