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In Re: Mark Krull, : File Docket: 11-017
Respondent : X-ref: Order No. 1609
: Date Decided: 9/24/12
: Date Mailed: 10/9/12
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 allegations. 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 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 Krull, a public official/public employee in his capacity as an Income
Maintenance Caseworker for the Department of Public Welfare, violated Sections 1103(a)
and 1104(a) of the State Ethics Act (Act 93 of 1998), 65 Pa.C.S. §§ 1103(a) and 1104(a),
when he used the authority of his public position and/or confidential information obtained
through his public position for the private pecuniary benefit of himself and/or a private
business with which he is associated to contact and contract, in a private capacity, with
applicants/clients of DPW seeking Social Security Disability (SSD) and Social Security
Income (SSI) benefits; and when he used the authority of his public position and/or
confidential information obtained through his public position in an attempt to contract, in a
private capacity, with applicants/clients of DPW seeking SSD and SSI benefits; when he
used the facilities and equipment and supplies of the Department of Public Welfare in
furtherance of his private business interest; and when he failed to file Statements of
Financial Interests for the 2006, 2007, 2008, 2009 and 2010 calendar years.
II.FINDINGS:
1. Mark Krull was employed by the Pennsylvania Department of Public Welfare
(hereafter “DPW”) from approximately January 11, 1982, to June 29, 2011.
a. Krull served as a DPW Income Maintenance Caseworker (job classification
#44720) from approximately January 11, 1982, to June 29, 2011.
Krull, 11-017
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1. Krull was transferred to the Disability Advocate Program (hereafter
“DAP”) division of DPW on February 7, 2005.
2. Krull was commonly referred to as a DPW DAP Caseworker/Advocate
from February 7, 2005, to June 29, 2011.
3. Krull, as a DPW DAP Caseworker/Advocate, maintained job
classification #44720.
b. Krull retired from DPW effective June 30, 2011.
2. The Position Description for Krull, certified by Krull on June 10, 2008, provided, in
part, the following purpose and description of duties:
a. Position Purpose: Provide services to help recipients with disabilities
through Supplemental Security Income (SSI) or Social Security Disability
Income (SSDI) application and appeal process. Determines eligibility for
LIHEAP.
b. Description of Duties:
Determines appropriateness of referrals
Process referrals from other agencies
Monitor client progress through SSI/SSDI application and appeal process
Manage a DAP caseload
Participates in evaluations and development of service plans
Procure and evaluate additional medical information as the basis for
decisions by Medical Review Team (MRT), Adjudication Administrative Law
Judges and Appeals Council.
May perform other DAP functions such as: counsel clients on benefits of
obtaining counsel, represent clients at SSA, testify and/or represent clients
at ALJ hearings.
3. DAP is a social service program that was established by DPW in 1985 to assist
DPW clients with disabilities through the Supplemental Security Income (“SSI”) and
Social Security Disability Insurance (“SSDI”) application and appeal process.
a. SSI and SSDI are federally funded programs that are administered and
regulated by the Social Security Administration (“SSA”).
1. SSI is a federally funded program designed to assist aged, blind, and
disabled individuals who have little or no income.
2. SSDI is a federally funded program designed to provide income
supplements to individuals who are physically restricted in their ability
to be employed.
4. DPW clients with disabilities who are recipients of cash assistance, Medicaid,
and/or food stamps are referred to a DAP Caseworker/Advocate by DPW County
Assistance Office eligibility workers.
a. Referrals may also be provided by other agencies, including but not limited
to the Mental Health Base Service Unit or SSA.
5. Procedures regarding the DAP are detailed in the DPW Supplemental Handbook,
Chapter 820, Disability Advocacy Program.
Krull, 11-017
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a. During interviews with DPW clients, DAP Caseworkers/Advocates are to
perform the following duties:
1. Explain their role in the process of assisting the DPW client.
2. Provide a DAP Contact Card to the DPW client.
3. Emphasize the benefits related to a DPW client receiving SSI and/or
SSDI.
4. Inform the DPW client that he/she may appoint the DAP
Caseworker/Advocate as their representative.
5. Assess the DPW client’s capabilities and determine if any family,
friends, or other social service agency personnel are available to
assist the DPW client with his/her SSI and/or SSDI application.
6. Generate notes/records to develop social, medical, and employment
histories related to DPW clients.
6. An Appointment of Representative Form (SSA 1696 form) must be completed if the
DPW client selects the DAP Caseworker/Advocate as his/her non-attorney
representative.
a. The completion of the SSA 1696 form authorizes the DAP
Caseworker/Advocate as the client’s appointed non-attorney representative
in matters related to the client’s claim with SSA.
b. DPW procedures require the DAP Caseworker/Advocate to complete the
waiver of fee section of the SSA 1696 form to waive the right to charge and
collect a fee for his/her representative services.
