HomeMy WebLinkAbout12-530 Confidential
ADVICE OF COUNSEL
April 20, 2012
12-530
This responds to your letters of February 27, 2012, and March 1, 2012, by which
you requested a confidential advisory from the Pennsylvania State Ethics Commission.
Issue:
Whether the Public Official and Employee Ethics Act (“Ethics Act”), 65
Pa.C.S. § 1101 et seq., would impose any restrictions upon employment of an A
following termination of employment with Commonwealth Department B.
Facts:
You request a confidential advisory from the Pennsylvania State Ethics
Commission regarding the post-employment restrictions of the Ethics Act. You have
submitted facts that may be fairly summarized as follows.
You are currently employed as an A with Commonwealth Department B, in which
capacity you are the C for the D Bureau within Commonwealth Department B’s E Office.
You have submitted copies of your official Commonwealth Department B position
description and the job classification specifications for the position of A (job code
[number]), both of which documents are incorporated herein by reference. You have
also submitted applicable organization charts, which are also incorporated herein by
reference.
You state that in your current position with Commonwealth Department B, you
are responsible for [certain matters]. You or your staff may have involvement in [certain
activities].
You are contemplating leaving your employment with Commonwealth
Department B to work for an F [type of firm] (the “Firm”) that has numerous contracts
with Commonwealth Department B. You state that you may also buy a non-controlling
interest in the Firm.
You state that all of the contracts under which F Gs have been hired are
contracts with one of the Hs and that such contracts are awarded at the H level. You
further state that you are not aware of any contract where the E Office hired the F G and
that you have not participated on any H team which hired an F G for at least the last five
years.
You state that you are an I J. You further state that pursuant to Section [number]
of the K Code, [cite], a person whose L is M by Commonwealth Department B has the
right to be reimbursed up to [amount] for [certain expenses].
Based upon the above submitted facts, you pose the following questions:
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April 20, 2012
Page 2
(1) Whether it would be permissible for you to purchase an ownership interest
in the Firm, and if you would purchase such an ownership interest,
whether your name could be listed as an owner or employee when the
Firm would be soliciting new contracts with Commonwealth Department B;
(2) Whether it would be permissible during the first year following termination
of your employment with Commonwealth Department B for you to work for
the Firm on existing Commonwealth Department B projects already under
contract and for your name to be listed on invoices submitted to
Commonwealth Department B by the Firm for the work that you would
perform;
(3) If you would be permitted to work on Commonwealth Department B
projects during the first year following termination of your employment with
Commonwealth Department B, whether you could communicate with
Commonwealth Department B personnel regarding project matters, and
whether your name could appear in print as someone who completed a
form or notarized a document when your name would be seen by
Commonwealth Department B personnel;
(4) If the answers to questions 2 and 3 above are “no,” then what work, if any,
would you be permitted to do on existing Commonwealth Department B
projects;
(5) Whether it would be permissible during the first year following termination
of your employment with Commonwealth Department B for you to work for
the Firm on local, non-Commonwealth Department B projects where
Commonwealth Department B would have oversight responsibility to
ensure compliance with state and federal laws and a person from
Commonwealth Department B might see your name as someone who
completed a form or notarized a document; and
(6) Whether it would be permissible during the first year following termination
of your employment with Commonwealth Department B for you to be hired
to perform work as a J by a person whose L has been M by
Commonwealth Department B where such person would then ask
Commonwealth Department B for reimbursement for your services
pursuant to Section [number] of the K Code.
Discussion:
It is initially noted that pursuant to Sections 1107(10) and 1107(11) of
the Ethics Act, 65 Pa.C.S. §§ 1107(10), (11), advisories are issued to the requester
based upon the facts that the requester has submitted. In issuing the advisory based
upon the facts that the requester has submitted, the Commission does not engage in an
independent investigation of the facts, nor does it speculate as to facts that have not
been submitted. It is the burden of the requester to truthfully disclose all of the material
facts relevant to the inquiry. 65 Pa.C.S. §§ 1107(10), (11). An advisory only affords a
defense to the extent the requester has truthfully disclosed all of the material facts.
As an A for Commonwealth Department B, you would be considered a “public
employee” subject to the Ethics Act and the Regulations of the State Ethics
Commission. See, 65 Pa.C.S. § 1102; 51 Pa. Code § 11.1; [cite]; [cite]. This
conclusion is based upon the position description and the job classification
specifications, which when reviewed on an objective basis, indicate clearly that the
power exists to take or recommend official action of a non-ministerial nature with
respect to one or more of the following: contracting; procurement; administering or
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April 20, 2012
Page 3
monitoring grants or subsidies; planning or zoning; inspecting; licensing; regulating;
auditing; or other activity(ies) where the economic impact is greater than de minimis on
the interests of another person.
Consequently, upon termination of employment with Commonwealth Department
B, you would become a "former public employee" subject to Section 1103(g) of the
Ethics Act.
While Section 1103(g) does not prohibit a former public official/public employee
from accepting a position of employment, it does restrict the former public official/public
employee with regard to “representing” a “person” before “the governmental body with
which he has been associated”:
§ 1103. Restricted activities
(g) Former official or employee.--
No former public
official or public employee shall represent a person, with
promised or actual compensation, on any matter before the
governmental body with which he has been associated for
one year after he leaves that body.
