The Business of Government Hour


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The Business of Government Hour features a conversation about management with a government executive who is changing the way government does business. The executives discuss their careers and the management challenges facing their organizations. Past government executives include Administrators, Chief Financial Officers, Chief Information Officers, Chief Operating Officers, Commissioners, Controllers, Directors, and Undersecretaries.

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Join the IBM Center for a weekly conversation about management with a government executive who is changing the way government does business.

Amy Comstock interview

Friday, November 9th, 2001 - 20:00
Amy Comstock
Radio show date: 
Sat, 11/10/2001
Intro text: 
Amy Comstock
Complete transcript: 

Washington, D.C.

Wednesday, August 22, 2001

MR. LAWRENCE: Welcome to The Business of Government Hour. I'm Paul Lawrence, a partner at PricewaterhouseCoopers and the co-chair of The Endowment for The Business of Government. We created The Endowment in 1998 to encourage discussion and research into new approaches to improving government effectiveness. To find out more about the Endowment, visit us on the Web at

The Business of Government Hour features a conversation about management with a government executive who is changing the way government does business. Our conversation today is with Amy Comstock, Director of the Office of Government Ethics.

Good morning, Amy.

MS. COMSTOCK: Good morning.

MR. LAWRENCE: Well, let's start by finding out something about the Office of Government Ethics. Could you tell us about its history and its activities?

MS. COMSTOCK: The Office of Government Ethics was created in 1978 as part of the Ethics in Government Act, under the leadership of President Carter, actually. It was created in the wake of the declining trust in government, following Watergate. There was, obviously, a lot of responses to that scandal and one of the concerns was that the public had lost its trust in government and also, needed a little more ability to assess for itself the integrity and impartiality of government officials.

So the Office of Government Ethics was created, as I said, in 1978. At that time it was part of the Office of Personnel Management, OPM. In 1989, the Office of Government Ethics, which I will refer to as OGE, was made a separate agency and it has been a separate agency since.

We are a nonpartisan agency. I am a presidential appointee, but I have a term appointment, so that my position doesn't change as a result of the recent election, for example.

Our mission is to oversee ethics programs for the entire Executive Branch. We establish the policies and regulations governing conflicts of interest and other ethics matters for all Executive Branch employees. We, as we'll discuss in more detail later, we work directly with each of the departments and agencies in the Executive Branch to ensure that their ethics programs are functioning properly.

So, that's a quick thumbnail sketch of what we do.

MR. LAWRENCE: Well, one of the questions I have is does OGE have enforcement responsibility?

MS. COMSTOCK: Well, we're responsible for overseeing the ethics programs, but if we determine that they're -- or an agency ethics official determines that there is a problem or a question with one of the employees in their agencies, we generally rely on the Inspector Generals for investigation. And, then, if there's still determined to be a problem, the matter would be referred to the Department of Justice for prosecution.

So we do not consider ourselves an enforcement agency, although we are responsible for ensuring the integrity of the programs and if we need to, we will then refer and rely on other agencies for the enforcement actions.

MR. LAWRENCE: How big is OGE and what type of employees work there?

MS. COMSTOCK: OGE is 82 full-time employees. So we're actually, as government goes, pretty small. And we have a very specialized skill. We have a very strong staff of, oh, maybe 20 lawyers and a strong number of maybe 50 government ethics experts. Because what our field, our function is fairly unique to the federal government, we have people who are trained on the job and come and learn about government ethics.

We have -- I'm happy to say, we have a lot of long-time employees who really enjoy the work they do and feel strongly about our mission. And that's really good, given the fact that the skills that we need for our job are really unique to OGE and people learn it on the job.

MR. LAWRENCE: And then what's the relationship between OGE and the other organizations that are also working with ethics? How do you all work with the departments?

MS. COMSTOCK: Well, we're the only agency that does government ethics, as defined by the federal government. But ethics officials in agencies often are also responsible for giving advice on matters such as political activities, discrimination issues. Those are handled by other agencies. Political activities, the Hatch Act, are covered by the Office of Special Counsel; EEOC, Equal Employment Opportunity Commission, deals with discrimination matters. Obviously, as I indicated, the Department of Justice prosecutes; Inspectors General investigate matters.

