The Congressional Budget Office and Disclosure of Conflicts of Interest

The Congressional Budget Office is a Legislative branch agency that supports the Congressional budget process by providing analyses of budgetary and economic issues. CBO makes use of an outside panel of advisers to help inform its work products. Because outside experts can have conflicts of interest, CBO requires the advisers to annually submit forms to disclose “substantial political activity and significant financial interests.” 

In normal times you can email CBO at communications@cbo.gov to request to review the disclosure forms. The process involves a visit to CBO’s offices — the documents are not disclosed online. They are maintained on a stand-alone computer that is not connected to the internet. You cannot download the documents or print them out, but you are allowed to use your phone to take pictures of the screen or to take notes. (This is a somewhat convoluted process, modeled after aspects of the House of Representatives’ disclosure process, which works in a similar fashion.)

Recently, the CBO  made it possible to review the documents remotely. Just as before, you must email communications@cbo.gov to request access. Instead of visiting the CBO offices, they will send you a link to an online document management system (“IRM Webdrive”), a password, and provide a two-hour access window during which you can review the documents.

Immediately below is the login screen. Note the fairly alarming “CONSENT TO MONITORING” warning screen.

Image of the landing page for IRM WebDrives. It contains warning text and a place to enter your passcode.

Once you log in, you are faced with the following screen, which allows you to select from calendar years from 2015-2020. 

The IRM WebDrives front page, which contains folders for the years 2016-2020.

When you click on a calendar year, it shows a list of disclosure forms for that year. 

An additional image of the CBO WebDrive. On the left is a column of folders representing the years 2016-2020. On the right is a list of files that contain disclosures for individuals at CBO.

When you click on an individual report, you open a disclosure form like this one. Please note that you cannot print it and cannot download it, just as before. You can only view it, which can make it harder to review the information at your leisure. It is possible to take screenshots, which is how we have this example. 

This is an image of page 1 of a conflict-of-interest disclosure form. The text is too small to read, but there are a number of checkboxes.
This is page 2 of the conflict-of-interest disclosure form. It contains hand-written data, including the name of income source, type of income, and the amount of income. The amount of income is broken into two columns: under $200,000 and over $200,000.

Closing thoughts

We are pleased to see that the CBO has taken steps to address our concerns about access to the disclosure forms during the COVID era. Nonetheless, we would urge the CBO to go further. 

In an ideal approach, these conflict-of-interest disclosure forms should be published online, just like many other Legislative branch conflict-of-interest documents. There should be no requirement to register to be able to access these forms. We would also recommend that this information be published as structured data and not only as scanned PDFs.

However, assuming that CBO made this decision deliberately, we would argue that even under the current system it should be possible for users to download the disclosure forms to their computers. Because CBO is already providing this information to the public, from our perspective there is no good reason to make it difficult for users to make use of the information by requiring them to copy it down by hand or make use of screenshots.

We asked CBO to comment on the release of the new system and the agency provided this statement:

“We have been working to develop a new procedure to enable financial disclosure forms for members of our panels of advisers to be reviewed electronically and that system is now available. It replicates the experience users would have had if they had reviewed the statements in our offices. Transparency is a top priority for CBO and the agency continues to enhance its efforts.  We are happy to have been able to make advancements at a time when CBO has been working intensively to assist the Congress as it continues to address the consequences of the pandemic.”