This final management advisory provides the results of the DoD Office of Inspector General’s review of the timeliness of public financial disclosure reports of senior DoD officials filed from January 1, 2022, through July 31, 2023. This is the first of two products that will be issued as part of the Audit of Senior DoD Officials Public Financial Disclosures that was announced on July 10, 2023. The objective of the audit is to determine whether public financial disclosure reports of senior DoD officials were submitted and reviewed in a timely manner, which is addressed in this management advisory.
Generally, senior DoD officials submitted, and DoD ethics officials reviewed, public financial disclosure reports in a timely manner for disclosure reports filed from January 1, 2022, through July 31, 2023. Of the five types of public financial disclosure reports, we found that the annual, termination, and combination annual/termination reports were generally timely, with submission and review timeliness rates above 90 percent. However, we found that senior DoD officials did not consistently submit the new entrant and periodic transaction reports in as timely a manner. In addition, DoD ethics officials generally reviewed the new entrant and periodic transaction reports in a timely manner.
The May 2024 update to the Joint Ethics Regulation (JER) established new requirements that should mitigate the timeliness concerns for new entrant reports. As discussed below, the updated JER expands the responsibilities that the directors of personnel offices have to support the ethics officials. The updated requirements in the JER should result in ethics officials being notified in a timely manner that a new entrant must file a new entrant report. In addition, ethics officials are proactively working with senior DoD officials to ensure that periodic transaction reports are submitted and reviewed in a timely manner by providing more training and guidance on when and what transactions must be reported. We will continue to monitor these developments and, therefore, do not make any recommendations in this management advisory.