7. Pursuant to the DAP procedures, the DAP Caseworker/Advocate is to perform the
following during the SSI/SSDI application process to identify the specific disability
or disabilities:
a. Assist the DPW client in any interviews with SSA workers.
b. Assist the DPW client in completing the SSI/SSDI application (if necessary).
c. Assist the DPW client in completing the Appointment of Representative Form
(SSA form 1696) if not already completed.
d. Update the DAP Client Tracking and Reporting System.
e. Schedule follow-up appointments with DPW clients as needed to compile
medical documentation, attend consultative appointments, etc.
8. SSA either approves or denies the client for SSI/SSDI following submission of an
application.
a. If SSA approves the DPW client for SSI/SSDI the DAP Caseworker/Advocate
is to:
1. Update the DAP Client Tracking and Reporting System.
Krull, 11-017
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2. Notify the CAO (County Assistance Office) eligibility worker of the
DPW client’s approved status by completing the DPW PA 731 form.
b. If SSA denies the DPW client for SSI/SSDI the DAP Caseworker/Advocate is
to:
1. Interview the DPW client and discuss the SSI/SSDI appeal process.
2. Advise the DPW client of his/her right to have either the DAP
Caseworker/Advocate or an attorney represent him/her at his/her
appeal.
3. Provide DPW clients with the DPW approved Attorney Listing and
assist DPW clients in obtaining an attorney if desired.
4. Complete the Request for Hearing form, the Authorization to Disclose
Information to the SSA form and the Disability Report-Appeal form.
9. If the client does not have a non-DAP representative, the DAP
Caseworker/Advocate’s role during the appeal process is as follows:
a. Contact SSA to obtain copies of consultative examination reports, Social
Security denial letters, and justifications.
b. If needed, seek advice as to whether to pursue an appeal by forwarding the
SSA information and the DAP file to MRT (Medical Review Team) for review
and recommendation.
c. If requested, assist the client’s attorney to prepare for an Administrative Law
Judge hearing.
10. The Administrative Law Judge is an SSA official/attorney who conducts the first
step in the appeal process by conducting a face-to-face hearing with the DPW
client and his/her representative.
a. A DAP Caseworker/Advocate testifying on behalf of the DPW client was rare
and would usually occur by written testimony and even then only if the client
was represented by an attorney.
b. A DAP Caseworker/Advocate cannot testify on behalf of the DPW client if
the Caseworker/Advocate is designated as the DPW client’s representative.
c. Documentation can be provided to support the disability claim if requested
by the Administrative Law Judge or the DAP Caseworker/Advocate
determines it to be beneficial to the case.
11. The Administrative Law Judge then makes the determination to grant or deny
SSI/SSDI for the DPW client.
a. If the Administrative Law Judge approves the SSI/SSDI for the DPW client,
the DAP Caseworker/Advocate is to:
1. Update the DAP Client Tracking and Reporting System.
2. Notify the CAO worker of the outcome of the hearing by completing
DPW form PA 731.
Krull, 11-017
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b. If the Administrative Law Judge denies the applicant DPW client SSI/SSDI,
the applicant’s DAP Caseworker/Advocate and/or the attorney may review all
of the evidence to determine if an appeal to the Appeals Council is
warranted.
1. The Appeals Council is a review unit of the SSA which reviews the
decisions of the Administrative Law Judge.
2. The Appeals Council’s decision can be appealed by the DAP
Caseworker/Advocate to the US District Court.
12. Krull, in his position as a DAP Caseworker/Advocate, had access to DPW client
information.
a. DPW client information is confidential and to be used only for DPW
business.
13. SSA guidelines provide that representatives (whether they are attorneys or non-
attorneys) who have successfully represented clients with disabilities through the
SSI/SSDI application and appeal process can collect a fee from their clients for
services provided.
a. The permissible fee can total no more than 25% of past due benefits or
$6,000.00 (whichever is less).
b. DPW DAP Caseworkers/Advocates representing clients through the hearing
process are ineligible to receive this fee.
1. The DAP Caseworker Advocate completes the waiver of fee section
of the SSA 1696 form.
c. Any fees must be approved by the Administrative Law Judge.
14. Krull has been an enrolled member of SSA’s Direct Payment to Non-Attorney
Representatives Program (hereafter “NRP”) since January/February of 2009.
a. The program permanently extended the authority to withhold 25% of past-
due benefits and directly pay any authorized fees to eligible non-attorney
representatives under Titles II and XVI of the SSA.
1. Previous to the enactment of NRP only attorney representatives were
able to receive a direct pay authorized by SSA as a result of favorable
decisions.
2. Individuals enrolled in NRP who have received direct payments are
issued a 1099 MISC IRS composite form from SSA at the conclusion
of each year.
b. Non-attorney representatives who are not enrolled in the SSA’s NRP can
obtain payment directly from their clients instead of from SSA, only if
authorized by an Administrative Law Judge.
