OGE Form 278e Excel

JUSTIFICATION FOR NO MATERIAL/NON-SUBSTANTIVE
CHANGE
EXECUTIVE BRANCH PERSONNEL PUBLIC FINANCIAL
DISCLOSURE REPORT [OGE FORM 278]

In early 2014, OIRA/OMB reviewed and approved a three-year extension under the Paperwork
Reduction Act covering the new OGE Form 278e to be incorporated in the new Integrity e-filing
application, as well as the existing OGE Form 278 PDF and 278 Excel spreadsheet versions.
The most significant difference between the 278 PDF and 278 Excel versions is that the 278e is a
streamlined, rendered report format that presents only the filer’s data inputs in a given category,
eliminating categories not applicable to the specific filer. Otherwise all three approved versions
collect the same information and are similar in burden requirements. In anticipation of the
launch of the Integrity e-filing application, OGE recently created a new, “standalone” Excel
version of the 278 form that closely resembles the 278e rendered format. OGE proposes to
introduce the 278e Excel version as soon as possible and shortly thereafter, to phase out the 278
PDF and 278 Excel versions.
OGE is proposing to do this primarily because of a desire for uniformity. In addition, OGE
hopes that the new format will reduce confusion regarding the various versions of the form for
ethics officials reviewing public financial disclosure reports, for Senate Committees considering
PAS nominees, for filers preparing and submitting their own financial disclosure reports, and for
members of the public requesting access to financial reports.