Justification for a Nonsubstantive Change - OGE 450 Excel

U. S. OFFICE OF GOVERNMENT ETHICS
JUSTIFICATION FOR A NONMATERIAL/NONSUBSTANTIVE CHANGE
OGE FORM 450 EXECUTIVE BRANCH CONFIDENTIAL
FINANCIAL DISCLOSURE REPORT
SEPTEMBER 2020

The OGE Form 450 has been approved for use until November 2021. The current
information collection request includes one information collection instrument, a PDF
version of the form. OGE is now requesting approval to make a Microsoft Excel version
of the OGE Form 450 available for use as a second instrument. The proposed Excel
version will collect the same information as the approved PDF instrument, and the
instructions are the same. The only differences are slight variations in line breaks, font,
and the number of blank data entry rows on the Part I pages. The public burden will not
be affected. Accordingly, OGE is requesting a nonmaterial/nonsubstantive change to add
the second information collection instrument to the information collection.
The purpose of the proposed Excel version is to improve the user experience,
particularly for confidential filers with extensive assets. OGE currently makes available
two versions of the OGE Form 450 PDF form. The first version is 508-compliant but
static, meaning there is no way for the user to add additional pages within the form file
itself. Several continuation pages are instead provided at the end of the file. The second
version is not 508-compliant but it is dynamic, meaning the user can add pages by
clicking an “Add Page” button which appears at the bottom of each page. Unfortunately,
the second, dynamic version contains a number of technical defects that have proven
difficult to fix. In the interests of providing a fully functional, dynamic version of the
OGE Form 450 to users within the limits of OGE’s resources, OGE has developed a
Microsoft Excel file that recreates the existing (August 2020) OGE Form 450. Users
would be able to add pages by copying the appropriate tab within the Excel file.