15. As a non-attorney representative, Krull fulfilled the following requirements to be
enrolled in SSA’s NRP:
Krull, 11-017
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a. Have a bachelor’s degree from an accredited institution of higher education
or at least four years of relevant professional experience and either a high
school diploma or General Education Development (“GED”) certificate;
b. Pass a written examination developed and administered by the SSA which
tests the knowledge of the relevant provisions of the Act and the most recent
developments in SSA and court decisions affecting Titles II and XVI of the
Act;
c. Secure and maintain continuous professional liability insurance or equivalent
insurance;
d. Undergo a criminal background check; and
e. Demonstrate ongoing completion of qualified courses of continuing
education including education regarding ethics and professional conduct,
which are designed to enhance professional knowledge in matters related to
entitlement to, or eligibility for, benefits based on disability under Titles II and
XVI of the Act.
16. Krull was considered a non-attorney representative while representing DPW clients
in his official capacity as a DPW DAP Caseworker/Advocate.
a. Krull, as a DAP Caseworker/Advocate, was not permitted to receive any fees
per SSA guidelines for his representation of DPW clients as their non-
attorney representative due to the completion of the waiver of fee section on
SSA form 1696.
b. DPW policies outlined in Chapter 820 of the DAP prohibited DAP
Caseworkers/Advocates from collecting fees for representing clients.
c. DPW did not require DAP Caseworkers/Advocates to be enrolled in SSA’s
NRP.
1. DPW did not have any policies in place that prohibited Krull from
becoming a member of SSA’s NRP.
2. Krull’s enrollment in NRP provided Krull the opportunity to obtain
direct fee payments from SSA rather than from clients.
3. Krull never received payment(s) from any clients.
17. Krull has been a registered member in the National Organization of Social Security
Claimants’ Representatives (hereafter “NOSSCR”) since on or about April 18, 2010.
a. NOSSCR was established in 1979 to provide attorney and non-attorney
representatives of SSI/SSDI claimants with information related to
successfully representing their claimants.
b. Krull as a DAP Caseworker/Advocate was not required by DPW to be
enrolled in NOSSCR.
c. Krull’s enrollment in NOSSCR served a dual purpose by benefiting Krull with
knowledge that could be used in his capacity as both a DPW DAP
Caseworker/Advocate and a private non-attorney Disability Advocate.
1. Krull personally paid for his enrollment/membership with NOSSCR.
Krull, 11-017
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18. Krull’s enrollment in SSA’s NRP and membership with NOSSCR occurred during a
time when Krull was contemplating retirement from DPW to pursue a career as a
private non-attorney Disability Advocate.
19. Krull took annual leave from May 12, 2010, through May 14, 2010, to attend the
nd
62 National NOSSCR Conference in New Orleans, Louisiana.
a. The conference occurred from May 12, 2010, through May 15, 2010.
1. Krull obtained information/training to assist his career as both a DPW
DAP Caseworker/Advocate and a future private non-attorney
Disability Advocate.
20. From as early as August 2010 Krull considered receiving payments from his DPW
clientele as their private non-attorney representative.
a. Krull emailed Nancy Shor, Executive Director, NOSSCR, on August 2, 2010,
to determine steps required in order to receive compensation from DPW
clients he intended to represent in a private capacity.
21. Krull identified himself, in his email to Nancy Shor, as a non-attorney disability
advocate representative participating in the NRP for an “organization.”
a. Krull did not inform Shor that he was employed by the Commonwealth of
Pennsylvania/DPW.
b. Krull indicated that he planned to retire in the near future from DPW with the
intention to continue to represent the clientele he established at DPW.
c. Krull informed Shor that he had waived the receipt of any fees to be paid to
him by his DPW clients for his representation during the time period that he
represented said clients through the unidentified “organization.”
1. Krull indicated that he waived the fees by completing the appropriate
section of the Appointment of Representative form (SSA form 1696).
d. Krull explained that most of his clients’ cases would not be adjudicated at the
time of his retirement.
e. Krull specifically inquired if he could re-submit the Appointment of
Representative forms for those DPW clients that he planned to represent
after his retirement with the expectation to receive payment.
22. Krull did not receive a response from Shor and/or NOSSCR.
23. On or about June 17, 2011, Krull sent an email to his supervisor, Francis
Rectenwald, to inform Rectenwald about his intentions of retiring from DPW.
a. Rectenwald responded to Krull’s email informing Krull to submit a formal
notice of retirement to Patricia Steinkopf, Southern District Director, DPW.
24. By the time Krull informed Rectenwald of his plan to retire, Krull had already
devised a business plan to establish a home-based sole proprietorship that
provided non-attorney disability advocacy services.
a. Krull named his business Krull and Associates, LLC.
Krull, 11-017
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1. Krull did not register the business with the Pennsylvania Corporation
Bureau nor did he file any Articles of Incorporation.
b. Krull’s business plan to generate clientele included having DPW colleagues
refer DPW clients to Krull and Associates, LLC and by independently
soliciting his own DPW clients.
1. While Krull had not implemented any other method of generating
clientele, he had planned to do outreach beyond DPW clients.
25. DPW clients contacted by Krull indicated that Krull spoke to them about his possible
private representation of them after his retirement.
a. These contacts occurred between January and June 2011.
b. Krull made his DPW clients aware of his intimate knowledge of their cases.
