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3. ARE YOU CURRENTLY SERVING AS AN SGE?

Now that you are officially appointed as an SGE, you will have the following annual requirements. Once you are notified by your designated Institute/Center Committee Management Officer, please pen-and-ink sign, scan, and return the following:

  1. Foreign Activities Questionnaire (HHS 697)
  2. Foreign Activities Questionnaire (HHS 697)
  3. Initial Ethics Training

You will also have the following periodic requirement:

  • Immigration and Naturalization Employment Eligibility Verification (I‑9)
  • Appointment Affidavit (SF 61) (form must be notarized)
  • Declaration for Federal Employment (OF 306)

You will also have the following periodic requirement:The items below are some of the forms and requirements necessary to be appointed and to serve as an SGE. Please review these items and consider whether you would 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 who reached out to you.

eRA Commons:

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 Ethics Enterprise System (NEES) as a secure mechanism to complete and periodically update OGE450 report, the Executive Branch Confidential Disclosure Report (see below) using your eCommons account. You may want to assure now that you have a current eCommons account and can gain access to that system (more information about eCommons and accounts is availablehere).

USA Staffing:

This is the system you will use 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 instructions from the relevant committee management office.

Confidential Financial Disclosure Report (OGE 450)

The purpose of this report is to assist employees and their agencies in avoiding conflicts between official duties and private financial interests or 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 the 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 through the above-provided link. 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, or for-profit entities.

Foreign Activities and the Emoluments Clause

SGEs are subject to the Emoluments Clause of the U.S. Constitution and/or the Foreign Gifts and Decorations Act. 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), which can be foundhere.

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 by completing the form which can be foundhere.

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 foundhere.(Note to ORS:link to"Are you currently serving as an SGE" page that lists the annual requirements)

Next Step:

If you are interested in serving after reviewing these requirements, you will be asked for the following documents and information by email:Currentversion of your curriculum vitae (CV)

  • Current version of your curriculum vitae (CV)

  • 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

When you log in to youreCommons account, please ensure the following demographic information is entered into your profile:

  • Birth date

  • Employer(s) name

  • Work mailing address

  • Phone number

  • E-mail address

If you have any questions regarding this process or packet, please contact theCommittee Management Contact from your welcome email.

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