Loading...
HomeMy WebLinkAbout1606 Kirkwood In Re: Mark Kirkwood, : File Docket: 10-048 Respondent : X-ref: Order No. 1606 : Date Decided: 9/24/12 : Date Mailed: 10/5/12 Before: John J. Bolger, Chair Donald M. McCurdy, Vice Chair Raquel K. Bergen Nicholas A. Colafella Mark Volk Mark R. Corrigan This is a final adjudication of the State Ethics Commission. Procedurally, the Investigative Division of the State Ethics Commission conducted an investigation regarding possible violation(s) of the Public Official and Employee Ethics Act (“Ethics Act”), 65 Pa.C.S. § 1101 et seq., by the above-named Respondent. At the commencement of its investigation, the Investigative Division served upon Respondent written notice of the specific allegation. Upon completion of its investigation, the Investigative Division issued and served upon Respondent a Findings Report identified as an “Investigative Complaint.” An Answer was filed and a hearing was requested. A Stipulation of Findings and a Consent Agreement waiving an evidentiary hearing were subsequently submitted by the parties to the Commission for consideration. The Stipulated Findings are set forth as the Findings in this Order. The Consent Agreement has been approved. I.ALLEGATIONS: That Mark Kirkwood, a public official/public employee in his capacity as a Board Member of the New Castle Area School District, violated Section 1103(a) of the State Ethics Act (Act 93 of 1998), 65 Pa.C.S. § 1103(a), when he used the authority of his public position for the private pecuniary benefit of himself and/or a member of his immediate family to obtain college credits for his son at reduced costs thereby enabling the son to receive an athletic scholarship. II.FINDINGS: 1. Mark Kirkwood has served as a Member of the New Castle Area School District Board of Directors (hereafter “Board”) from approximately 2003 to the present. a. Kirkwood has served as Vice President of the Board from approximately 2010 to the present. b. Kirkwood has served as a Member of the following Board committees during his tenure as a Board Director: Athletic, Building & Grounds, Finance, Education, and Personnel. Kirkwood, 10-048 Page 2 2. New Castle Area School District (hereafter “District”) is governed by a nine Member Board of Directors. a. District legislative meetings are held on the second Wednesday after the first Monday of the month. b. Caucus meetings are held on the Monday before the Wednesday legislative meeting. c. Committee meetings and special meetings are held as necessary. 3. Voting at District meetings occurs via either individual or roll call vote. a. Abstentions or objections are specifically noted in the minutes. 1. Minutes of each meeting are approved for accuracy at the subsequent meeting held. 4. The Board of Directors receives informational packets as early as the Friday before the Monday caucus meeting regarding situations, issues, events, etc., which have occurred since the last legislative meeting. a. The packets are developed by the Superintendent, Assistant to the Superintendent, and the Business Manager. 1. The information is compiled and organized by District administrative assistant(s) to the Superintendent/Assistant Superintendent. b. The packets include information such as the caucus meeting agenda, the Superintendent’s report, the Business Manager’s report, support documentation related to items on the agenda, etc. 1. Informational handouts (not included in the prepared packets) are occasionally provided at caucus meetings to the Board Directors in attendance. 2. Board Directors absent from caucus meetings are provided the handouts that were distributed during their absence, upon request. 5. The Board of Directors vote to approve a listing of bills at each legislative meeting. a. The listing of bills approved represents those bills received by the District since the last legislative meeting. 6. District signature authority is maintained by the Business Manager. 7. Seton Hill University (hereafter “SHU”) is an accredited university located at One Seton Hill Drive, Greensburg, PA 15601. a. SHU has been providing college level education within the Commonwealth since 1918. 8. SHU has been partnered with school districts located within the Commonwealth in order to provide the College in High School Program (hereafter “CIHSP”) to eligible high school students. Kirkwood, 10-048 Page 3 a. The purpose of the CIHSP is to provide high school students the opportunity to earn SHU college credits at a reduced cost through completion of specifically approved high school classes. 1. SHU’s fee for students enrolled at the university was approximately $705.00 per credit in 2010. 2. The fee for high school students participating in the CIHSP is $220.00 per course regardless of the number of credits assigned to the course. 9. Eligibility requirements for high school students interested in the CIHSP are as follows: a. Participants must be a currently enrolled junior or senior high school student with the district offering the program. 1. High school graduates and/or high school dropouts are not eligible to be enrolled in the program. 2. Kirkwood purports that he and his son, Matt Kirkwood, were not made aware that high school graduates and/or high school drop outs were not eligible to be enrolled in the program at the time Matt Kirkwood entered the program at New Castle High School. a. Respondent maintains that he was later made aware that the program was only for high school students, currently in school, by letter dated March 25, 2011. b. Students must be able to fulfill graduation requirements by the end of [their] senior year based upon the credits earned and required courses completed/scheduled. 1. Kirkwood purports that he and his son, Matt Kirkwood, were not made aware of this requirement at the time Matt Kirkwood entered the program. c. Students must have demonstrated a proficiency in reading, writing, and mathematics through tenth grade. d. Students must have demonstrated the ability and readiness for college level coursework in the course(s) being offered by the school district/SHU as CIHSP course(s). e. Students must have received a recommendation from the prerequisite teacher to the CIHSP course confirming the student has the capabilities to take the CIHSP course. 10. High school junior[s] and seniors who have not demonstrated a proficiency in reading, writing, and mathematics through tenth grade and/or have not received a recommendation from their prerequisite teacher can still be enrolled in a CIHSP course if the following criteria is met: a. The student is a high school junior with a cumulative grade point average of 3.5 or better. b. The student has demonstrated exceptional ability in a content area and has the recommendation of the high school principle, his/her guidance Kirkwood, 10-048 Page 4 counselor, and has demonstrated proficiency on the most-recently administered PSSA (Pennsylvania System of School Assessment) exam. 11. The CIHSP requires that students maintain a grade point average of 3.0 and maintain a minimum grade of a C (2.0) in each CIHSP course in which they are enrolled. a. Students who do not meet this requirement are not eligible to receive the SHU college credits associated with the course(s) in which they were enrolled. b. There are no exceptions to this requirement. 12. Beginning in or about January 2010 District Assistant Superintendent/Director of Curriculum Terence Meehan initiated contacts with SHU officials regarding the District establishing a program of college level classes for students through SHU. a. On January 14, 2010, and January 15, 2010, Meehan engaged in a series of emails with SHU officials Mary Ann Gawelek, Education Department Provost and Terry DePasquale, Dean of Graduate and External Programs. b. Meehan’s emails inquired about a partnership between the District and SHU regarding dual enrollment funding. 