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(,1 page) for all HHS employees. To further that effort, a memo establishing a new(,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:
- Filed a completed new entrant form OGE-278 with the HHS Office of the General Counsel, Ethics Division (OGC/ED);
- Executed an ethics agreement, where appropriate, that is satisfactory to the Designated Agency Ethics Official (DAEO), or his designee;
- Received an initial ethics orientation or similar briefing from the DAEO's office, in person, by telephone, or other means; and
- 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)
- Clearance of Candidate Selected to Fill a Covered Position(,3 pages)
- Clearance of Current Employee Acting in the Position 14 Days or Less(,1 page)
- Clearance of Current Employee Acting in the Position More than 14 Days(,2 page)
Documents Mentioned in the Above Procedures:
- Conflicts of Interest Fact Sheet (Revised 9/05)(,2 pages).
- Sample Email Notification of Ethics Clearance(,1 page)
*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(,4 pages).