65 Pa.C.S. § 1103(g) (Emphasis added).
The terms “represent,” “person,” and "governmental body with which a public
official or public employee is or has been associated" are specifically defined in the
Ethics Act as follows:
§ 1102. Definitions
"Represent."
To act on behalf of any other person in
any activity which includes, but is not limited to, the
following: personal appearances, negotiations, lobbying and
submitting bid or contract proposals which are signed by or
contain the name of a former public official or public
employee.
"Person."
A business, governmental body,
individual, corporation, union, association, firm, partnership,
committee, club or other organization or group of persons.
"Governmental body with which a public official
or public employee is or has been associated."
The
governmental body within State government or a political
subdivision by which the public official or employee is or has
been employed or to which the public official or employee is
or has been appointed or elected and subdivisions and
offices within that governmental body.
65 Pa.C.S. § 1102.
The term "Person" is very broadly defined. It includes, inter alia, corporations and
other businesses. It also includes the former public employee himself, Confidential
Opinion, 93-005, as well as a new governmental employer. Ledebur, Opinion 95-007.
The term "represent" is also broadly defined to prohibit acting on behalf of any
person in any activity. Examples of prohibited representation include: (1) personal
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April 20, 2012
Page 4
appearances before the former governmental body or bodies; (2) attempts to influence;
(3) submission of bid or contract proposals which are signed by or contain the name of
the former public official/public employee; (4) participating in any matters before the
former governmental body as to acting on behalf of a person; and (5) lobbying.
Popovich, Opinion 89-005.
Listing one's name as the person who will provide technical assistance on a
proposal, document, or bid, if submitted to or reviewed by the former governmental
body, constitutes an attempt to influence the former governmental body. Section
1103(g) also generally prohibits the inclusion of the name of a former public official/
public employee on invoices submitted by his new employer to the former governmental
body, even if the invoices pertain to a contract that existed prior to termination of service
with such governmental body. Shay, Opinion 91-012. However, if such a pre-existing
contract does not involve the unit where the former public employee worked, the name
of the former public employee may appear on routine invoices if required by the
regulations of the agency to which the billing is being submitted. Abrams/Webster,
Opinion 95-011.
A former public official/public employee may assist in the preparation of any
documents presented to his former governmental body. However, the former public
official/public employee may not be identified on documents submitted to the former
governmental body. The former public official/public employee may also counsel any
person regarding that person's appearance before his former governmental body. Once
again, however, the activity in this respect should not be revealed to the former
governmental body. The Ethics Act would not prohibit or preclude making general
informational inquiries to the former governmental body to secure information which is
available to the general public, but this must not be done in an effort to indirectly
influence the former governmental body or to otherwise make known to that body the
representation of, or work for, the new employer.
Section 1103(g) only restricts the former public official/public employee with
regard to representation before his former governmental body. The former public
official/public employee is not restricted as to representation before other agencies or
entities. However, the “governmental body with which a public official/public employee
is or has been associated” is not limited to the particular subdivision of the agency or
other governmental body where the public official/public employee had influence or
control but extends to the entire body. See, Legislative Journal of House, 1989
Session, No. 15 at 290, 291; Sirolli, Opinion 90-006; Sharp, Opinion 90-009-R.
The governmental body with which you would be deemed to have been
associated upon termination of your employment with Commonwealth Department B
would be Commonwealth Department B in its entirety, including but not limited to the D
Bureau. Therefore, for the first year following termination of your employment with
Commonwealth Department B, Section 1103(g) of the Ethics Act would apply and
restrict “representation” of a “person” before Commonwealth Department B.
Having established the above general principles, your specific questions shall
now be addressed.
In response to your first question, you are advised as follows. Section 1103(g) of
the Ethics Act would not prohibit you from purchasing an ownership interest in the Firm.
However, during the first year following termination of your employment with
Commonwealth Department B, Section 1103(g) of the Ethics Act would prohibit you
from engaging in any activity(ies) that would involve prohibited representation before
Commonwealth Department B as set forth above. Section 1103(g) of the Ethics Act
would prohibit you from being identified as an owner or employee of the Firm when the
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April 20, 2012
Page 5
Firm would be soliciting new contracts with Commonwealth Department B as such
would necessarily involve prohibited representation before Commonwealth Department
B.
With regard to your second and third questions, you are advised as follows.
Section 1103(g) of the Ethics Act would not prohibit you from working on
Commonwealth Department B projects during the first year following termination of your
employment with Commonwealth Department B subject to the condition that in so
doing, you would not engage in prohibited representation before Commonwealth
Department B. Section 1103(g) of the Ethics Act would prohibit you from
communicating with Commonwealth Department B personnel regarding project matters
and would prohibit you from being identified as someone who completed a form or
notarized a document when your name would be seen by Commonwealth Department
B personnel as such would necessarily involve prohibited representation before
Commonwealth Department B.