13. DePasquale informed Meehan on or about January 22, 2010, that SHU would be interested in partnering with the District to provide the CIHSP. a. SHU’s interest was contingent upon the District meeting the requirements related to the CIHSP. 14. Marlane Busch, Administrative Assistant, Graduate and External Programs, SHU, emailed Meehan a copy of SHU’s generic dual enrollment agreement and a copy of the CIHSP handbook on January 22, 2010, at 10:40 a.m. a. Included within the CIHSP handbook, among other information, is the following: Seton Hill University is working together with High Schools to offer eligible students the opportunity to earn college credits while in high school through the College in High School program. College in High School provides students with the opportunity to get a head start on their college degree while still in high school. And, the program helps students make a smooth and successful transition to college by giving then [sic] a preview of college-level academic work. 15. Meehan issued a memo titled “Board Approval for College in High School” to District Superintendent George Gabriel on February 5, 2010. a. Meehan informed Gabriel in the memo that Board action was required to enter into an agreement with Seton Hill University to provide a College in High School Program for recommended students in grades eleven and twelve. b. Meehan specified in his memo that the program was for recommended District students in eleventh and twelfth grade. Kirkwood, 10-048 Page 5 c. Gabriel was aware of Meehan’s intentions to implement the SHU CIHSP prior to receipt of the February 5, 2010, memo via day-to-day conversations he had with Meehan. 16. Meehan presented a PowerPoint presentation to the Board related to the CIHSP at the February 8, 2010, Board caucus meeting. a. It was at this meeting that the Board was first made aware of Meehan’s proposal to have SHU’s CIHSP implemented by the District. b. Kirkwood was present for the February 8, 2010, meeting. c. Meehan provided a handout to Board Members explaining the PowerPoint presentation. 1. Kirkwood was provided with the handout explaining the PowerPoint presentation at the February 8, 2010, meeting. 17. At its February 16, 2010, legislative meeting, the Board voted 8-0 to approve the written agreement between the District and SHU to provide the CIHSP during the 2010-2011 school year. a. Kirkwood was not present at the February 16, 2010, meeting. b. Although Kirkwood was not present at the February 16, 2010, meeting, he received a copy of the memo entitled “Board Approval for College in High School” and the agreement between the District and SHU. 18. The agreement approved by the Board at the February 16, 2010, meeting mandated eligibility requirements for District students interested in the CIHSP as follows: a. The student must be a high school junior or senior. b. The student must fulfill graduation requirements by the end of his/her senior year based upon credits earned and required course(s) completed/scheduled. c. The student must have demonstrated proficiency in reading, writing, and mathematics through grade ten. d. The student must have demonstrated the ability and readiness for college- level coursework in the intended area of study. e. The student must have the recommendation of the Honors level prerequisite teacher(s). f. A student must maintain a grade point average of 3.0 and maintain a minimum grade of C (2.0) in each CIHSP course in order to remain in the program. 19. The agreement further provided that students not meeting the criteria were permitted to enroll in CIHSP courses upon meeting the following alternative criteria and receiving approval from both SHU and from the District: a. The student is a junior with a cumulative grade point average of 3.5 or better. Kirkwood, 10-048 Page 6 b. The student has demonstrated exceptional ability in a content area and has received the recommendation of the High School principal, his/her guidance counselor, and has demonstrated proficiency on the most-recently administered PSSA exams. c. A student must maintain a grade point average of 3.0 and maintain a minimum grade of C (2.0) in each CIHSP course in order to remain in the program. 20. The agreement specifically required that the students enrolled in the CIHSP be either high school juniors or seniors. a. The agreement further stipulated that the CIHSP was to begin at the start of the 2010-2011 school year. 1. The Board’s approval made no reference to the CIHSP beginning during the summer of 2010. 2. No formal presentation was made to the Board indicating that program initiated during the summer of 2010. 21. DePasquale of SHU and Meehan exchanged multiple email communications between February 23, 2010, and March 22, 2010, regarding the District’s status related to meeting the requirements of the CIHSP. a. Topics addressed included: 1. District teachers and courses selected by Meehan to be associated with the CIHSP; 2. SHU’s approval of District teachers and course material; 3. A date for DePasquale to visit the District to address the District teachers associated with CIHSP in order to prepare them for the approval process associated with the program; and 4. Target dates for the District to begin registering students for the program. 22. Correspondence from Meehan addressed to District parents/guardians issued on or about March 11, 2010, indicated the following: Dear Parent/Guardians: Enclosed you will find a preview of our College Preparatory Program. Along with this is a letter informing you of the advanced level course(s) that your child has been recommended. We will soon begin the process of selecting courses for the 2010-2011 school year. The courses listed on the recommendation list are only open to students who have demonstrated exceptional achievement in prior study leading to these courses; I commend your child for their academic focus. I also congratulate you as parents of these fine students for your motivation in support in their education. These recommendations are made with great attention to the student and their overall achievement and promise for continued, in-depth study. Kirkwood, 10-048 Page 7 The courses that your child has been recommended are being considered for a partnership with Seton Hill University for College in High School. This will result in your child receiving and [sic] academic transcript from Seton Hill and the opportunity to earn college credits for these courses. The courses will be monitored by Seton Hill University to ensure that they are presented with the same rigor and intensity of a true college course. The enclosed booklet illustrates the potential credits that your child can earn and the Seton Hill course that our courses are being matched. This is a tremendous opportunity for our advanced students. Your child is not required to enroll in these courses, but we do want you to be aware that their teachers believe they will succeed at this level. Please discuss this with your child and plan an appropriate course load for next year. It is important to experience advanced study, but it is also important not to overload the student with too many demanding courses. Please give great consideration to the course selection process. If you have any questions regarding the course selection process or the College in High School Program, please feel free to contact me at (724) 656-4759. Your child’s guidance counselor can also assist with the process. It is our goal to make certain that your child has every opportunity to succeed and have the necessary foundation to experience continued success at the college level. Sincerely, Terence P. Meehan a. Indicated in Meehan’s correspondence was that the CIHSP was to begin during the 2010-2011 school year. 23. As of May 17, 2010, SHU approved District teachers/courses as part of the CIHSP to begin during the 2010-2011 school year, as shown below. a. The approved teachers were Jeff Shaftic, Kelly Evanoski, Teresa Emery, Susan Harlan, William Bradley, and Frank Mantinaos. b. Only approved District teachers/course material were to be associated with the CIHSP. 