Individuals in certain pay plans or positions are required by the Ethics in Government Act (EIGA), as amended, to file a Public Financial Disclosure Report (OGE-278e) within 30 days of entering the covered position, annually thereafter, and within 30 days of terminating from a covered position. There are some exceptions, and there are occasions when one report fulfills both requirements. Individuals required to file this report include those in SES; ST or SL paid above a specified salary level; Commissioned Officers at or above the O-7 rank; the six NIH level Deputy Directors; all IC Directors; Deputy Directors; Clinical Directors; Scientific Directors; and the Extramural Program Officials who report to their IC Director. Your IC Ethics Officials will provide instructions for completing the report to the appropriate individuals when reports are required.
Form number revisions:
Changed from OGE-278 to OGE-278e (January 2016). Current Version.
Changed from SF-278 to OGE-278 (January 2011).
All Filers: NIH employees should use the NIH Enterprise Ethics System (NEES) to enter their financial data for their Public Financial Disclosure Report (OGE-278e) and Periodic Transaction Report (OGE 278-T). Information and instructions for using NEES are available in the NEES Employee/Filer User Manual.
Incumbent Employees: You may create your annual (incumbent) report after January 1st in the year you will file and begin working on it, before the notice is sent.
New Employees: All individuals new to a public filer position must be cleared prior to entering on duty into the position. This usually requires submission of a draft New Entrant report fairly quickly. See the NIH Pre-Clearance policy and procedures. Candidates may need to submit a paper report. Links to the paper copy of the form are below.
Terminating Employees: All current OGE-278e filers exiting service with NIH are required to file a Termination OGE-278e within 30 days of leaving service. To make this more manageable for the employees they may submit their OGE-278e up to 15 days prior to termination. Employees will then be required to verify their report or provide updated changes to their IC Ethics Specialist between their last day of service and 30 days after termination. This verification may be provided via email to the Ethics Specialist.
OGE Program Advisory PA-16-06 
(9/22/2016): Acceptance Date for Termination Filings,
Resources for Employees Required to File the OGE-278e and OGE 278-T
Public Financial Disclosure Guide: OGE web-based guidance for completing the Public Financial Disclosure Report (OGE Form 278e) and the supplemental Periodic Transaction Report (OGE Form 278-T).
Public Financial Disclosure Report (OGE-278e)
NIH policy indicates that financial disclosure reports should be submitted electronically via the NIH Enterprise Ethics System (NEES).
It may be helpful for filers to have a copy of the form and detailed instructions. You may wish to print or view the form or instructions, to see what the final report looks like or to guide you through data entry in NEES, as noted above. The paper form may need to be used for pre-employment draft reports. The form is available on the Office of Government Ethics website via this link: OGE-278e form
Public Financial Disclosure Periodic Transaction Report (OGE-278-T)
NIH policy indicates that financial disclosure reports should be submitted electronically via the NIH Enterprise Ethics System (NEES).
The STOCK Act, enacted on April 4, 2012, mandates additional requirements for the OGE-278e Public Financial Disclosure Report filers, i.e., filers must report certain transactions and filers must submit a written recusal for negotiating future employment (see the Forms page). Additional information about the STOCK Act is available on the STOCK Act page.
Resources for Ethics Officials
See Resources for Managing a Financial Disclosure System, on the Financial Disclosure Page, and OGE's Resources for Financial Disclosure Filers.
OGE-278e Checklist: HHS provided checklist for processing the OGE-278e
The STOCK Act, enacted on April 4, 2012, mandates additional requirements for ethics officials and for OGE-278e Public Financial Disclosure Report filers, e.g., reporting certain transactions, and written recusal for negotiating a new position. The Office of Government Ethics (OGE) has issued multiple legal advisories to assist filers and ethics officials. See the list on the STOCK ACT web page for the explanatory memos and new forms, where applicable.
Public Financial Disclosure Reviewer's Guide (OGE, 2019) (OGE website)
HHS DAEO Instruction 20-4, 6/16/2020: Public Financial Disclosure System Procedures for the Department of Health and Human Services (HHS web site, HHS Access only)
HHS Late Fee Assessment Procedure for OGE-278 Filers The link goes to the first page of the Instruction.
Delegation of Authority
Each Deputy Ethics Counselor has the authority to receive and review Public Financial Disclosure Reports (OGE-278e) and the Periodic Transaction Reports (OGE-278-T) for employees within their respective areas of responsibility and to certify the reports. The authority to certify OGE-278e reports may not be redelegated, including New Entrant, Annual, Termination, and Combination reports.
However, certification of the OGE-278-T may be redelegated to individuals who are knowledgeable and at a high enough level within the organization to be consistent with good management of this authority and to maintain program integrity, e.g., an experienced Ethics Specialist or Ethics Coordinator. All redelegations must be in writing, and a copy sent to the NIH Ethics Office.
Updated: 1/27/2023