You are further advised that during the one-year period of applicability of Section
1103(g) of the Ethics Act, as a general rule, your name could not be listed on invoices
submitted to Commonwealth Department B by the Firm. However, if you would perform
work for the Firm on Commonwealth Department B contracts that existed before you
terminated employment with Commonwealth Department B, and if such contracts would
not involve the “unit” of Commonwealth Department B where you formerly worked,
specifically, the D Bureau, your name could appear on routine invoices submitted to
Commonwealth Department B as to those particular pre-existing contracts if required by
the regulations of Commonwealth Department B. See, Abrams/Webster, supra.
However, the foregoing is limited to the submission of billing hours. The ability to
include your name on invoices subject to the aforesaid conditions would not impact the
applicability of Section 1103(g) of the Ethics Act as to other activities.
Your fourth question is general and has been addressed above to the extent that
it can be addressed.
As to your fifth question, you are advised as follows. During the period of
applicability of Section 1103(g) of the Ethics Act, it would appear to be impossible, as a
practical matter, for you to work for the Firm on local, non-Commonwealth Department
B projects without running afoul of Section 1103(g) when Commonwealth Department B
would have oversight responsibility to ensure compliance with state and federal laws
and a person from Commonwealth Department B might see your name as someone
who completed a form or notarized a document.
In response to your sixth question, you are advised as follows. Section 1103(g)
of the Ethics Act would not prohibit you from being hired to perform work as a J by a
person whose L has been M by Commonwealth Department B. However, during the
first year following termination of your employment with Commonwealth Department B,
Section 1103(g) of the Ethics Act would prohibit you from submitting or acting to further
the submission of any information to Commonwealth Department B that would identify
you as the provider of N services to a person seeking reimbursement of N fees from
Commonwealth Department B under the K Code. Such identifying information would
include but would not be limited to your name and state N O.
You are advised that “acting to further the submission of information to
Commonwealth Department B that would identify you as the provider of N services”
would include but would not be limited to placing such identifying information on
document(s) that you know or reasonably expect will be submitted to Commonwealth
Department B.
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April 20, 2012
Page 6
During such times as Section 1103(g) of the Ethics Act would not be applicable
to you, Section 1103(g) would not restrict you from submitting information to
Commonwealth Department B that would identify you as the provider of N services to a
person, regardless of when such services were provided.
Based upon the facts that have been submitted, this Advice has addressed the
applicability of Section 1103(g) only. It is expressly assumed that there has been no
use of authority of office or employment, or confidential information received by being in
the public position, for a private pecuniary benefit as prohibited by Section 1103(a) of
the Ethics Act. Further, you are advised that Sections 1103(b) and 1103(c) of the Ethics
Act provide in part that no person shall offer or give to a public official/public employee
and no public official/public employee shall solicit or accept anything of monetary value
based upon the understanding that the vote, official action, or judgment of the public
official/public employee would be influenced thereby. Reference is made to these
provisions of the law not to imply that there has been or will be any transgression
thereof but merely to provide a complete response to the question presented.
Lastly, the propriety of the proposed conduct has only been addressed under the
Ethics Act; the applicability of any other statute, code, ordinance, regulation or other
code of conduct other than the Ethics Act has not been considered in that they do not
involve an interpretation of the Ethics Act. Specifically not addressed herein is the
applicability of the P.
Conclusion:
As an A for Commonwealth Department B, you would be
considered a "public employee" subject to the Public Official and Employee Ethics Act
(“Ethics Act”), 65 Pa.C.S. § 1101 et seq., and the Regulations of the State Ethics
Commission, 51 Pa. Code § 11.1 et seq. Upon termination of your employment with
Commonwealth Department B, you would become a "former public employee" subject
to Section 1103(g) of the Ethics Act. The former governmental body would be
Commonwealth Department B in its entirety, including but not limited to the D Bureau.
For the first year following termination of your employment with Commonwealth
Department B, Section 1103(g) of the Ethics Act would apply and restrict
“representation” of a “person” before Commonwealth Department B. The restrictions as
to representation outlined above must be followed. Lastly, the propriety of the proposed
conduct has only been addressed under the Ethics Act.
Pursuant to Section 1107(11) of the Ethics Act, an Advice is a complete defense
in any enforcement proceeding initiated by the Commission, and evidence of good faith
conduct in any other civil or criminal proceeding, provided the requester has disclosed
truthfully all the material facts and committed the acts complained of in reliance on the
Advice given.
This letter is a public record and will be made available as such.
Finally, if you disagree with this Advice or if you have any
reason to challenge same, you may appeal the Advice to the full
Commission. A personal appearance before the Commission will be
scheduled and a formal Opinion will be issued by the Commission.
Any such appeal must be in writing and must be actually
received at the Commission within thirty (30) days of the date of this
Advice pursuant to 51 Pa. Code § 13.2(h). The appeal may be
received at the Commission by hand delivery, United States mail,
delivery service, or by FAX transmission (717-787-0806). Failure to
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April 20, 2012
Page 7
file such an appeal at the Commission within thirty (30) days may
result in the dismissal of the appeal.
Sincerely,
Robin M. Hittie
Chief Counsel