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Financial Disclosure

This document provides general information about the financial disclosure reporting system. The HHS Office of the General Counsel, Ethics Division, distributes sample memos for distribution prior to each financial disclosure cycle.  Ethics staff may also request these documents from the NIH Ethics Office.

Types of Financial Disclosure
There are two types of financial disclosure reports, public (OGE-278) and confidential (OGE-450). As the names imply,  public financial disclosure reports may be released to the public. Confidential financial disclosure reports are not released to the public, but may be released to the Chair of congressional committees. (Note: Prior to January 2011, the OGE-278 was the SF-278.)
Who Must File
Public Financial Disclosure Report, OGE-278:  All SES, presidential appointees, Commissioned Corps O-7 and above, and special government employees whose annualized salary is more than 120% of Grade 15, Step 1, must file a Public Financial Disclosure Report.  By regulation, this includes those appointed under the ST and SL mechanisms.  Individuals appointed under the SBRS, Title 42 or equivalent mechanism, such as AD/EE, are excluded unless the individual serves in a position identified as equivalent to a public filer position.  Employees in these positions must file an OGE-278 regardless of their appointment mechanism.  See also NIH Manual Chapter 2300-735-1, Avoiding Conflicts of Interest, Appendix 2.

Confidential Financial Disclosure Report, OGE 450:  Confidential filers are determined by their official responsibilities. All Deputy Directors, Associate Directors, Division Directors, contract officers, program managers, and others in similar positions who make decisions affecting non-federal entities meet the criteria for filing the Confidential Financial Disclosure Report. Individuals appointed under the Title 42 or equivalent mechanism, such as AD/EE, whose responsibilities meet these criteria are also required to file.  See also NIH Manual Chapter 2300-735-1, Avoiding Conflicts of Interest, Appendix 3.

When Do I File?
Public financial disclosure reports are filed annually in May. New and terminating public filers also must file a new/termination report within 30 days of the action, unless they are already a filer.  Depending on the timing of your termination, you may be able to file a single combined report to meet the annual and termination requirements.  The period covered by the annual report is normally the previous calendar year up through the date you sign the report. Additional instructions will be distributed with the request for the report.

Confidential financial disclosure reports are filed annually in Febreuary. New employees in covered positions or employees who move into covered positions must file a new entrant report within 30 days of beginning the new position. If the employee filed the report in the previous position, he/she may not need to submit the new entrant report, depending on the timng of the change. Discuss with your ethics officials.

Who Distributes the Forms?
Paper forms are not distributed. NIH uses the NIH Enterprise Ethics System (NEES) to electronically submit and review financial disclosure reports, both OGE-278 and OGE-450. NEES is located at, accessible to NIH staff only.
Availability of Forms
Forms are available in various formats via the link from the NIH Ethics Program web site to the Office of Government Ethics web site.
Reviewing Financial Disclosure Reports
The following review guides published by the Office of Government Ethics are available from their web site.

Public Financial Disclosure: A Reviewer's Reference (2004) (pdf) - This is a reference manual for reviewers of the OGE Form 278. It contains an introduction to the public financial disclosure system, the procedures and mechanics of review and conflict resolution, summaries of applicable ethics laws and regulations, sample OGE-278 entries, model letters and documents related to the review process, and case studies.  This is a very large file; the document is about 275 pages.

OGE Form 450: A Review Guide (2008) (pdf)     - This is a reference guide designed for anyone who reviews the OGE Form 450 or administers agency confidential financial disclosure systems. The guide presents an overview of the confidential financial disclosure system and the specific requirements of the OGE Form 450. The guide includes appropriate reference materials and guidance on conducting effective reviews.

See also the Financial Research Tools on the "Links to Other Web Sites" for assistance with finding information about the various companies.

For additional information, contact your IC's Deputy Ethics Counselor or Ethics Coordinator.

Updated: 2/15/11