24. A brochure developed by the School District and provided District families included information regarding the costs of college credits and the costs per course for District students enrolled in the CIHSP. a. The brochure was prepared by or at the direction of Meehan. b. The brochure noted the following regarding costs per credit hour and course: Seton Hall: $720 per credit for (1) to (11) credits. CIHSD: $220 per course for (3) or (4) credit course. c. The brochure noted that the District received a grant to offset some of the $220/course costs to $102.76 per course and offered a payment plan as follows: Down-payment in the amount of $30.76 (per course) is due September 14, 2010. Kirkwood, 10-048 Page 8 Payment of $24.00 per course is due by October 15, 2010. Payment of $24.00 per course is due by November 15, 2010. Final payment of $24.00 per course is due by December 15, 2010. 25. Matt Kirkwood graduated from New Castle Area School District on June 1, 2008. 26. Matt Kirkwood was enrolled as a student at Shelton State Community College from the fall of 2008 to the spring of 2010. a. Shelton State Community College is a two-year junior college located in the state of Alabama. b. Matt Kirkwood played baseball for Shelton State Community College during his tenure there. 27. In or about the spring/summer of 2010, Matt Kirkwood was interested in transferring to Cleveland State University located in Ohio. a. Kirkwood was aware that Cleveland State was interested in recruiting his son to play baseball. b. Cleveland State offered Matt Kirkwood an athletic scholarship valued at eighty-five percent of the cost of tuition for two years to play baseball for the college beginning in or about the fall of 2010. c. The minimum total value of a full-time (out of state) transfer student’s tuition at Cleveland State was $7,884.00 in the fall of 2010. d. The approximate value of the scholarship was $6,701.40. 1. Eighty-five percent of $7,884.00 is $6,701.40 (7,884 x .85 = 6,701.40). 28. Kirkwood became aware during or about the spring/summer of 2010 that his son needed six additional college credits to transfer from Shelton State Community College to Cleveland State. a. The credit requirement did not limit Matt Kirkwood to obtain the credits in any specific subject matters. 29. Kirkwood, on or about June 24, 2010, informed Meehan of Matt Kirkwood’s opportunity to obtain an athletic scholarship upon transfer from Shelton State Community College to Cleveland State, but that his son needed six credits to complete the transfer. a. Kirkwood approached Meehan about his son’s situation after being informed by Butler Community College that enrollment for summer courses had already ended. 1. Kirkwood initially approached Meehan to determine if Meehan had any contacts that could assist his son in obtaining the college credits. Kirkwood, 10-048 Page 9 b. Kirkwood informed Meehan of Matt Kirkwood’s opportunity after a District meeting that required Kirkwood and Meehan to attend in their official capacities. 1. The conversation took place in the hallway outside of the meeting room. 2. Kirkwood and Meehan do not socialize outside of District related functions. c. Kirkwood asked Meehan whether or not Mr. Meehan could help him to obtain six (6) additional credits for his son during the summer months. d. Kirkwood indicated to Meehan that he had already checked with Butler County Community College but it was too late to enroll into the summer courses. 30. Meehan advised Kirkwood that he would look into the matter. 31. Meehan, in his capacity as a District official, sent an email to DePasquale on June 24, 2010, at 1:03 p.m. informing DePasquale of Kirkwood’s request and requesting approval from SHU to offer the CIHSP courses as follows: Hi Terry We are very pleased to learn our Expository Comp. class has been approved. I assure you this course is the true essence of a college level course in high school. I have a request from a board member here and wondered if it would be possible on your end. His son needs 6 college credits for an athletic scholarship. Would we be able to offer 2 of our approved courses to him over the summer with us compensating our teachers for him to earn these 6 credits? I am thinking it would be the Expository Comp course and possibly the US History. If we can do this and the family pays the administrative fee to Seton Hill, could we get him the transcript with the 6 credits? I realize he would need to register etc. with Seton Hill. This could provide me a run through on that process before I begin the larger group in the fall. If we can do this, I assure you that the workload will be the same syllabus that was presented to Seton Hill for approval, we will have an ALL AM and ALL PM meeting for him at our High School and the district will compensate the teachers. Please let me know if this is possible. Thanks so much for everything, I look forward to working with you on our registrations and the dual enrollment distribution of funds. Terry a. Mr. Meehan alleges that he told Mr. Kirkwood that he would use the CIHSP program during the summer as a trial run, and if successful, he would like to make the program available to all New Castle High School graduates who are college students needing summer college credits. Kirkwood, 10-048 Page 10 1. The New Castle Area School Board never discussed utilizing the CIHSP program for New Castle High School Graduates who were college students, and the program has not been utilized for any other New Castle High School graduate. 32. Meehan informed DePasquale that the program would run during the summer of 2010. a. The Board approved the program to being [sic] during the 2010-2011 school year. b. Meehan assured DePasquale that the student “workload” would not be limited. 1. DePasquale was of the understanding based on Meehan’s email that the courses presented to the student would not be altered or reduced in substance and time. c. Meehan’s email specifically noted Kirkwood’s position as a Board Member. 33. DePasquale responded to Meehan via email on June 24, 2010, at 2:15 p.m. advising Meehan that SHU did not object to the CIHSP beginning during the summer of 2010. a. DePasquale did not oppose Meehan’s request due to Meehan’s assertions that: 1. The student(s) to be enrolled were eligible high school student(s); 2. The teacher(s)/course(s) to be provided during the summer program had been previously approved by SHU; and 3. The approved course material would be unaltered and presented in its entirety. 34. Meehan and Kirkwood had a telephone conversation around the time that Meehan emailed DePasquale on June 24, 2010. a. Kirkwood advised Meehan of what college classes his son had already taken so that Meehan could determine what CIHSP classes could be offered to Matt Kirkwood during the summer of 2010. 35. In late June 2010, Meehan partially completed a SHU CIHSP registration form on behalf of Matt Kirkwood. a. SHU required the completion of registration forms in order to enroll students in the CIHSP. 36. The top of the registration form reflects that the CIHSP is a program for high school students. The form notes the following: Seton Hill University and your High School are working together to offer eligible students the opportunity to earn college credits while in high school through the College in High School (CHS) program. Register for one or more of the approved courses and upon successful completion of each course, you will receive college credit from Seton Hill University. Kirkwood, 10-048 Page 11 37. The portion of the form Meehan completed on behalf of Matt Kirkwood indicated that Matt Kirkwood would be enrolling in the CIHSP during the summer of 2010. a. Meehan identified the two classes and the two teachers that would be associated with Matt Kirkwood’s summer education as: 1. Teresa Emery - Plant Biology & Ecology 2. Frank Mantinaos - Calculus with Analytic Geometry b. Meehan also completed the grade level portion of the form on behalf of Matt Kirkwood. c. Meehan signed the form as the “the school liaison approving student enrollment.” 