Ethics Due Dates

The following items are due each year, some on an exact date and other are ongoing activities with corresponding timeframes. 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.

IC Ethics Officials' Management Reports

OGE 2022 Important Ethics Dates 

HHS 2021 Ethics Calendar pdf-icon.jpg

Due Date

Item Due

Responsible Party

January 1

Note: January 1, is the beginning of OGE Form 278e and OGE Form 450 CY reporting periods.

Ethics Officials

January 10 Provide a list to NEO of all employees who have no completed the AET for the prior calendar year. NEO will submit the report to OGC by the established deadline. Ethics Officials
January 14 Complete updates to NEES filer status' in preparation for the OGE-450 Automated Reminder Notice (Dispatched from NEES to filers on January 15). 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. The 2802 must be signed by the DEC.
Note: If January 31 falls on a weekend or holiday, the report is due the next business day.

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-278e’s.

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

Employees who file the OGE-278e
Ethics Officials

November Initiate a supervisory review of OGE 450 filer lists and comprise all updates into a current OGE 450 filer list by December 31 each year.     Ethics Official
November Review IRB member roster (disseminated by NEO after receipt from OHSRP).  Update financial disclosure filing status and collect reports, as needed.

Ethics Official / NEO

December 31 Complete audit of OGE 450 filer lists to prepare for the upcoming OGE 450 filing cycle and ensure NEES filer status is accurate by January 14, prior to the NEES notice to filers. Ethics Officials

December 31 (approx.)

Ethics Program Questionnaire, submit to NEO.

Ethics Officials

December 31

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

All NIH Employees

December 31 Annual Agency Questionnaire (Annual Report of workload statistics). May be due in December; watch for notice. Ethics Officials

 

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-278e) are pre-cleared and submit their new entrant report prior to coming on board.)

Employees designated as New Entrant Confidential (OGE-450) filer.

Within 30 days of filer status change Collect HHS 717-1 reports from employees within 30 days of acquiring a SAO, becoming a new 278e or 450 filer, or new investigator role Ethics Officials
Ongoing Check EMIS bi-weekly View Alerts for onboarding staff and staff changes to ensure accurate employee data and identification of financial disclosure filers. Ethics Officials

Ongoing

Check recusal end dates. Ensure employees are aware of continuing recusals.

Ethics Officials

Ongoing

Review and certification of OGE-450s and OGE-278e’s (278e and 278T), to be completed within 60 days of receipt unless additional information is needed.

Ethics Officials

Ongoing

Late fee for any OGE-278e (278e and 278T) filers who submit their report more than 30 days after latest due date.

Employees designated as public (OGE-278e, or 278T) 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-278e) filers who meet certain criteria (make certain transactions) and submit their report late.

Ongoing Monthly OGE 278T and STOCK Act requirement reminders to OGE 278e filers on the 7th day of each month – OGE 278T reports due the 15th of each month. Ethics Officials

Ongoing

Track compliance with annual ethics training; send reminders, and involve supervisors as needed. 

Includes complete of AET upon return to work for employees who did not complete by the December 30 deadline due to extended leave, deployment, etc.

Ethics Officials

Ongoing

NEO specialists send monthly reminders to file OGE-278Ts to Top 5 OGE 278e filers on the 7th day of each month.

Ethics Officials