SaaS case study: How the Department of Veteran Affairs modernized financial disclosure

The VA capitalized on the success of a small IT project focused on solving a specific technical problem preventing 150 SGEs from filing financial disclosure forms – and used it to modernize the entire process for 13,000 filers and 5,000 supervisors enterprise-wide 

The Department of Veterans Affairs (VA) sometimes employs outside experts. This category of personnel is known as Special Government Employees (SGEs). They are usually employed for 130 days or less and work on specific projects that require their specialized knowledge. 

SGEs usually maintain outside connections during their special employment – and for good reason. Many put their full-time jobs on hold until a given VA project is complete. Because they maintain these connections, they are required to comply with stringent ethics rules, such as financial disclosure. 

Any federal employee, including SGEs, who has influence over budget decisions is required to disclose personal financial holdings. These assets are reviewed for potential conflicts of interest (COI) by an agency’s ethics department. The purpose is to reduce the risk of an SGE offering advice in a manner that serves personal interests rather than the government’s or taxpayer’s interests. 

 

Problem: Modern requirements are limited by a legacy solution

Financial disclosures are made using a form managed by the Office of Government Ethics (OGE) such as the OGE Form 450 series or OGE Form 278 series, depending on their responsibilities. Yet the VA found itself in a difficult position when trying to facilitate compliance for a small group of 150 SGEs – because they didn’t have government email addresses. 

To manage and account for the forms, the VA used a homegrown system developed by the U.S. Army called Financial Disclosure Management (FDM). The system requires users to have a government email, however, the temporary status of SGEs means a government email is not issued to them. This technical problem prevented these employees from filing online.  

The alternative was to complete forms manually – that is, fill out a PDF copy of the OGE form – and email it around while tracking progress in a spreadsheet. This has two primary drawbacks. First, the manual process is error-prone. Second, these forms contain sensitive personally identifiable information (PII) and email simply isn’t reliably secure.

 

Solution: A rapidly deployed SaaS solution for secure financial disclosure

The compliance manager for this project had come from another federal agency, and she had worked with Financial Disclosure Online (FDonline) by Intelliworx. FDonline is a FedRAMP-authorized SaaS solution used by dozens of other federal agencies. 

Over the last several years, FDonline has facilitated disclosures for over 90,000 federal employees per year. The smallest agency has just 17 civil servants required to file annual financial disclosures, while the largest has 16,200 filers on the platform. Once the contract was approved, Intelliworx quickly provisioned the system just for those 150 employees.

 

Results: Small success leads to an opportunity for modernization

Those 150 SGEs were able to comply with financial disclosure requirements in little more than the time it took them to complete the form. These forms tend to be complicated and taxing to complete, yet with FDonline, even SGEs found the process of complying to be easy. 

This is because Intelliworx used its solution to convert those complicated forms into simple and intuitive intelligent interviews – as it has done many times with a variety of different forms and processes across multiple government agencies.  Moreover, the VA discovered FDonline is a cost-effective solution that yields an efficient and streamlined process that expedites compliance and yields many other benefits:

• A better employee experience (EX). The intelligent interviews aside, the system saves the data from year to year, so employees aren’t wasting time rekeying information they’ve already submitted. Automated alerts and reminders help everyone meet deadlines.
  
• Improved data accuracy. The system incorporates field and form-level validations that include compliance with form instructions, business rules, applicable laws, regulations, unique agency policies, and data constraints. This ensures the integrity of the data and prevents errors and rework.
  
• Customizable to meet unique needs. FDonline enables each office to configure the system to meet its own unique needs. This includes customizing the intelligent interviews, workflows, tasks, and instruction and reminder templates, to best support internal processes. 
• Brings transparency to the process. Unlike a static government form, FDonline isn’t just a means to collect disclosure data, it supports the whole process. All stakeholders can see where a disclosure application is in the process – and what actions are pending.
  
• Puts leaders in command of their numbers. Managers can easily report on aggregate disclosure activities, including those disclosures that are due, submitted, in review, approved and disapproved. They can easily identify bottlenecks or zoom in to verify compliance details on demand. 

While the VA contracted this project to solve a specific problem, the speed, efficiency and efficacy FDonline brought to the financial disclosure process had gotten the organization thinking. Perhaps there was an opportunity to modernize the process for the entire organization.

 

Turning a small success into enterprise-wide process improvement 

FDonline provided one key benefit the VA could not do with the legacy system: involve supervisors in the disclosure review process. While all OGE forms are reviewed by a lawyer or ethics official, they don’t have visibility into the day-to-day work of any given employee. 

To put it another way, a local supervisor for an employee who works at a VA healthcare facility in Atlanta is better positioned to understand possible conflicts listed on a form than an ethics lawyer based in Washington, DC. The best practice is that both the supervisor and the ethics department should be involved in the review process.

The challenge was that the existing legacy system could not support supervisors in the review and approval workflow. While one-offs here and there might be feasible to manage in a spreadsheet, the VA had 13,000 filers with 5,000 supervisors, which made that idea untenable. 

The VA issued a public request for a proposal (RFP) for an enterprise deployment of financial disclosure software. Intelliworx won the contract award, and once the authorization-to-operate (ATO) was granted, the system was rolled out for all 13,000 filers and 5,000 supervisors in merely four weeks.  

With that decision, the VA joined 38 other federal agencies that have already implemented FDonline to support financial disclosure. Collectively, Intelliworx has supported the collection and review of 450,000 disclosure forms over the last six years. Excluding the Department of Defense, Intelliworx facilitates roughly 60% of these filings across the federal government.

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Intelliworx has been providing purpose-built software to the federal government for 20 years and currently serves 39 federal government agencies. The company is a certified service-disabled veteran-owned small business (SDVOSB) and is FedRAMP-authorized. See how FDonline can bring greater efficiency to your agency. Contact us for a no-obligation demo.

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