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.

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 1	Note: January 1, is the beginning of OGE Form 278e and OGE Form 450 CY reporting periods.	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. 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
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: 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-278e) 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-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	Track compliance with annual ethics training; send reminders, and involve supervisors as needed.	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

Updated: 1/16/20