26. Krull discussed his fee with his DPW clients who verbally agreed to utilize Krull as
their private non-attorney representative.
a. Persons were told that would be the fee if Krull successfully represented
them, not to exceed twenty-five percent.
b. Krull’s clients were unsure if payment to Krull was required if they did not
receive favorable outcomes in their cases.
1. Krull advised all potential clients that any fee would be contingent and
would require the approval of an Administrative Law Judge.
27. On or about June 22, 2011, Krull issued a formal notice of retirement to Steinkopf
notifying DPW of his plan to begin his retirement on June 30, 2011.
a. Krull also made his DPW colleagues aware of his plan to retire during the
week of June 20, 2011.
1. Krull indicated to his colleagues that he was planning to begin his
own disability advocate business in the near future to assist
individuals through the SSI/SSDI application/appeals process.
2. Krull advised of his willingness to be referred DPW clients to his
business.
28. On or about June 24, 2011, Krull received a letter from Laura Macie-Nagy,
Allegheny County Assistance Office Human Resources Department Director, DPW,
[indicating] that Krull’s retirement had been accepted by DPW.
a. Krull’s final date of employment was scheduled for June 29, 2011.
29. On Friday, June 24, 2011, Rectenwald directed Krull to generate a contact letter to
a number of DPW clients identified by Rectenwald who might be eligible for DAP
assistance.
a. DPW utilizes a form letter to notify clients of such services.
1. Although a standard form letter can be used, Krull’s first approach
was to phone clients and provide the advice as to available services.
Krull, 11-017
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30. The content of the letter generated by Krull was altered to include information that
Krull would be available, in a private capacity, to assist clients with DAP. Krull’s
alteration included the following:
Important Note: June 29, 2011 will be my last day working as
a Disability Advocate.
However, beginning June 30, 2011 I will begin working
privately with clients who wish to apply for SSA
Disability benefits, doing all the things listed above as
well as to present cases at SSA ALJ hearings. If you’d
like help with your claim please let me know at the
“other” phone listed below.
31. The concluding paragraph was added by Krull with the intent to generate clientele
for Krull and Associates, LLC.
a. The “other” phone number listed on the correspondence was the business
telephone number for Krull and Associates, LLC.
32. Krull only had access to the DPW clients eligible for DAP assistance as a result of
his employment as a DPW Income Maintenance Caseworker.
a. The client information was personal and confidential and not available to the
public.
33. Krull prepared the contact letter throughout the course of his normal work hours.
34. On June 24, 2011, Beth Mikus, Income Maintenance Caseworker Supervisor, DPW,
observed correspondence on her desk authored by Krull.
a. This letter appeared to resemble a standard DPW correspondence issued to
DPW clients.
b. Mikus further noticed that at the end of the letter, additional information
related to Krull’s private business interests after retirement from DPW was
added.
35. Mikus immediately showed the letter to her supervisor, Susan Kretz, DPW Income
Maintenance Administrator, due to the nature of the information in Krull’s letter
related to Krull’s private endeavors.
a. Kretz reviewed the letter and informed Mikus that she also received a copy
of the letter.
b. Kretz attempted to reach her immediate supervisor, Bea Cleath, Manager,
Southern District Office, DPW, about the situation but was unsuccessful.
36. Kretz questioned the appropriateness of Krull informing his DPW clients that he
was retiring and that he could continue to represent them in a private capacity.
a. Kretz was aware that Krull was retiring to pursue a profession that would
allow him to represent clients in a private capacity.
b. Kretz was made aware of Krull’s retirement plan while conversing with Krull
shortly after he announced his retirement.
Krull, 11-017
Page 10
c. Krull did not request Kretz to refer DPW clients to his private business.
37. Kretz reviewed Krull’s work area that same day after DPW employees (including
Krull) had left for the day.
a. Kretz discovered forty-one letters authored by Krull enclosed in DPW
envelopes addressed to DPW clients on top of filing cabinets located at
Krull’s work space.
1. The forty-one letters were identical to the letter found by Mikus and
Kretz earlier that same day.
b. Kretz additionally found two of Krull’s DPW business cards that had his
DPW telephone number scratched out and replaced by the business
telephone number for Krull and Associates, LLC (412-212-1175).
38. Kretz secured the envelopes in her office and did not deposit them into the mail.
39. On Monday, June 27, 2011, Dave Householder, Human Resources representative,
DPW, contacted Harrisburg DPW’s legal office, informing it of the events of June
24, 2011.
a. DPW’s legal office advised that Krull be informed not to report to work on his
last day, Wednesday, June 29, 2011.
1. Krull had utilized annual leave on June 27, 2011.
40. Krull was contacted by Householder on June 27, 2011, and advised not to report to
work on June 28, 2011, and/or June 29, 2011, due to the letters composed by Krull
on June 24, 2011.
a. Householder informed Krull that his actions and events of June 24, 2011,
were being forwarded to the Pennsylvania State Ethics Commission for
review.
