Ethics and Confidential Financial Disclosure for Special Government Employees

Ethics and Confidential Financial Disclosure for Special Government Employees 

Most members of Federal advisory committees are appointed as Special Government Employees (SGEs), and serve as Federal employees for up to 130 days in any given year. SGEs, like all Executive Branch employees, are subject to the Standards of Ethical Conduct issued under the Ethics Reform Act of 1989. The U.S. Office of Government Ethics (OGE) requires that members must receive Ethics Training each year, and must submit annual financial disclosure reports before they may meet to render advice or recommendations to the government. The intent of these requirements is to ensure that advice, guidance, and recommendations rendered by Federal advisory committees are free of actual and apparent conflicts of interest. Click here for a summary of the ethics rules that apply to SGE advisory committee members. 

CDC’s Committee Management Officer has day-to-day responsibility to oversee ethics-related activity for CDC’s advisory committee members, including the rigorous review and conflict of interest analysis process for advisory committee members’ financial disclosure reports. We are also responsible for providing initial and annual ethics training for SGE committee members. OGE has the authority and the responsibility to regulate ethics-related activity for the entire Executive Branch.    

Members of peer review committees (also known as initial review groups - IRGs) are not appointed as SGEs therefore are not subject to the same disclosure requirements. However, under HHS and CDC rules members of IRGs are required to disclose conflicts of interest, and to provide assurance that they are free of conflicts of interest, before they may participate at each peer review meeting. 

Some CDC employees who are fulltime Federal employees are also required to provide annual confidential financial disclosure, to ensure their personal financial interests and outside activities do not conflict with their official duties. CDC’s Ethics Program Office has responsibility for this requirement.

At our Laws & Regulations page we have provided a collection of the conflict of interest laws and regulations as well as links to access the forms required of SGEs.

The DHHS Office of the General Counsel is another useful source of information.