38.Matt Kirkwood went to the District Office to pick up the form for completion. a. Matt Kirkwood completed the remaining information required by the form. 39. Kirkwood was contacted by Meehan’s administrative assistant on June 28, 2010, to provide payment that day for his son’s participation in the CIHSP. a. Kirkwood hand delivered a personal check to Meehan’s administrative assistant in the amount specified by her on June 28, 2010. b. Meehan then forwarded the registration form and payment to SHU on or about June 30, 2010. 40. Kirkwood issued check no. 1301, dated June 28, 2010, payable [to] SHU in the amount of $440.00 from his personal account at Huntington Bank. a. The cost of each CIHSP course was $220.00. b. Kirkwood signed the check as the authorized signatory. 41. SHU received Matt Kirkwood’s registration form and payment on or about July 1, 2010. a. The registration form was processed, and the payment was deposited by SHU on or about July 1, 2010. 42. Meehan emailed Teresa Emery, District Biology teacher, on July 1, 2010, at 3:35 p.m. to gauge her interest in teaching the CIHSP Biology course in the summer of 2010, as indicated below: Teresa We have a student that needs a very condensed version of Bio (the plant and ecology part) presented to him this summer, so he can get college credits through Seton Hill. Would you be interested in working with him? We would set a specific number of hours and compensate you $25 per hour for your teaching. Kirkwood, 10-048 Page 12 Let me know, we have to start him right after the holiday to get enough information for the credit to count. Thanks T. Meehan a. Emery subsequently responded to Meehan’s inquiry advising him that she would be available to teach the CIHSP biology course during the summer of 2010. 1. Emery was one of the District teachers approved to teach the biology class. 43. Meehan informed Emery that the biology course should not exceed twelve hours of instruction. a. The CIHSP biology course was to run the entire school year exceeding well over twelve hours of instruction. 1. SHU’s requirement for classroom instruction is (15) hours for each credit or (45) hours for a three-credit course. b. Meehan informed Emery that she would be providing instruction to one student, Matt Kirkwood. 1. Meehan did not inform Emery that Matt Kirkwood is the son of a school board director. c. Meehan provided Emery’s cellular telephone number to Matt Kirkwood so that Emery and Matt Kirkwood could make the appropriate arrangements to meet and complete the classroom instruction. 1. Emery and Matt Kirkwood agreed to meet at Emery’s high school classroom for one hour on certain days of the week until the twelve hours of instruction were fulfilled. 44. Meehan on or about late June/early July 2010 had a discussion with District math teacher Frank Mantinaos regarding Mantinaos teaching the CIHSP calculus course during the summer of 2010. a. Mantinaos was one of the District teachers approved by SHU to teach the CIHSP calculus course. b. Mantinaos declined to participate due to having prior commitments arranged for the summer of 2010. 45. Meehan subsequently contacted District math teacher Sam Siciliano about teaching the CIHSP calculus course to Matt Kirkwood during the summer of 2010. a. Siciliano was not one of the District teachers initially approved by SHU to teach the CIHSP calculus course. b. Siciliano was subsequently approved by SHU to teach the CIHSP calculus course. c. Meehan informed Siciliano that the calculus course should not exceed twelve hours of instruction. Kirkwood, 10-048 Page 13 1. SHU’s requirement for classroom instruction is (15) hours per credit or (45) hours for a three-credit course. 2. The credit hours of instruction received by Matt Kirkwood were determined by SHU to be adequate for completion of the course. d. Meehan informed Siciliano that he would be providing instruction to one student, Matt Kirkwood. 1. Siciliano was aware that Matt Kirkwood was Kirkwood’s son and a graduate of the District. 46. Meehan provided Matt Kirkwood’s cellular telephone number to Siciliano so that Siciliano and Matt Kirkwood could make the arrangements to meet and complete the instruction. a. Siciliano and Matt Kirkwood agreed to meet at the high school for one hour on the same days of the week that Matt Kirkwood was to receive instruction from Emery until the twelve hours of instruction were fulfilled. 47. The syllabi approved by SHU related to the instruction for the CIHSP biology course detailed the various material to be covered during the 2010-2011 school year: a. The first and second nine week periods were considered CIHSP course BL 150 – General Biology I. 1. The course was considered a four credit course. aa. The classroom part of the course was considered three credits. bb. The lab part of the course was considered one credit. b. The third and fourth nine-week periods were considered CIHSP course BL 160 – General Biology II. 1. The course was considered a four credit course. aa. The classroom part of the course was considered three credits. bb. The lab part of the course was considered one credit. 2. CIHSP course BL 150 – General Biology I was a prerequisite to BL – 160 General Biology II. c. The [textbook approved by] SHU for the course was Campbell, Neil A. et al. th 2008, Biology, 8 ed., The Benjamin Cummings Publishing Company, New York. 48. The syllabi approved by SHU related to the instruction associated with the CIHSP calculus course detailed the material to be covered during the 2010-2011 school year: a. The calculus course (MA -130 Calculus with Analytic Geometry) was considered a four credit course. Kirkwood, 10-048 Page 14 b. The approved textbook by SHU for the course was Calculus by Elgin Johnson and Jerold Mathews (2002) ISBN 0-321-006682-8. 1. The textbook and syllabi utilized by Siciliano was not approved by SHU. 49. Matt Kirkwood received instruction in relation to the CIHSP courses during the time period of July 14, 2010, to August 3, 2010. a. Matt Kirkwood met with Emery and Siciliano for three hours each week during the four-week time period. b. Matt Kirkwood received a total amount of twelve hours of instruction from each CIHSP teacher (3 hours per teacher x 4 weeks = 12). 50. Matt Kirkwood was the only individual who received CIHSP teaching from any District teacher in the summer of 2010. 51. Graded course material completed by Matt Kirkwood related to the CIHSP biology course included a composition book in which Matt Kirkwood detailed what he had learned reading chapters 35 – 38, 40, 51 – 55 of Campbell, Neil A. et al. 2008, th Biology, 8 ed., The Benjamin Cummings Publishing Company, New York. a. Matt Kirkwood provided a four to eleven sentence long explanation as to what he learned from each chapter. b. Matt Kirkwood received a score of seventy-nine (79) out of eighty-five (85) for his efforts associated with the journal. c. No other graded material was maintained by the District in association with Matt Kirkwood completing the CIHSP biology course. 52. Graded course materials completed by Matt Kirkwood related to the CIHSP calculus course included two graded tests and homework. a. The first test consisted of eight handwritten problems to solve. 1. Matt Kirkwood scored an eighty (80) out of a possible one hundred points (100). b. The second test consisted of ten handwritten problems to solve. 1. Matt Kirkwood scored one-hundred (100) out of a possible one- hundred points (100). c. A handwritten piece of paper submitted by Siciliano to Meehan indicates that Matt Kirkwood scored a fifty (50) out of a possible fifty (50) points on his homework. 