So, our jurisdiction relates, if you will, but our jurisdiction is only on what are considered absolutely ethics conflict-of-interest matters.

MR. LAWRENCE: Well, let's spend some time talking about your career. Could you tell us about your career and how you got here?

MS. COMSTOCK: After graduating from law school, I went to a private law firm in Washington and, to be quite frank with you, I just decided that that was not going to be for me. It did �

MR. LAWRENCE: How long did that take?

MS. COMSTOCK: About two years. Actually, I decided right away, but I didn't leave for two years. I just decided that the private law-firm mission was not going to be mine. And started looking into the government and, actually, had always been interested in teaching. And saw an attorney position open up at the Department of Education and thought, well, that might be a good compromise; kind of combine my interests. And I applied there and started working there in 1988. I worked in the field of special education as a staff attorney for a couple of years and that was a fascinating job.

But then moved on from there and started -- became the executive assistant to the general counsel, which is where I was first exposed to government ethics issues. And I think that was in 1990. And I moved on from there and became the assistant -- at the Department of Education, assistant general counsel for ethics, I think in 1993. And I oversaw the ethics program at the Department of Education until 1998.

At which time, I went on detail, which I can explain in a minute, to the White House to oversee the ethics program there for about 15 months. On detail meant, I went as a career employee; I didn't become a political in the Clinton Administration, although I was working in the White House.

It was during that 15-month period that I was nominated to be the head of the Office of Government Ethics. And my -- I was confirmed in 2000.

MR. LAWRENCE: Which of the positions that you described gave you the best preparation for your work now? I mean it seemed as though each one of those was a function where you didn't have a lot of management responsibility and now, you have a great deal. How did -- or did I not hear the descriptions correctly?

MS. COMSTOCK: No, in the education, as the assistant general counsel, I was head of the ethics division, so there was a fair amount of management and responsibility there. And in both agencies, Education and the White House, I oversaw the ethics programs, so there certainly was a lot of management responsibility in that perspective.

Both of them were excellent training for the work that we do from the perspective that the ethics program, and we'll talk about the details of what it encompasses in a bit. But the ethics program is actually something that has a huge impact on the lives -- can have a huge impact on the lives of Executive Branch employees.

The areas that we oversee are, in fact, the areas where someone's job and their personal life may overlap. And that's pretty serious business. You're talking about affecting someone very personally. The experience that I had in running the ethics programs at Education and the White House, the experience of having to train employees, having to counsel employees, having to sit with employees when you're telling them they simply can't do -- either in their jobs or in their personal lives -- that which they very strongly want to do -- that's a hard thing to do.

I think it was important for me to be able to bring that kind of experience to OGE. I am, actually, the first director of OGE to come from the ethics community as someone who has run programs working directly with the employees we work with. Again, OGE basically has an oversight function. So I think it was good for me to be -- I know -- it's important for me to be able to bring to that job the perspective of the person who has to deal directly with the unhappy employee or the frustrated employee. And that kind of customer orientation is something I've been able to instill in OGE, since I've been there.

MR. LAWRENCE: Well, I'm curious. What was the most effective tool in those conversations, because without enforcement ability, I guess, you're left with education to explain why they can't do these things? But at some point, obstinate people probably didn't listen.

MS. COMSTOCK: Well, I have to say; I've been pretty lucky. I mean, each of our -- we should always try and run a prevention program and so we do try, and it's very important, to educate people why the answer is either no that you can't do that or, if you're going to do it, you know, you must do it the following ways.

But I've been very lucky that I haven't run into too many obstinate people. I mean the fact is that the rules and regulations and the laws that we implement are all designed to ensure impartiality and integrity in decision-making by government officials. But behind all those rules, obviously, there are regulations that you cannot violate and criminal statutes. So, while I may never have been able to personally have the enforcement, I mean, the fact is if you're sitting across from someone and you say, you cannot do that; that is criminal. It generally works.

MR. LAWRENCE: Well, you've had a chance to be around some leaders in, I guess, a unique perspective. What qualities have you observed are crucial to be a good leader?