41. Prior to the time of his conversation with Householder, Krull ordered five-hundred
letterheads, five-hundred business cards, and five-hundred envelopes for Krull and
Associates, LLC from Minuteman Press of Allison Park.
42. Krull ceased business activities as Krull and Associates, LLC, after his conversation
with Householder.
a. DPW clients who considered utilizing Krull and Associates, LLC, for DAP
representation, made attempts to contact Krull in or about late June 2011 to
further discuss their business arrangements.
1. Krull ended all contact with DPW clientele by ceasing any
communication with them.
b. DPW clients who were to utilize Krull and Associates, LLC, contacted DPW
for assistance in contacting Krull.
1. DPW informed the clients that Krull was no longer employed by DPW.
c. Communication between Krull and Associates, LLC and DPW clients ceased
at or about the time Krull left Commonwealth employment on June 28, 2011.
Krull, 11-017
Page 11
43. Krull’s 2011 IRS tax filings reflected no IRS 1099 MISC composite form from SSA
documenting any payment received by Krull.
a. Krull received no direct or indirect compensation from DPW clients for
representation.
b. Krull did not represent any DPW clients as a private disability representative
at any SSA functions.
c. Krull and Associates, LLC did not represent any DPW clients at any SSA
functions.
44. Krull and Associates, LLC was not listed on Krull’s 2011 Federal tax filing Schedule
C “Profit or Loss from Business.”
a. Krull and Associates, LLC was never operational and ceased to exist by the
end of June 2011.
b. Krull and Associates, LLC was never operational and conducted no
business.
45. On April 12, 2012, Krull provided a sworn statement to Commission investigators, at
which time Krull stated the following:
a. In 2009/2010 Krull began to contemplate the idea of providing private
disability advocacy services after retirement.
b. In approximately January/February 2009 Krull applied to be enrolled in
SSA’s direct pay program.
c. Krull’s membership with NOSSCR and his attendance at the NOSSCR
convention in New Orleans in May 2010 provided him with knowledge to
assist DPW clients as a DAP caseworker as well as future clients he would
try to obtain as a private disability advocate.
d. In late 2010 Krull was giving greater consideration to retiring from DPW to
pursue being a private disability advocate.
e. By March/April 2011 Krull began transferring DPW client information via
flash drive/CD from his DPW office to his home officefor the dual purpose of
providing services for clients while working at home, and also plans to do
such work in the future on a private basis.
f. Krull contacted at least nine DPW clients to determine if they would be
interested in utilizing Krull as their private disability representative after Krull
retired from DPW.
1. Krull made contact with said clients while still employed with DPW.
g. Krull was aware that it was not permissible to represent DPW clients both
publicly and privately at the same time.
1. Krull intended to transfer some of his DPW clients to the private
sector with him after his retirement.
Krull, 11-017
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h. Krull solicited DPW clients to utilize him as their private representative, and
Krull asked DPW co-workers Stan Levandowski and Laron Thompson to
refer DPW clients to Krull privately because they are initially responsible for
the referrals of DPW clients.
i. Krull tried to generate clientele for himself privately by generating the letter
that was addressed to forty-one DPW clients in which Krull informed them of
his retirement and his [availability] to provide private advocacy services.
j. Krull stopped all contact with those DPW clients who indicated they would
utilize Krull as their private representative after being contacted by David
Householder, employee, Human Resources, DPW, on June 26, 2011.
1. Krull stopped the pursuit of creating his own private disability
business.
2. Krull destroyed all of the DPW client information in his personal
possession, however DPW maintains the originals of those files.
k. Krull did not represent any DPW clients after his retirement from DPW.
l. Krull did not receive any payments from DPW clients after his retirement
from DPW.
m. Krull never filed a Statement of Financial Interests form while employed as
an Income Maintenance Caseworker by DPW.
1. DPW union representatives advised DPW Income Maintenance
Caseworkers they are not required to file Statement of Financial
Interests forms.
THE FOLLOWING FINDINGS RELATE TO THE ALLEGATION THAT KRULL FAILED
TO FILE STATEMENTS OF FINANCIAL INTERESTS FOR CALENDAR YEARS 2006,
2007, 2008, 2009, AND 2010.
46. Statement of Financial Interests (“SFI”) filing requirements for public officials and
employees are mandated by Section 1104 of the State Ethics Act.
a. Section 1104(a) mandates in part, the following:
…Any other public employee or public official shall file
a statement of financial interests with the governing
authority of the political subdivision by which he is
employed or within which he is appointed or elected no
later than May 1 of each year that he holds such a
position and of the year after he leaves such a position.
47. Income Maintenance Caseworkers are “public employees” as defined by the
Pennsylvania Public Official and Employee Ethics Act (“Ethics Act”) (65 Pa.C.S. §
1101 et seq.) and are therefore subject to the provisions of the Ethics Act.
a. The title of “Welfare Case Worker” was changed to “Income Maintenance
Worker 2” and then to the current title of “Income Maintenance Caseworker”
in 1985.