53. On or about August 9, 2010, the District forwarded to SHU the letter grades Matt Kirkwood received as a result of completing the CIHSP courses. a. The grades were forwarded to DePasquale’s administrative assistant. 54. Kirkwood asked Meehan to forward his son’s transcripts for completing the CIHSP courses sent to Cleveland State University. Kirkwood, 10-048 Page 15 55. On August 10, 2010, at 4:04 p.m., Terri Passerrello, Meehan’s Administrative Assistant, sent an email to DePasquale’s Administrative Assistant, Marlane Busch, advising Busch that Meehan wanted Matt Kirkwood’s SHU transcript sent to Cleveland State University and Kirkwood’s residence. a. Busch specified in her email where and to whom the transcript was to be addressed, as shown below: 1. Mr. Mark Kirkwood, [residence address]. 2. Cleveland State University, Winnie Lane, 2121 Euclid Avenue, Cleveland, Ohio 44115. b. The email was sent based on an inquiry by Kirkwood to Meehan as to whether or not the transcript had been sent. 56. On August 25, 2010, SHU issued an official SHU transcript for Matt Kirkwood to Cleveland State. a. The transcript reflected that Matt Kirkwood completed the biology and calculus CIHSP courses scoring a B in biology and an A- in calculus resulting in a cumulative GPA of 3.38. b. The transcript additionally reflected that Matt Kirkwood earned seven (7) SHU college credits. c. SHU did not forward a copy of the transcript to the Kirkwood residence. 57. As a result of Matt Kirkwood’s SHU transcript being forwarded to Cleveland State, Matt Kirkwood was able to transfer from Shelton State Community College and be enrolled as a full-time Cleveland State student starting in the fall of 2010. a. In addition, Matt Kirkwood received an athletic scholarship to play baseball for Cleveland State. 58. On August 25, 2010, Meehan issued a memo to District Business Manager Joseph Ambrosini requesting District payment to Emery and Siciliano for their services in relation to SHU/District CIHSP instruction of Matt Kirkwood during the summer of 2010, as shown below: Please release payment to the following teachers who have completed and submitted final copies of curriculum for AP courses (College in High School) courses written. Teachers are to be compensated at a rate of $25 per hour for their work. August 18, 19, 20 Theresa Emery…………………………………………….$300.00 Sam Siciliano……………………………………………...$300.00 Teacher sign-in sheets for the days worked are attached. 59. The District compensated Emery and Siciliano $337.59 each for their involvement in Matt Kirkwood’s CIHSP instruction. Kirkwood, 10-048 Page 16 a. The $300.00 was for the twelve hours of instruction at a rate of $25.00 per hour (25 x 12 = 300). b. The additional $37.59 accounted for Social Security (0.0765%), Unemployment Compensation (0.0206%), and Retirement (0.0282%) paid out by the District for the teachers in association with their time of instruction related to the CIHSP (300 x 0.1253 = 37.59). c. Emery and Siciliano received their respective payments on September 10, 2010. 1. Emery’s payment was received via District check D0051335. 2. Siciliano’s payment was received via District check D00511650. d. Both Emery and Siciliano’s $300.00 payment for instruction was coded as curriculum development on their check stubs. 60. Payments issued to Emery and Siciliano were approved by the Board during the meeting of October 13, 2010. a. The payments approved were part of the payroll totaling $1,319,178.37 issued in September 2010. 1. Individual checks were not listed as part of the payroll listing. b. Kirkwood was present at the October 13, 2010, meeting and voted to approve the payroll. 61. On or about October 29, 2010, Kirkwood was issued an invoice by the District for the compensation paid to Emery and Siciliano for the classes taught to Matt Kirkwood. a. Eligible high school students associated with the CIHSP were not required to remit payment to the District instructor costs. 1. No payment was required due to the instruction taking place during the normal days/hours of the school year. 62. District Business Manager Joseph Ambrosini issued a District invoice to Kirkwood on or about October 29, 2010, which provided the following: Dear Mr. and Mrs. Kirkwood Our records show you have an outstanding balance of $674.00 with our District. The following invoice is due at this time: 10-11-109 674.00 Reimbursement for College Credits Please make your check payable to the NEW CASTLE AREA SCHOOL DISTRICT. The mailing address is: New Castle Area School District Business Office 420 Fern Street New Castle, PA 16101 Kirkwood, 10-048 Page 17 If payment is not possible at this time or you need to discuss this matter with the Business Manager, please call 724-656-4771. 63. Kirkwood began remitting partial payments to the District related to invoice #10-11- 109 subsequent to receiving the Notice of Investigation from the State Ethics Commission. a. Kirkwood’s first payment was submitted to the District on February 16, 2011, in the form of US currency in the amount of $50.00. 1. Kirkwood issued his first payment to the District approximately three months after receipt of the invoice. 2. The District deposited Kirkwood’s payment of $50.00 on February 17, 2011. b. Kirkwood’s second payment was provided to the District on March 4, 2011, in the form of US currency in the amount of $75.00. 1. The District deposited Kirkwood’s payment of $75.00 on March 10, 2011. c. Kirkwood’s third payment [was] provided to the District on April 29, 2011, via personal check #1396 dated April 28, 2011, in the amount of $200.00. 1. The District deposited Kirkwood’s payment of $200.00 on May 4, 2011. d. No additional payments were made by Kirkwood between April 29, 2011, and June 9, 2011. 64. Kirkwood received correspondence from Ambrosini on or about June 9, 2011, advising Kirkwood that he owed the District a remaining balance of $349.00 in relation to Matt Kirkwood’s education as shown below: Dear Mr. and Mrs. Kirkwood Our records show you have an outstanding balance of $349.00 with our District. The following invoice is due at this time: 10-11-109 349.00 Reimbursement for College Credits Please make your check payable to the NEW CASTLE AREA SCHOOL DISTRICT. The mailing address is: New Castle Area School District Business Office 420 Fern Street New Castle, PA 16101 If full payment is not possible at this time or you need to discuss this matter with the Business Manager, please call 724-656-4771. a. Kirkwood’s previous payments of $50.00, $75.00, and $200.00 reduced the total owed to the District to $349.00 (674 – 50 – 75 – 200 = 349.00). Kirkwood, 10-048 Page 18 65. Kirkwood issued personal check no. 1416, dated August 26, 2011, payable to the District in the amount of $349.00 from his personal account at Huntington Bank. a. The check paid the remaining balance owed to the District that Kirkwood was first notified of on October 29, 2010. b. Kirkwood indicated in the memo section that the check was for “teacher balance.” c. Kirkwood signed the check as the authorized signatory. d. The District deposited Kirkwood’s payment on September 2, 2011, into the District’s general fund account (XXXXXXX7947) maintained at Huntington Bank. 66. At the conclusion of the 2010-2011 college baseball season, Matt Kirkwood was informed by Cleveland State that the baseball program would no longer be supported by the university. a. In order to continue playing baseball collegiately, Matt Kirkwood opted to transfer to Marshall University located in West Virginia at the conclusion of the spring 2011 semester at Cleveland State. b. The transfer necessitated that official transcripts from SHU be forwarded to Marshall University. 