MS. COMSTOCK: There are a number of qualities that are important for leadership. One is, obviously, honesty and to try and actually be the kind of person you would want to have as your most trusted adviser, someone who's honest, someone who's up-front, someone who will always be open-minded and fair. And I think those qualities are infectious in terms of the people you work with directly, either on my own staff or on the clients that I serve.

I also think, as a leader of an agency, that has such a broad impact on the entire Executive Branch, it's extremely important for me to be able to instill a sense of mission in my own staff and in ethics officials across the agency.

MR. LAWRENCE: It's a good breaking point, so it's times for a break. Stick with us through the break, because when we come back, we'll ask Amy Comstock, Director of the Office of Government Ethics, about the financial disclosure processes for political appointees. Did you ever wonder what you'd have to reveal if you were asked to join the Administration? We'll find out when The Business of Government Hour returns.


MR. LAWRENCE: Welcome back to The Business of Government Hour. I'm Paul Lawrence, a partner at PricewaterhouseCoopers and today's conversation is with Amy Comstock, Director of the Office of Government Ethics.

Well, Amy, in the first segment, you mentioned a couple of things that I probably want to make sure I have a complete understanding of. And that's conflict of interest and disclosure. Could you spend a minute telling me -- making sure I got the right definitions of those?

MS. COMSTOCK: Absolutely. A conflict of interest, in the government sense, means that a government official may have worked -- or a conflict would be where a government official works on a matter or participates in an issue, if you will, where they also have a personal financial interest.

And so the criminal statute at issue and then the regulations are actually written in a prophylactic way. They prohibit federal officials from working on any matter in which they have a financial interest.

An easy example of this would be if I have $50,000 worth of stock in a particular company that would be affected by a decision I make as a government official because the decision would affect that segment of an industry. For an example, the easiest one is companies that make tires and I'm working on a regulation that might affect the tire industry. And I, in fact, own $50,000 of stock in a company that makes tires. I, under these rules, cannot participate in any decisions that would affect the finances of the tire companies.

What's interesting about these statutes is, as I said, they prophylactic, they keep people from having to decide am I doing the right thing -- am I sure I'm not making a decision just because I own stock in the company or, in fact, what they do is prohibit the employee from participating at all. They keep the federal employee from having to do the right thing or struggle to do the right thing.

That is the easiest example. There are a couple possible resolutions. Because, in fact, if we step back and look at all the different kinds of people who come in to the federal government, either as career servants who will be there long term or during the change of administration, as we've just seen. People have all different kinds of investments and they come in with all sorts of assets that they own.

What we do is, through a process of financial disclosure, we review someone's holdings and assets to determine if we think they will have a conflict of interest. We have something called a public financial disclosure form, which is filled out by all presidential nominees. And then, once a year, by the 20,000 top government executives, federal government executives, that form discloses all assets someone owns, financial transactions they've had in the last year, any outside positions they may hold, gifts they've received for -- not for nominees, but beyond that, gifts someone's received.

We review those forms to determine if there are any conflicts or, potentially, will be any conflicts. If a conflict, again, the tire industry, for example, if a conflict is found to have -- to be at issue, the possible resolutions are that someone divest themselves of the holding. In that case, I would sell my tire company stock or I agree to recuse, meaning I agree to not participate in the tire company decision or another common resolution is a waiver. Ethics officials throughout the federal government have the authority, if they review a number of factors that have to be taken very seriously, they have the authority to determine that, given all the factors, and looking at exactly how much stock this person owns and what the government question at issue is they waive the conflict and they've determined the person can participate in it.

The example I gave that might not be a good candidate for a waiver because that seems to be a pretty clean conflict -- pretty clear conflict. And it's a liquid holding, something I really couldn't divest.

When I referred to public financial disclosure forms, this is an important aspect of our program. The mission behind the Office of Government Ethics is not just for us to assess conflicts of interest or for ethics officials throughout the Executive Branch to assess conflicts of interest. It's also to ensure that the public has the ability to assess the integrity of government decision-making on its own.

So for those 20,000 Executive Branch employees who file financial disclosure forms every year, they are available to the public for the public to view themselves. They -- and they are viewed. They're requested quite regularly by the media and are used to determine whether there might be questions behind a public official's decision-making.