Krull, 11-017
Page 13
b. Individuals holding the position of Income Maintenance Caseworker, or
those who performed the same duties under a different title, were held to be
“public employees” subject to the Ethics Act as early as 1997.
1. The Commission’s 1997 adjudication rendered in Metrick, Order No.
1037, concluded that caseworkers are public employees under the
Ethics Act.
c. DPW union representatives had advised that persons in Krull’s position were
not required to file SFIs and that union was then currently involved in
proceedings before the Commission over the filing issue. (Ludwig, Opinion
09-001, [decided] 3/12/09, [issued 3/27/09]).
d. In Quaglia v. State Ethics Commission, the Commonwealth Court upheld the
State Ethics Commission’s ruling that individuals employed by the
Department of Public Welfare (“DPW”) as income maintenance caseworkers
are subject to the Ethics Act, and the regulations thereunder, requiring
“public employees” to, inter alia, file financial interests statements. Quaglia
v. State Ethics Commission, 986 A.2d 974 (Pa. Cmwlth. 2010), amended by,
2010 Pa. Commw. LEXIS 8 (Pa. Cmwlth. January 5, 2010), allocatur denied,
607 Pa. 708, 4 A.3d 1056 (2010).
48. On or about September 2, 2011, SFIs required to be filed by Krull in his capacity as
an Income Maintenance Caseworker were requested by the Investigative Division
from DPW.
a. DPW had not required Income Maintenance Caseworkers to complete and
submit SFIs in their public positions.
b. Krull had no SFIs on file with DPW.
49. Krull failed to file SFIs for calendar years 2006, 2007, 2008, 2009, and 2010.
a. Krull failed to file SFIs upon advice by DPW union representatives that DPW
Income Maintenance Caseworkers were not required to file SFIs.
III.DISCUSSION:
As an Income Maintenance Caseworker for the Pennsylvania Department of Public
Welfare (“DPW”) from approximately January 11, 1982, to June 29, 2011, Respondent
Mark Krull, hereinafter also referred to as “Respondent,” “Respondent Krull,” and “Krull,”
was a public employeesubject to the provisions of the Public Official and Employee Ethics
Act (“Ethics Act”), 65 Pa.C.S. § 1101 et seq. See, Quaglia, supra.
The allegations are that Respondent Krull violated Sections 1103(a) and 1104(a) of
the Ethics Act: (1) when he, as an Income Maintenance Caseworker for DPW, used the
authority of his public position and/or confidential information obtained through his public
position for the private pecuniary benefit of himself and/or a private business with which he
is associated to contact and contract, in a private capacity, with applicants/clients of DPW
seeking Social Security Disability (“SSD”) and Social Security Income (“SSI”) benefits; (2)
when he used the authority of his public position and/or confidential information obtained
through his public position in an attempt to contract, in a private capacity, with
applicants/clients of DPW seeking SSD and SSI benefits; (3) when he used the facilities
and equipment and supplies of DPW in furtherance of his private business interest; and (4)
when he failed to file Statements of Financial Interests (“SFIs”) for the 2006, 2007, 2008,
2009 and 2010 calendar years.
Krull, 11-017
Page 14
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" or "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
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.
Section 1104(a) of the Ethics Act provides that each public official/public employee
must file an SFI for the preceding calendar year, each year that he holds the position and
the year after he leaves it.
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.
From approximately January 11, 1982, to June 29, 2011, Respondent Krull was
employed by DPW as an Income Maintenance Caseworker under job classification number
44720. Commencing February 7, 2005, Respondent worked in DPW’s Disability Advocate
Program (“DAP”) division as a DAP Caseworker/Advocate, still under job classification
number 44720. Respondent retired from DPW effective June 30, 2011.
DAP is a social service program that was established by DPW in 1985 to assist
DPW clients with disabilities through the Supplemental Security Income (“SSI”) and Social
Security Disability Insurance (“SSDI”) application and appeal process. SSI and SSDI are
federally funded programs that are administered and regulated by the Social Security
Administration (“SSA”).
Krull, 11-017
Page 15
Respondent’s duties as a DAP Caseworker/Advocate included, but were not limited
to, acting as the appointed non-attorney representative for DPW clients who authorized
Respondent to represent them in matters related to their claims with SSA. In his capacity
as a DAP Caseworker/Advocate, Respondent was not permitted to receive any fees for
such representation. DPW policies outlined in Chapter 820 of the DAP prohibited DAP
Caseworkers/Advocates from collecting fees for representing DPW clients. When a DPW
client selects the DAP Caseworker/Advocate as his/her non-attorney representative, DPW
procedures require the DAP Caseworker/Advocate to complete the “waiver of fee” section
of SSA’s Appointment of Representative Form (SSA 1696 form), waiving the right to
charge and collect a fee for such representative services.