67. On or about March 24, 2011, Kirkwood received a billing statement and correspondence from DePasquale of SHU directing that Matt Kirkwood forward a payment in the amount of $4,935.00 to SHU for the cost of credits taken during the summer of 2010. DePasquale’s letter stated as follows: In summer 2010 you registered for and completed two (2) Seton Hall University courses through the College in High School program at New Castle High School. It has come to our attention that you were not a high school student when you took these courses and that you provided inaccurate information on the registration form by indicating th that you were in 12 grade. In fact, you were already in college at that time. The reduced tuition rate is provided only to high school students in schools affiliated with Seton Hill’s College in High School program. Therefore, you are being billed for the remainder of the tuition for the seven (7) credits earned through Seton Hill courses. The tuition rate for summer 2010 was $705.00 per credit which amounts to $4,935.00. You already paid $440.00 which will be considered partial payment. Enclosed is a bill from the University for $4,495.00 for the remainder of the tuition owed. The University must receive payment no later than April 29, 2011. If we do not receive full payment by that date, we will be forced to remove record of the credits from your transcript and will notify any institutions of higher education to which the transcript was sent of this decision. 68. Kirkwood subsequently contacted DePasquale about the correspondence and billing statement at which time DePasquale informed Kirkwood that the SHU credits Matt Kirkwood received in the summer of 2010 should not have been assessed at the CIHSP rate. Kirkwood, 10-048 Page 19 a. Due to his status as a college student, Matt Kirkwood should have been assessed the standard rate of SHU’s summer tuition for seven credits at the rate of $705.00 per credit. 69. From March 24, 2011, to August 4, 2011, Kirkwood made five payments to SHU totaling $4,495.00, representing payment for the credits Matt Kirkwood received from the CIHSP program. a. Kirkwood was given credit by SHU for the $440.00 previously paid to the School District for the two classes. b. Kirkwood paid the entire amount of $4,495.00 to Seton Hill College in full. c. Kirkwood paid all bills that were due and owing both to the New Castle Area School District and Seton Hill University. 70. Kirkwood realized a pecuniary gain when the District/SHU CIHSP program was used to assist Matt Kirkwood in obtaining college credits required to transfer from Shelton State Community College to Cleveland State in order to obtain an athletic scholarship with Cleveland State that would minimize the financial burden associated with Matt Kirkwood’s college education. III.DISCUSSION: As a Member of the New Castle Area School District (“District”) Board of Directors (“Board”) from approximately 2003 to the present, Respondent Mark Kirkwood, hereinafter also referred to as “Respondent,” “Respondent Kirkwood,” and “Kirkwood,” has been a public officialsubject to the provisions of the Public Official and Employee Ethics Act (“Ethics Act”), 65 Pa.C.S. § 1101 et seq. The allegation is that Respondent Kirkwood violated Section 1103(a) of the Ethics Act when he used the authority of his aforesaid public position for the private pecuniary benefit of himself and/or a member of his immediate family to obtain college credits for his son at reduced costs thereby enabling the son to receive an athletic scholarship. Pursuant to Section 1103(a) of the Ethics Act, a public official/public employee is prohibited from engaging in conduct that constitutes a conflict of interest: § 1103. Restricted activities (a)Conflict of interest.— No public official or public employee shall engage in conduct that constitutes a conflict of interest. 65 Pa.C.S. § 1103(a). The term "conflict of interest" is defined in the Ethics Act as follows: § 1102. Definitions "Conflict" or "conflict of interest." Use by a public official or public employee of the authority of his office or employment or any confidential information received through his holding public office or employment for the private pecuniary benefit of himself, a member of his immediate family Kirkwood, 10-048 Page 20 or a business with which he or a member of his immediate family is associated. The term does not include an action having a de minimis economic impact or which affects to the same degree a class consisting of the general public or a subclass consisting of an industry, occupation or other group which includes the public official or public employee, a member of his immediate family or a business with which he or a member of his immediate family is associated. 65 Pa.C.S. § 1102. Section 1103(a) of the Ethics Act prohibits a public official/public employee from using the authority of public office/employment or confidential information received by holding such a public position for the private pecuniary benefit of the public official/public employee himself, any member of his immediate family, or a business with which he or a member of his immediate family is associated. As noted above, the parties have submitted a Consent Agreement and Stipulation of Findings. The parties' Stipulated Findings are set forth above as the Findings of this Commission. We shall now summarize the relevant facts as contained therein. Respondent has served as a Member of the Board from approximately 2003 to the present. Respondent has served as Vice President of the Board from approximately 2010 to the present. The Board consists of nine Members. Beginning in or about January 2010, District Assistant Superintendent/Director of Curriculum Terence Meehan (“Meehan”) initiated contacts with officials of Seton Hill University (“SHU”) regarding establishing SHU’s “College in High School Program” (“CIHSP”) in the District. The CIHSP provides high school students the opportunity to earn SHU college credits at a reduced cost through completion of specifically approved high school classes. Participation in the CIHSP is only available to junior or senior high school students. High school graduates are not eligible to be enrolled in the program. Respondent was present at a February 8, 2010, Board caucus meeting when the Board was first made aware of Meehan’s proposal to have SHU’s CIHSP implemented by the District. Respondent was not present at the Board’s February 16, 2010, legislative meeting, when the Board voted 8-0 to approve the written agreement (“CIHSP Agreement”) between the District and SHU to provide the CIHSP during the 2010-2011 school year. However, Respondent received a copy of the CIHSP Agreement and a memorandum authored by Meehan, which indicated that the CIHSP was for recommended District students in eleventh and twelfth grade. The CIHSP Agreement specifically required that a student enrolled in the CIHSP be either a high school junior or senior. The CIHSP Agreement further stipulated that the CIHSP was to begin at the start of the 2010-2011 school year. The Board’s approval made no reference to the CIHSP beginning during the summer of 2010. Respondent’s son, Matt Kirkwood, graduated from New Castle Area School District in 2008. From the fall of 2008 to the spring of 2010, Matt Kirkwood was enrolled as a student at Shelton State Community College where he played baseball. In or about the spring/summer of 2010, Matt Kirkwood was interested in transferring to Cleveland State University located in Ohio. Cleveland State offered Matt Kirkwood an athletic scholarship valued at eighty-five percent of the cost of tuition for two years to play baseball for the college beginning in or about the fall of 2010. In the fall of 2010, the minimum total value of a full-time (out of state) transfer student’s tuition at Cleveland State was $7,884.00, such that the approximate value of the scholarship was $6,701.40. Kirkwood, 10-048 Page 21 During or about the spring/summer of 2010, Respondent became aware that his son needed six additional college credits to transfer from Shelton State Community College to Cleveland