MR. LAWRENCE: What are some of the management challenges that OGE faced in the most-recent presidential election?

MS. COMSTOCK: Well, in terms of the most-recent presidential election, we did -- because we review for every presidential nominee -- Senate-confirmed nominee -- the financial disclosure to determine if there will be any conflicts of interest -- quite frankly, the extended election did mean that we began that process a little bit later than we expected to, but I have to say that the staff at OGE and the agencies and the White House have worked very hard so we feel that we are caught up in that. So that was just a -- that was just some late nights in the spring when we expected to have the late nights in late winter.

But in terms of the management challenges that I think I've seen at OGE since I started in November -- and actually in the years that I've been working at ethics -- one issue that I struggle with is, honestly, the name of our agency. We are, of course, the Office of Government Ethics and I have had many conversations with people who feel that we have, therefore, usurped what you and I might consider to be ethical decision-making.

Our office does issue a code of conduct that all federal employees are expected to abide by. We have conflict-of-interest regulations, we have post-employment regulations that everyone, based on statutes, that everyone is expected to abide by. But it was never intended that the codes-of-conduct that we have would usurp individual employees' and executives' personal decision-making.

I am a strong proponent of ethical decision-making and values-based decision-making by all executives. And I would always challenge everyone that the code-of-conduct is not the last place to -- is not the last stop for your own decision-making as a government executive. We establish minimal standards for behavior, but if something -- one must always bring their own values, their own judgment to any decision that they make.

If something feels wrong, you need to pursue it. If one of our rules tells you that something is wrong and you firmly disagree with it, you need to call me. I -- government executives, I firmly believe and will always will encourage, still need to bring their own years of experience and judgment to any issue they consider to be ethical -- now if it's -- an ethical question, if it's clearly covered by our rules, we need to talk about that and have that conversation with someone in my office or with an ethics official. But never think that our office has usurped individual ethics decision-making values, if you will.

MR. LAWRENCE: Are there any challenges around the disclosure form? The example you gave of the tire company and the stock and that kind of decision, seem clear. But I'm wondering about the sort of blurring of companies and services and the Internet and how even to unravel that in a possible �

MS. COMSTOCK: It's getting harder. I think you've hit on a real point that we struggle with. Investments are getting more complicated. Companies are getting more complicated, in terms of parent companies and subs. We will discuss in a little bit some legislation that we've sent up to the Congress just this summer to try and streamline the financial disclosure process. But one of the components of that legislation is a new provision to help us deal with limited partnerships, for example.

Ten years ago, most often, even for very wealthy individuals, assets tended to be just straight equity stock holdings. Many, many people now have limited partnerships where they hold something that then holds another partnership, it's much more complicated to even figure out, believe it or not, what someone actually owns. And if you buy some share of a limited partnership, you don't even always know exactly what you own. You may know what industry it is. So that is becoming more of a struggle.

We're trying to achieve that perfect balance between not putting so much burden on an employee that it's hundreds of hours work to fill out the financial disclosure form. But, quite frankly, the public still absolutely, under our system and I believe it, has a right to know what this person owns and where their interests are.

Remember -- and this is an important concept we always have to keep in mind in our office -- our government is basically designed to turn over at the highest levels every four-to-eight years. So we do have a constant churning of new people coming into the government. And we're trying to ensure that our system of disclosure is not so burdensome that, without need, without unnecessarily, that it deters people -- that it's such a struggle, in and of itself, to do these forms that it deters people from wanting to come into government.

I don't think we've ever reached that point, but there -- in the last two years, there have been some complaints that we're close.

MR. LAWRENCE: That's a good place for us to stop for a break. We'll come back. We'll ask Amy Comstock of the Office of Government Ethics more about how the ethics programs work.

This is The Business of Government Hour.


MR. LAWRENCE: Welcome back to The Business of Government Hour. I'm Paul Lawrence, a partner at PricewaterhouseCoopers and today's conversation is with Amy Comstock, Director of the Office of Government Ethics.

Well, Amy, in our last segment, you talked about new legislation that you're developing and you described some of the characteristics, could you give us a little more insight into the legislation?