Respondent has been an enrolled member of SSA’s Direct Payment to Non-
Attorney Representatives Program (“NRP”) since January/February of 2009. Respondent
has been a registered member in the National Organization of Social Security Claimants’
Representatives (“NOSSCR”) since on or about April 18, 2010. Respondent’s enrollment
in SSA’s NRP and membership with NOSSCR occurred during a time when he was
contemplating retiring from DPW to pursue a career as a private non-attorney Disability
Advocate.
DPW client information is confidential and to be used only for DPW business.
Respondent, in his position as a DAP Caseworker/Advocate, had access to DPW client
information.
In a sworn statement to Commission investigators, Respondent acknowledged that
by March/April 2011, he began transferring DPW client information via flash drive/CD from
his DPW office to his home officefor the dual purpose of providing services for clients
while working at home and plans to do such work in the future on a private basis.
Respondent acknowledged that he intended to transfer some of his DPW clients to the
private sector with him after his retirement. Respondent also acknowledged that while he
was still employed with DPW, he contacted at least nine DPW clients to determine if they
would be interested in utilizing Respondent as their private disability representative after
Respondent retired from DPW. Respondent acknowledged that he asked DPW co-
workers Stan Levandowski and Laron Thompson to refer DPW clients to Respondent
privately because those individuals are initially responsible for the referrals of DPW
clients.
DPW clients contacted by Respondent indicated that Respondent spoke to them
about his possible private representation of them after his retirement. These contacts
occurred between January and June 2011. Respondent made his DPW clients aware of
his intimate knowledge of their cases. Respondent discussed his fee with his DPW clients
who verbally agreed to utilize Respondent as their private non-attorney representative.
On or about June 17, 2011, Respondent sent an email to his supervisor, Francis
Rectenwald, to inform Rectenwald about his intentions of retiring from DPW. Rectenwald
responded to Respondent’s email, informing Respondent to submit a formal notice of
retirement to Patricia Steinkopf (“Steinkopf”), DPW’s Southern District Director.
By the time Respondent informed Rectenwald of his plan to retire, Respondent had
already devised a business plan to establish a home-based sole proprietorship that
provided non-attorney disability advocacy services. Respondent named his business
“Krull and Associates, LLC.” Respondent did not register the business with the
Pennsylvania Corporation Bureau or file any Articles of Incorporation.
On or about June 22, 2011, Respondent issued a formal notice of retirement to
Steinkopf notifying DPW of his plan to begin his retirement on June 30, 2011.
Respondent also made his DPW colleagues aware of his plan to retire during the week of
June 20, 2011. Respondent indicated to his colleagues that he was planning to begin his
own disability advocate business in the near future to assist individuals through the
Krull, 11-017
Page 16
SSI/SSDI application/appeals process. Respondent advised of his willingness for DPW
clients to be referred to his business.
On or about June 24, 2011, Respondent received confirmation that his retirement
had been accepted by DPW. Respondent’s final date of employment was scheduled for
June 29, 2011.
On Friday, June 24, 2011, Rectenwald directed Respondent to generate a contact
letter to a number of DPW clients identified by Rectenwald, who might be eligible for DAP
assistance. DPW utilizes a form letter to notify clients of such services. As detailed at
Fact Finding 30, Respondent altered the content of the letter to include information that
Respondent would be available, in a private capacity, to assist clients with DAP.
Respondent altered the aforesaid letter with the intent to generate clientele for Krull and
Associates LLC. Respondent listed the business telephone number for Krull and
Associates, LLC on such correspondence.
Respondent only had access to the DPW clients eligible for DAP assistance as a
result of his employment as a DPW Income Maintenance Caseworker. The client
information was personal and confidential and not available to the public. Respondent
prepared the contact letter throughout the course of his normal work hours.
The letter altered by Respondent came to the attention of Respondent’s superiors at
DPW on June 24, 2011. One such superior discovered: (1) forty-one of the altered letters
authored by Respondent enclosed in DPW envelopes addressed to DPW clients on top of
filing cabinets located at Respondent’s work space; and (2) two of Respondent’s DPW
business cards that had his DPW telephone number scratched out and replaced by the
business telephone number for Krull and Associates, LLC. In his sworn statement to
Commission investigators, Respondent acknowledged that he tried to generate clientele
for himself privately by generating the aforesaid letter.
Respondent had utilized annual leave on June 27, 2011. On June 27, 2011,
Respondent was contacted by a DPW Human Resources representative and advised not
to report to work on June 28, 2011, and/or June 29, 2011, due to the letters composed by
Respondent on June 24, 2011. The Human Resources representative informed
Respondent that Respondent’s actions and events of June 24, 2011, were being forwarded
to this Commission for review. After his conversation with the aforesaid DPW Human
Resources representative, Respondent ended all contact with DPW clientele. Respondent
received no direct or indirect compensation from DPW clients for representation. Krull and
Associates, LLC was never operational and ceased to exist by the end of June 2011.
We shall now review the Stipulated Findings regarding Respondent’s failure to file
SFIs.