State. On or about June 24, 2010, Respondent approached Meehan after a District meeting that Respondent and Meehan were required to attend in their official capacities. Respondent asked Meehan whether Meehan could help him to obtain six additional credits for his son during the summer months. Respondent indicated to Meehan that he had already checked with Butler County Community College but it was too late to enroll in the summer courses. Meehan advised Respondent that he would look into the matter. This conversation took place in the hallway outside of the meeting room. Respondent and Meehan do not socialize outside of District related functions. On June 24, 2010, Meehan, in his capacity as a District official, sent an email to Terry DePasquale (“DePasquale”), Dean of Graduate and External Programs at SHU, requesting approval from SHU to offer the CIHSP courses to a Board Member’s son during the summer of 2010. Meehan assured DePasquale that the student “workload” would not be limited. DePasquale responded to Meehan via email later that same day, advising Meehan that SHU did not object to the CIHSP beginning during the summer of 2010. DePasquale did not oppose Meehan’s request due to Meehan’s assertions that the student(s) to be enrolled were eligible high school student(s); the teacher(s)/course(s) to be provided during the summer program had been previously approved by SHU; and the approved course material would be unaltered and presented in its entirety. On or about June 24, 2010, Respondent advised Meehan of what college classes his son had already taken so that Meehan could determine what CIHSP classes could be offered to Matt Kirkwood during the summer of 2010. Meehan alleges that he told Respondent that he would use the CIHSP program during the summer as a trial run, and if successful, he would like to make the program available to all New Castle High School graduates who are college students needing summer college credits. However, the Board never discussed utilizing the CIHSP program for New Castle High School Graduates who were college students, and the program has not been utilized for any New Castle High School graduate other than Matt Kirkwood. SHU required the completion of registration forms in order to enroll students in the CIHSP. In late June 2010, Meehan partially completed the SHU CIHSP registration form on behalf of Matt Kirkwood. The portion of the form that Meehan completed included identification of the CIHSP classes that Matt Kirkwood would be enrolling in during the summer of 2010 and the grade level of Matt Kirkwood. Fact Finding 67 includes a statement by DePasquale that Matt Kirkwood’s CIHSP registration form indicated that Matt Kirkwood was in twelfth grade. Matt Kirkwood completed the remaining information required by the CIHSP registration form. The top of the registration form reflects that the CIHSP is a program for high school students. Nevertheless, Respondent purports that he and Matt Kirkwood were not made aware that high school graduates were not eligible to be enrolled in the CIHSP at the time Matt Kirkwood entered the CIHSP at New Castle High School. In 2010 SHU’s fee for students enrolled at SHU was approximately $705.00 per credit. The fee for high school students participating in the CIHSP is $220.00 per course regardless of the number of credits assigned to the course. On June 28, 2010, Respondent was contacted by Meehan’s administrative assistant to provide payment that day for Matt Kirkwood’s participation in the CIHSP. On June 28, 2010, Respondent hand delivered to Meehan’s administrative assistant a personal check dated June 28, 2010, payable to SHU in the amount of $440.00 for two courses for Matt Kirkwood at $220.00 each. Meehan forwarded the registration form and payment to SHU Kirkwood, 10-048 Page 22 on or about June 30, 2010. The registration form was processed, and the payment was deposited by SHU on or about July 1, 2010. Meehan arranged for two District teachers (hereinafter referred to as the “CIHSP Teachers”) to teach the CIHSP biology course and calculus course to Matt Kirkwood during the summer of 2010. Meehan informed the CIHSP Teachers that their respective courses should not exceed twelve hours of instruction. During the time period of July 14, 2010, to August 3, 2010, Matt Kirkwood received a total of twelve hours of instruction from each of the CIHSP Teachers. Matt Kirkwood was the only individual who received CIHSP teaching from any District teacher in the summer of 2010. Although SHU’s requirement for classroom instruction is 15 hours per credit or 45 hours for a three-credit course, the credit hours of instruction received by Matt Kirkwood were determined by SHU to be adequate for course completion. On or about August 9, 2010, the District forwarded to SHU the letter grades Matt Kirkwood received as a result of completing the CIHSP courses. On August 10, 2010, Terri Passerrello, Meehan’s Administrative Assistant, sent an email to Marlane Busch (“Busch”), DePasquale’s Administrative Assistant at SHU, advising Busch that Meehan wanted Matt Kirkwood’s SHU transcript sent to Cleveland State University and Respondent’s residence. On August 25, 2010, SHU issued an official SHU transcript for Matt Kirkwood to Cleveland State. The transcript reflected that Matt Kirkwood completed the biology and calculus CIHSP courses and earned seven SHU college credits. As a result of Matt Kirkwood’s SHU transcript being forwarded to Cleveland State, Matt Kirkwood was able to transfer from Shelton State Community College and be enrolled as a full-time Cleveland State student starting in the fall of 2010. In addition, Matt Kirkwood received an athletic scholarship to play baseball for Cleveland State. On August 25, 2010, Meehan issued a memo to District Business Manager Joseph Ambrosini (“Ambrosini”) requesting District payment to the CIHSP Teachers for their services in relation to SHU/District CIHSP instruction of Matt Kirkwood during the summer of 2010. The District compensated each of the CIHSP Teachers in the amount of $337.59 for their involvement in Matt Kirkwood’s CIHSP instruction. Of this amount, $300.00 was for the twelve hours of instruction at a rate of $25.00 per hour, and the balance was for Social Security, Unemployment Compensation, and retirement. On the CIHSP Teachers’ check stubs, the payments for instruction were coded as curriculum development. On October 13, 2010, Respondent participated in the Board’s vote approving the September 2010 payroll, which included the aforesaid payments to the CIHSP Teachers for instructing Matt Kirkwood in the CIHSP. Individual checks were not listed as part of the payroll listing. Per the Stipulated Findings and Consent Agreement, following the initiation of this Commission’s investigation, Respondent was billed $674.00 by the District for the aforesaid compensation paid to the CIHSP Teachers for the classes taught to Matt Kirkwood, and $4,495.00 by SHU as the balance due for the SHU credits Matt Kirkwood received when he was not eligible for the reduced tuition rate provided to high school students through the CIHSP. Respondent made payment in full to those entities. The parties have stipulated that Respondent realized a pecuniary gain when the District/SHU CIHSP program was used to assist Matt Kirkwood in obtaining college credits required to transfer from Shelton State Community College to Cleveland State in order to obtain an athletic scholarship with Cleveland State that would minimize the financial burden associated with Matt Kirkwood’s college education. Kirkwood, 10-048 Page 23 Having highlighted the Stipulated Findings and issues before us, we shall now apply the Ethics Act to determine the proper disposition of this case. The parties' Consent Agreement sets forth a proposed resolution of the allegations as follows: 4. The Investigative Division will recommend the following in relation to the above allegations: a. That a transgression of Section 1103(a) of the Public Official and Employee Ethics Act, 65 Pa.C.S. §1103(a) occurred when the District/SHU CIHSP program was used to assist in Matt Kirkwood obtaining the college credits required to transfer from Shelton State Community College to Cleveland State in order to obtain an athletic scholarship with Cleveland State that would minimize the financial burden associated with Matt Kirkwood’s college education. 