MS. COMSTOCK: One of the things that I mentioned is that there has been sense, and I agree with it, that the nominations process and the financial disclosure or public financial disclosure process has become too burdensome. I'm focusing, primarily, on the financial disclosure aspect of that.

The information that we've required for the last 20 years for public financial disclosure is actually quite detailed. And as a result of the Presidential Transition Act, legislation that was enacted last fall, OGE was asked to do a study to see if that process could be streamlined.

Quite basically, what we did was go in with the mandate that we were not going to lessen our or ethics officials' ability to assess conflicts at all. But we went in with the mission that after 20 years of experience is there information that we receive from that form, that is either never used, useless, redundant? So we just went through with those questions in mind and, as a result were able to propose legislation that really eliminates a lot of the, I would call, unnecessary information that we accept on the form.

For example, currently, if someone comes from a private corporation and they're coming into the government, they have to list on the form the exact dollar figure of their salary from their prior corporation. Quite frankly, it doesn't matter what that dollar figure is, it will not change the fact that they should have a one-year cooling off period from their corporation and any official decision-making they make unless they receive a waiver. And if they own stock in the corporation it will be a conflict. It doesn't -- they -- but someone has to actually go through the -- take the time to get the exact dollar figure written down on the form. We've proposed to eliminate that requirement.

In addition, the current form has 11-different categories for the range, the value of an asset you hold. And this is -- this is the most significant change that we're proposing. Currently, if you have to -- if you own stock in that tire corporation, again, you have to check in a range if it's worth between I think it's $15,000 and $50,000, between $100,000 and $250,000; but, with certain limits, if that asset is worth maybe $50,000 or $250,000, there is a conflict. It actually doesn't matter to assess a conflict the exact value of that asset but, especially for people who have any significant assets at all, the amount of the hours it takes to go through and determine the exact value of all their assets is phenomenal.

We've been able to eliminate the 11 categories or propose eliminating the 11 categories of value and reduce it to three. I could go through all these and I don't think our listeners want to hear all the details of all of them. But the fact is that if these proposals are enacted, we will be able to reduce hours and hours the amount of time it takes to fill out this form. But we firmly believe not impede at all an ethics officials' or the public's ability to determine whether someone has a conflict and assess integrity in decision-making.

MR. LAWRENCE: Well, earlier you mentioned that you were, in fact, a political appointee, yourself. Do you have any suggestions or lessons-learned for those nominees who are currently involved in the process?

MS. COMSTOCK: Well, be patient, I think would be the most important guidance. Answer all questions you're asked fully, but most important hang in there because it's worth the wait. From my own experience, as well as from surveys that I've read, a position as a presidential appointee, a Senate-confirmed position, according to a presidential appointee initiative survey, the vast majority of people who have held those jobs would recommend it to a friend. It's just a wonderful opportunity for public service and to really work on issues and matters that are important to the country. And I think it is definitely worth the wait.

MR. LAWRENCE: Well, let's shift a little bit in terms of talking now about manage OGE. What are the strategic priorities for OGE for the year?

MS. COMSTOCK: Paul, obviously, the number-one priority will be to do anything we need to do to ensure the passage of the legislation that we've just talked about. I'm hopeful that it will go through. We sent it up in July and it should be introduced in the fall. It is nonpartisan, good-government legislation, and I'm hoping it will go through.

But keeping my fingers crossed and assuming that that task is done because it's up on the Hill and we'll be successful, I am now committed to starting a review of the criminal conflict-of-interest statutes. We haven't really talked about that, but the criminal statutes that underlie the need for financial disclosure cover the areas of conflict-of-interest, post-employment, and issues of, for example, representations a federal employee can make to other agencies on behalf of outside organizations, volunteer activities, that kind of thing.

These statutes are very broad; they need a lot of modernization. Some of the activities that are actually criminal under these statutes, in my mind, should not be criminal and are not even intuitively wrong. This is an area that I'm very committed to working with the Department of Justice to see what proposals we can come up with to revise these statutes.

