Justification for a Nonsubstantive Change--OGE 278e

U. S. OFFICE OF GOVERNMENT ETHICS
JUSTIFICATION FOR A NONMATERIAL/NONSUBSTANTIVE CHANGE
OGE FORM 278E EXECUTIVE BRANCH PERSONNEL
PUBLIC FINANCIAL DISCLOSURE REPORT
MAY 2020

In November 2019, the Office of Management and Budget reviewed and
approved a three-year extension under the Paperwork Reduction Act of the OGE Form
278e Executive Branch Personnel Public Financial Disclosure Report. OGE will be
issuing final rule amendments soon that revise the executive branch financial disclosure
regulation at 5 C.F.R. §§ 2634.304 and 2634.907(g) to reflect the retroactive increase,
applicable as of January 1, 2020, of the threshold for reporting of gifts, reimbursements
and travel expenses for both the public and confidential report systems. The Ethics in
Government Act and OGE regulations tie these increases to the increase in March 2020
by the General Services Administration of “minimal value” for purposes of the Foreign
Gifts and Decorations Act to $415 for the three-year period 2020-2022. See GSA, FMR
B-50, Foreign Gift and Decoration Minimal Value (2020). The new aggregation
threshold for the reporting of gifts and reimbursements received from any one source on
financial disclosure reports is “more than $415”; items worth “$166 or less” do not need
to be counted towards that overall threshold.
These reporting threshold values are indicated on the OGE Form 278e in the
instructions to Part 9: Gifts and Travel Reimbursements. OGE proposes to update these
threshold values from “$156” and “$390” to “$166” and “$415,” respectively. These
changes to the OGE Form 278e have no material effect on the burden to filers; rather, the
changes simply update the form, including in Integrity, to provide the correct information
to filers regarding the currently-applicable aggregation threshold for reporting gifts and
travel reimbursements. OGE also proposes minor typological corrections in the
instructions to Part 2 and Part 7, adding the word “as” on page 3 and the word “the” on
page 8 and page 22 of the Excel version of the form.