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Pre-Employment Clearance for 278 Filer Positions

Procedure for Pre-Employment Ethics Orientation and Conflict of Interest Resolution for OGE-278 Filers

On October 1, 2004, the Secretary of the Department of Health and Human Services (HHS) distributed a memo emphasizing the importance of ethical conduct and integrity(pdf-icon.jpg,1 page) for all HHS employees. To further that effort, a memo establishing a new(pdf-icon.jpg,2 pages) requirement that candidates for positions subject to filing the Public Financial Disclosure Report (OGE-278)* must complete four steps prior to entering on duty. The selected individual must have:

  1. Filed a completed new entrant form OGE-278 with the HHS Office of the General Counsel, Ethics Division (OGC/ED);
  2. Executed an ethics agreement, where appropriate, that is satisfactory to the Designated Agency Ethics Official (DAEO), or his designee;
  3. Received an initial ethics orientation or similar briefing from the DAEO's office, in person, by telephone, or other means; and
  4. Received a final ethics clearance from the DAEO or his designee.

The following procedures and sample documents implement these requirements at the National Institutes of Health (NIH): (all documents are in Acrobat pdf format)

Documents Mentioned in the Above Procedures:

*Note that the memoranda uses the term "SF-278," which was changed to OGE-278 in 2011.

For assistance and additional information, contact your IC's Ethics Officials(pdf-icon.jpg,4 pages).