The criminal conflict-of-interest is, obviously, the main topic today. And there are some areas, I think, where that statute is very broad and the most educated person, in terms of government ethics training still can be surprised sometimes when I say not that would be considered a conflict and you need to be careful and stay out of that.

MR. LAWRENCE: What process does OGE go through to choose those strategic priorities?

MS. COMSTOCK: Obviously, I'm a firm believer in team management. And we work as a -- I have some excellent, excellent deputy directors. And we work, as a team to focus on the issues that we think are priorities for the next year or two.

I have a five-year term and, so, I have four more years within that term. The -- I also look very closely and take very seriously the issues that are raised with me by the ethics officials in the agencies, in terms of the problems that they're seeing or the issues that arise when they deal directly with their clients.

We haven't talked about that in great detail, but every department in the federal government and agency, has a designated agency ethics official. They're the people who bring to life, if you will, the programs and regulations and policies that are set by our office. They are each tasked with the responsibility of overseeing the ethics program within that agency. It's really a -- at least, in hindsight -- brilliant structure because it allows each department and agency to have someone who can tailor the ethics problem within that agency to the needs of that agency.

For example, the ethics issues that might arise at the SEC, the Securities and Exchange Commission, could be very different than the ethics issues that would arise at the Department of Education. And so, it's very important for those DEOs, that we call them, to be able to tailor the ethics rules to the needs of their clients.

MR. LAWRENCE: What role does OGE have in terms of evaluating the successes of those different ethics programs?

MS. COMSTOCK: It's our responsibility to oversee those programs. Under the statute, we're called the supervising ethics office, so that if particular issues arise, it is our responsibility to follow-up and ensure that that agency is responding to that issue to ensuring that that issue is dealt with properly. And, unfortunately, issues do arise occasionally.

And we keep in fairly close contact with the DEOs in the sense of we have regular written guidance, obviously, a number of the DEOs at the larger departments we speak with personally on a fairly regular basis. We have other communication tools that we use. Once a year we have an annual conference of between 400 and 500 ethics officials who come together to talk about the hot ethics topics of the year.

But, in addition, we every four years, audit the ethics program of every agency and department. We send out a team of staff from our office who will go and look at various aspects of the ethics program at each agency and, always, they walk away with some recommendations because, obviously, everything always could use a little improvement or tweaking.

But that's the process we use to ensure that the fundamental components of a program are in place.

MR. LAWRENCE: What is or does a successful ethics program look like? How do you measure it?

MS. COMSTOCK: A successful ethics program, in terms of the components that the law requires, would include a financial disclosure system, obviously, that is being monitored; the forms are being reviewed carefully in a timely manner. It also includes a training component, which we haven't really discussed, but at the highest levels, federal employees, all those who file these public financial disclosure forms, are required to be -- to receive ethics training once a year and a strong ethics program includes a training component. And these are all things that we can measure.

The fact is, though, that the best ethics program is one that is used by employees, where the employees will reach out to ethics officials and ask their questions. They receive answers that are workable for that agency. It's very important to me, as a leader and in terms of the mission of OGE to ensure that our program is not just a stand-alone, bureaucratic program. We need to be able to give guidance that is integrated well with the mission and the programs of an agency.

And that's much harder to measure. But counseling in a really strong program -- whenever we've seen a really strong program, it has a very strong counseling component.

Now, when you step back -- the bigger picture -- how do we know if the ethics program for the whole Executive Branch is successful? I don't really know. And that's what I meant if someone knew the answer.

If you see -- if an ethics official is getting an increase in calls, does that mean people understand the issues more and are calling more? Or does that mean they didn't learn a thing in training, they're totally confused and they're calling with questions? If the calls stopped, does that mean they learned all the answers, or they don't care about the issues?

I don't know how to measure that.

MR. LAWRENCE: Okay, and that's a good breaking point. Come back with us after the break, and we'll find out what the future of government ethics might look like. Will all this technology be an advantage or a disadvantage?

This is The Business of Government Hour.


MR. LAWRENCE: Welcome back to The Business of Government Hour. I'm Paul Lawrence, a partner at PricewaterhouseCoopers and today's conversation is with Amy Comstock, the Director of the Office of Government Ethics.

Well, Amy, what advice would you give to a young person who's interested in a career in public service?

