Special Government Employee ReQuirements
This information is for individuals who are thinking about whether they want to serve on a Committee/Board. We thank you for your consideration.
If you are interested in serving, you must be nominated, selected, and appointed as a Special Government Employee (SGE) in accordance with Federal laws and regulations.
Note: If you are serving under a current Federal appointment of any kind, such as with the U.S. Department of Veterans Affairs, please contact the NIH official, Institute/Center Committee Management Officer (IC CMO), or Designated Federal Official (DFO) who reached out to you about serving.
Listed below are some of the necessary forms to complete, requirements to fulfill, and systems you need to access to be appointed and to serve as an SGE. Please review these items and consider whether you would want to disclose the required information to NIH staff as part of the appointment process. If you identify any potential issues or have any concerns that might prevent you from serving or have any questions about the items below, please contact the NIH official, IC CMO, or DFO who reached out to you.
The eRA Commons (also known as eCommons) is an online interface where signing officials, principal investigators, trainees, and post-docs at institutions/organizations can access and share administrative information relating to research grants. Nominees and members of Committees/Boards are granted access to the NIH Enterprise Ethics System (NEES) as a secure mechanism to complete and periodically update the Confidential Financial Disclosure Report (OGE 450) (see below) using your eCommons account. Verify that you have a current eCommons account and can gain access to that system (more information about eCommons and accounts is available
here). If you do not have an eCommons account, please contact the NIH official, IC CMO, or DFO who reached out to you about serving.
USA Staffing Onboarding
You will use the USA Staffing Onboarding system to complete required Human Resources forms if you decide to serve on a committee and be appointed as an SGE. At the appropriate time, you will receive an email with a dedicated link and instructions for system login, form completion and submission from the appropriate Institute/Center Committee Management Office.
Confidential Financial Disclosure Report (OGE 450)
The purpose of this report is to assist employees and their agencies in avoiding conflicts of interest between official duties (i.e. the Committee’s work) and private financial interests and affiliations. Agency ethics officials will use the information that you provide to determine whether any potential conflicts exist. As an SGE, you are required to file an OGE 450 report prior to your appointment through NEES and then provide periodic updates throughout your appointment. Your OGE 450 reports will remain confidential and are only subject to release in accordance with federal requirements and the Privacy Act, as noted on the form. Designated NIH officials will review the information prior to your initial appointment and then again on each update cycle to help identify any potential conflicts of interest. Please review the OGE 450 report at this
link, which is a sample form. If you decide to become a member of a Committee/Board, you will be instructed when and how to complete the form electronically in the NIH Enterprise Ethics System, a secure mechanism used to complete and periodically update the OGE 450. Generally, you will need to disclose the following types of financial information for you, your spouse, and/or your dependent children:
- Sources of income exceeding $1,000 from any non-governmental source, such as domestic and foreign employment, intellectual property (e.g. patents with a royalty sharing agreement), and consultant work.
Assets with a value greater than $1,000 such as stock or stock options in publicly-traded and privately-held companies, real estate held for investment purposes, bonds, sector mutual funds, annuities, trusts, and private equity funds (e.g. limited partnerships, hedge funds, venture capital funds, etc.)
- Any position you hold, such as your employment, advisory board positions, or committee memberships with any non-governmental entity such as journals, professional societies, universities, non-profit or for-profit entities.
- Members need to report all non-Federal sources of research funding.
- Retirement accounts (self and spouse) with previous and current employers and their underlying holdings.
Foreign Activities and the Emoluments Clause
SGEs are subject to the Foreign Gifts and Decorations Act, and many SGEs are also subject to the Emoluments Clause of the U.S. Constitution. The provisions of these laws
will apply at all times during your appointment as an SGE, not just the periods of time you are performing services for the NIH. Generally, subject to some limited exceptions: (1) the Emoluments Clause will prohibit you from holding a position or title with a foreign governmental entity (including certain universities), and from receiving compensation and certain gifts from a foreign government and (2) the Foreign Gifts and Decorations Act will restrict your receipt of gifts from foreign governmental entities (including certain universities), although compensation for services is generally permitted. You will be required to complete the Foreign Activities Questionnaire (HHS 697) prior to your appointment and annually throughout your term. You may review the Foreign Activities Questionnaire
here. NIH Committees subject to the Emoluments Clause can be found
Federally Registered Lobbyist Prohibition
To reduce the influence of special interests, agencies may not appoint federally registered lobbyists to serve on Committees/Boards. The prohibition on the appointment of lobbyists applies to SGEs, and for the purposes of this policy, includes any individual who is subject to the registration and reporting requirements of the Lobbying Disclosure Act of 1995, as amended (2 USC 1605). Therefore, you will be required to certify that you are not a Federally-registered lobbyist prior to your appointment and annually throughout your term. You may review the policy and certification form at this
Items to Note:
In addition to completing these forms, once appointed, you will have several obligations during the year, such as updating your OGE 450 report and Foreign Activities Questionnaire, completing annual ethics training, and re-certifying that you are not a federally-registered lobbyist.
Additional information and guidance about serving as an SGE can be found here.
If you are interested in serving after reviewing these requirements, you will be asked by the NIH official, IC CMO, or DFO for the following documents and information:
Current version of your curriculum vitae (CV) or resume
Place of birth and residential address (if this information is listed on your CV, please disregard)
Name and contact information for your assistant (if applicable)
Your preferred email address and any other email addresses
Your eCommons ID (username)
When you log into your
eCommons account, please ensure the following demographic information is entered into your profile:
Work mailing address
Back to top