5. Following the initiation of the State Ethics Commission’s investigation, Mr. Kirkwood was billed $674.00 by the New Castle Area School District and $4,495.00 by Seton Hill University. Mr. Kirkwood made payment in full to those entities. Mr. Kirkwood further agrees to pay a portion of the costs of the investigation of this matter in the amount of $1,000.00 to be made payable to the Pennsylvania State Ethics Commission and forwarded to the Commission within six months of the issuance of the final adjudication in this matter. 6. Kirkwood agrees to not accept any reimbursement, compensation or other payment from New Castle Area School District representing a full or partial reimbursement of the amount paid in settlement of this matter. 7. The Investigative Division will recommend that the State Ethics Commission take no further action in this matter; and make no specific recommendations to any law enforcement or other authority to take action in this matter. Such, however, does not prohibit the Commission from initiating appropriate enforcement actions in the event of Respondent's failure to comply with this agreement or the Commission's order or cooperating with any other authority who may so choose to review this matter further. Consent Agreement, at 1-2. In considering the Consent Agreement, we accept the recommendation of the parties for a finding of a transgression of Section 1103(a) of the Ethics Act. Factually, Respondent, a District School Director, approached Meehan, a subordinate District employee, after a District meeting that Respondent and Meehan were required to attend in their official capacities, and solicited Meehan’s assistance in obtaining six additional college credits for his son, Matt Kirkwood, during the summer of Kirkwood, 10-048 Page 24 2010. This resulted in Meehan taking actions to enable Matt Kirkwood to participate in the District/SHU CIHSP despite the fact that Matt Kirkwood was not eligible to participate in the CIHSP and the CIHSP was not authorized by the Board to begin until the 2010-2011 school year. Respondent also participated in the Board’s vote approving the September 2010 payroll, which included the payments to the CIHSP Teachers for instructing Matt Kirkwood in the CIHSP. As a result of Respondent’s actions, Matt Kirkwood was able to obtain the college credits required to transfer from Shelton State Community College to Cleveland State in order to obtain an athletic scholarship with Cleveland State. The parties have stipulated that Respondent realized a pecuniary gain when the District/SHU CIHSP was used to assist Matt Kirkwood in obtaining college credits required to transfer from Shelton State Community College to Cleveland State in order to obtain an athletic scholarship with Cleveland State that would minimize the financial burden associated with Matt Kirkwood’s college education. We accept the parties’ recommendation and hold that a transgression of Section 1103(a) of the Ethics Act, 65 Pa.C.S. § 1103(a), occurred when the District/SHU CIHSP was used to assist in Matt Kirkwood obtaining the college credits required to transfer from Shelton State Community College to Cleveland State in order to obtain an athletic scholarship with Cleveland State that would minimize the financial burden associated with Matt Kirkwood’s college education. Following the initiation of this Commission’s investigation, Respondent was billed $674.00 by the District and $4,495.00 by SHU. Respondent made payment in full to those entities. As part of the Consent Agreement, Respondent has agreed to pay a portion of the costs of the investigation of this matter in the amount of $1,000.00 to be made payable to the Pennsylvania State Ethics Commission and forwarded to this Commission within six months of the issuance of the final adjudication in this matter. Respondent has also agreed to not accept any reimbursement, compensation or other payment from the District representing a full or partial reimbursement of the amount paid in settlement of this matter. We determine that the Consent Agreement submitted by the parties sets forth a proper disposition for this case, based upon our review as reflected in the above analysis and the totality of the facts and circumstances. Accordingly, per the Consent Agreement of the parties, Respondent Kirkwood is directed to make payment for a portion of the costs of the investigation of this matter, which payment is to be in the amount of $1,000.00 payable to the Pennsylvania State Ethics Commission and forwarded to this Commission within six months of the mailing date of this adjudication and Order. Per the Consent Agreement of the parties, Respondent Kirkwood is directed to not accept any reimbursement, compensation or other payment from the District representing a full or partial reimbursement of the amount paid in settlement of this matter. Compliance with the foregoing will result in the closing of this case with no further action by this Commission. Noncompliance will result in the institution of an order enforcement action. IV.CONCLUSIONS OF LAW: 1. As a Member of the New Castle Area School District (“District”) Board of Directors from approximately 2003 to the present, Respondent Mark Kirkwood (“Kirkwood”) Kirkwood, 10-048 Page 25 has been a public officialsubject to the provisions of the Public Official and Employee Ethics Act (“Ethics Act”), 65 Pa.C.S. § 1101 et seq. 2. Kirkwood transgressed Section 1103(a) of the Ethics Act, 65 Pa.C.S. § 1103(a), when the District/Seton Hill University “College in High School Program” was used to assist in Kirkwood’s son, Matt Kirkwood, obtaining the college credits required to transfer from Shelton State Community College to Cleveland State in order to obtain an athletic scholarship with Cleveland State that would minimize the financial burden associated with Matt Kirkwood’s college education. In Re: Mark Kirkwood, : File Docket: 10-048 Respondent : Date Decided: 9/24/12 : Date Mailed: 10/5/12 ORDER NO. 1606 1. As a Member of the New Castle Area School District (“District”) Board of Directors, Mark Kirkwood (“Kirkwood”) transgressed Section 1103(a) of the Public Official and Employee Ethics Act (“Ethics Act”), 65 Pa.C.S. § 1103(a), when the District/Seton Hill University “College in High School Program” was used to assist in Kirkwood’s son, Matt Kirkwood, obtaining the college credits required to transfer from Shelton State Community College to Cleveland State in order to obtain an athletic scholarship with Cleveland State that would minimize the financial burden associated with Matt Kirkwood’s college education. 2. Per the Consent Agreement of the parties, Kirkwood is directed to make payment for a portion of the costs of the investigation of this matter, which payment is to be in the amount of $1,000.00 payable to the Pennsylvania State Ethics Commission and forwarded to this Commission within six months of the mailing date of this Order. 3. Per the Consent Agreement of the parties, Kirkwood is directed to not accept any reimbursement, compensation or other payment from the District representing a full or partial reimbursement of the amount paid in settlement of this matter. 4. Compliance with paragraphs 2 and 3 of this Order will result in the closing of this case with no further action by this Commission. a. Non-compliance will result in the institution of an order enforcement action. BY THE COMMISSION, ___________________________ John J. Bolger, Chair