MS. COMSTOCK: Well, I actually, Paul, have to say that the first thing I want to say because my husband is a high school teacher, is work hard, stay in school and go to college. Beyond that, I'm really proud of my career in government service. I'm proud of the fact -- I still consider myself a career public servant, in spite of the fact that I am a presidential appointee. And I have to say that in the, I guess, 13 years that I've been in the government now, I have seen so many instances where a person's personal interests, personal passion, hard work, has allowed them to get a policy through to effect a change in the government, to actually have an impact. So, when I hear people espouse that the government is so big, it's such a large ship it can never be turned around that, you know, what's the point of going there, you know, you get lost in bureaucracy -- I can't deny that that occurs, I mean, obviously, I've seen enough of that in government, too.

But the fact is that that's not always the case. I've seen just as many instances where a person does come in, they do make a difference, their passion shows through in the work they do and it has an effect. So I would encourage people to keep the government in mind as an option for your work, because it really can be an effective, exciting place to work.

MR. LAWRENCE: Is there any set of skills you recommend they acquire?

MS. COMSTOCK: Gosh, it really depends on what area they want to go in. I'm a big believer, personally, in a liberal arts education because someone who can write well and who can speak well, will always be able to argue most -- argue their case and position very effectively.

MR. LAWRENCE: Well, how about somebody who's very interested in ethics, perhaps now, as a result of this conversation? What skills should they be learning or acquiring?

MS. COMSTOCK: Certainly that would be one where you'd want to write well. Someone who's interested in ethics, that's still -- that's a really broad term. You can have, you know, you can go back and talk about the philosophers, you can talk about codes-of-conduct, which a lot of corporations have. There are a lot of private organizations out there, which are now looking -- working with private corporations are looking at ethics from the broader perspective and the impact on society. If anyone's interested in those, I would suggest they go on the Internet, there are a lot of organizations that are dealing with ethics in the workplace now or ethics and society.

MR. LAWRENCE: Let's think a little bit about the future. What will be the future demands for ethics programs?

MS. COMSTOCK: Well, I think that the demand should remain the same and I hope it does. The mission, in terms of, for government ethics, ensuring integrity and impartiality in government decision-making should always remain the same. I think how we achieve that may change over the years -- and I hope it does because there's a lot of benefit that we can achieve through technology.

Currently our system is very paper-based and, as I indicated earlier people, for example, file an annual form. I think that -- I hoped that in ten years, for example, that will not be the case anymore. I foresee the day where employees will be able to go onto their computer and put in the asset, hopefully, because we run a prevention program that they're thinking of buying, not that they've already bought -- and determine if it's a problem. That they'll be able to instantaneously receive advice on a question about an outside position they want to take or something related to that; post-employment question for our former employees.

I really see kind of more immediate response. I do, eventually, believe, for example, that the public will be able to receive financial disclosure forms over the Internet. I don't know if they'll -- excuse me, over email. Currently, it's a very paper-based system, but I think there's a lot we can do through technology.

MR. LAWRENCE: Will there be any other benefits from technology that you can imagine other than replacing paper?

MS. COMSTOCK: Well, certainly, the instantaneous guidance is what I enjoy about the Internet, it's, you know, you basically can receive your information immediately. And the ethics program does not necessarily guarantee that now in terms of conflict-of-interest guidance, review of financial disclosure forms, it's a much longer process right now because it goes -- it will travel from person to person. And I would like to see that -- or I foresee the day where that will be -- that that will simply already be in the computer in terms of what problems are and someone will receive instantaneous guidance. And that will prevent a lot of problems.

MR. LAWRENCE: If it became easier, could we imagine a world in the future where lots more government employees participated in this process of disclosure, that it was rolled out much wider?

MS. COMSTOCK: Well, currently, we have 20,000 who file the public financial disclosure form now. But beyond that, there's, I believe -- gosh, I believe it's 250,000, although I'd have to check that figure, Paul, who file a confidential financial disclosure form. These are public officials who are not at the level that it's been determined that the public, really, should be able to determine their own decision-making, but they're still officials who have a lot of discretion in decision and have potential for conflicts.

Of course, all these people, I believe, are honest good civil servants. But they file financial disclosure forms, as well, but those forms are only reviewed by the ethics officials to determine that there aren't conflicts.

I don't know that we'll ever get to the point where more people than that need to file, but we may. But I think we've tried to cut it off at the people who already have the discretion, have the ability to have a conflict.

MR. LAWRENCE: How do you think OGE will evolve in the next ten years?

MS. COMSTOCK: Well, one other area where I think we will evolve and that also will be impacted by technology is training. The Executive Branch, as you know, actually has employees all over the world because of the Department of State, certainly, people at all sorts of embassies; Agriculture has people in all sort of -- in many parts of this country where there aren't large offices for the federal government.

So, another area where I see technology benefiting us is training. It does allow us for immediate interaction through the Internet, conversations that are significantly improved over telephone conversations. But that are more, you know, face-to-face interactive, but where people do not have to fly, to a post that is, you know, to have a conversation with one or two people. So I do -- I'm very excited about the opportunities that technology will give us in terms of reaching out to people individually, but without having to travel there because training, again, training will always be a very strong mission.

MR. LAWRENCE: How important or what are the characteristics of a good ethics program in an agency? I've heard it said that having strong leadership support for ethics is really key in having a program. And having all the other things but without that leadership support, probably it'll be difficult for that message to be carried?

MS. COMSTOCK: I think that's right. We all look to our leaders to see how they act and, in terms of setting our own standard. But -- and there's no doubt -- there's many studies that show that the actions taken and the standards set by our leaders, by our CEOs establish the culture for the agency.

But I have to say that in the federal government, I think, as is often the case, it's more complicated than that. We certainly look to our leadership, we look to the President to establish the standards and the Cabinet for ethical behavior and that's an extremely important influential statement.

But, in addition, quite frankly, we also look to the culture of the agency and to individual supervisors. One of the areas that I'm trying to focus on is to reach out, clearly to reach out to the highest-level leaders but, also, to reach out to the supervisors in all the agencies and ensure that they understand the importance of ethics and their role in ethics.

Quite frankly, if an employee ever has a problem, a dilemma, and they walk into their boss's office and say here's my dilemma, you know, where should I go with this and the boss gives them an answer. For most of us that is the answer, that's where they'll stop. So, one of the things that I'm trying to do in terms of building on this leadership -- the impact of leadership, is to include in our concept of leadership all the supervisors and managers in an agency and instill in them the highly influential role they have in establishing the ethical culture in the workplace.

MR. LAWRENCE: What kind of conflicts or challenges result because of what you just said, that those are, in fact, the people that you would turn to with issues and if they're not, perhaps, enlightened?

MS. COMSTOCK: Well, I don't know if it results in a conflict, but it certainly results in a challenge for us because our system -- as I came to OGE, our system is to basically communicate through, as I said, the one person whose the designated agency ethics official. In a large department, like Treasury, you know, that one person, I then in the system as we're structured, I kind of expect that person to then filter down what I said into the incredible number of people who work at Treasury.

The challenges -- what I'm talking about is reaching out more directly to supervisors and instilling in them from us the sense of mission and ethical culture that we're talking about. We're working with HUD to establish a pilot project to reach out directly in terms of ethics training to the supervisors at HUD to address the issues that we're talking about. And I'm hoping that that pilot project will show that the kind of training we want to do for supervisors will be effective and become a part of the culture in the agency.

MR. LAWRENCE: Well, Amy, I'm afraid we're out of time. I want to thank you for joining us this morning.

MS. COMSTOCK: It was a pleasure to be here, thank you. Oh, and I do want to mention that if anyone is interested in more details about what the Office of Government Ethics does, they can go to our website which is And, again, thank you for having me.

MR. LAWRENCE: Great, thanks a lot. This has been The Business of Government Hour, featuring a conversation with Amy Comstock, Director of the Office of Government Ethics.

Be sure to visit us at the website, there you can learn more about our programs and research into new approaches to improving government effectiveness. And you can also get a transcript of today's interesting conversation; once again, that's

This is Paul Lawrence, see you next week.

Amy Comstock interview
Amy Comstock

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