Individuals holding the position of Income Maintenance Caseworker, or those who
performed the same duties under a different title, were held to be “public employees”
subject to the Ethics Act as early as 1997. In 2009 DPW union representatives were
involved in proceedings before this Commission challenging the requirement that Income
Maintenance Caseworkers file Statements of Financial Interests pursuant to the Ethics Act.
See, Ludwig, supra. In Quaglia, supra, the Commonwealth Court of Pennsylvania upheld
this Commission’s ruling that individuals employed by DPW as Income Maintenance
Caseworkers are subject to the Ethics Act, and the regulations thereunder, including
requirements to file Statements of Financial Interests.
On or about September 2, 2011, the Investigative Division requested Respondent’s
SFIs from DPW. DPW had not required Income Maintenance Caseworkers to complete
and submit SFIs in their public positions. Respondent had no SFIs on file with DPW. In
relation to the allegations before us, Respondent failed to file SFIs for calendar years
Krull, 11-017
Page 17
2006, 2007, 2008, 2009, and 2010. Respondent failed to file SFIs upon advice by DPW
union representatives that DPW Income Maintenance Caseworkers were not required to
file SFIs.
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:
3. The Investigative Division will recommend the following
in relation to the above allegations:
a. That no violation of Section 1103(a) of
the Public Official and Employee Ethics
Act, 65 Pa.C.S. §1103(a) occurred in
relation to Krull’s attempts to contact and
contract with applicants/clients of DPW
seeking Social Security Disability (SSD)
and Social Security Income (SSI)
benefits; nor when he utilized the
facilities, equipment and supplies of the
Department of Public Welfare in
furtherance of his private business
interest, as there is insufficient evidence
to establish a violation by way of clear
and convincing evidence.
b. That a violation of Section 1104(a) of the
Public Official and Employee Ethics Act,
65 Pa.C.S. §1104(a) occurred when Krull
failed to file Statements of Financial
Interests for the 2006, 2007, 2008, 2009
and 2010 calendar years.
4. Krull agrees to make payment in the amount of
$2,250.00 in settlement of this matter payable as
follows:
a. $1,250.00 payable by certified check or
money order made payable to the
Commonwealth of Pennsylvania and
forwarded to the Pennsylvania State
Ethics Commission within thirty (30) days
of the issuance of the final adjudication in
this matter.
b. $1,000 in reimbursement representing a
portion of the expenses and costs
incurred by the State Ethics Commission
in the investigation and administrative
prosecution of the instant matter, payable
by certified check or money order made
payable to the Pennsylvania State Ethics
Commission. Said payment is to be
forwarded to the Pennsylvania State
Ethics Commission within thirty (30) days
Krull, 11-017
Page 18
of the issuance of the final adjudication in
this matter.
5. Krull agrees to file Statements of Financial Interests
with the Department of Public Welfare, through the
Pennsylvania State Ethics Commission, for 2006, 2007,
2008, 2009 and 2010 calendar years within thirty (30)
days of the issuance of the final adjudication in this
matter.
6. Krull agrees to not accept any reimbursement,
compensation or other payment from the
Commonwealth of Pennsylvania 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 2-3.
In considering the Consent Agreement, we accept the recommendation of the
parties for a finding that no violation of Section 1103(a) of the Ethics Act occurred in
relation to Respondent’s attempts to contact and contract with applicants/clients of DPW
seeking SSD and SSI benefits; nor when he utilized the facilities, equipment and supplies
of DPW in furtherance of his private business interest, based upon the parties’ agreement
that there is insufficient evidence to establish a violation by way of clear and convincing
evidence.
It appears that the parties’ recommendation as to the finding of no violation of
Section 1103(a) of the Ethics Act might be based upon the fact that Respondent’s
aforesaid actions ultimately did not result in any private pecuniary benefit. We recognize
the rights of the parties to negotiate the recommended result through a Consent
Agreement.
We accept the parties’ Consent Agreement and hold that no violation of Section
1103(a) of the Ethics Act, 65 Pa.C.S. § 1103(a), occurred in relation to Respondent’s
attempts to contact and contract with applicants/clients of DPW seeking SSD and SSI
benefits; nor when he utilized the facilities, equipment and supplies of DPW in furtherance
of his private business interest, based upon the parties’ agreement that there is insufficient
evidence to establish a violation by way of clear and convincing evidence.
As for the second recommendation of the Consent Agreement, we agree with the
parties and we hold that a violation of Section 1104(a) of the Ethics Act, 65 Pa.C.S. §
1104(a), occurred when Respondent failed to file SFIs for the 2006, 2007, 2008, 2009 and
2010 calendar years. Quaglia, supra, confirmed that DPW Income Maintenance
Caseworkers are subject to the Ethics Act, including the requirements for filing Statements
of Financial Interests. Respondent failed to comply with those requirements.
Krull, 11-017
Page 19
As part of the Consent Agreement, Respondent Krull has agreed to make payment
in the amount of $2,250.00 in settlement of this matter payable as follows: (1) $1,250.00
payable by certified check or money order made payable to the Commonwealth of
Pennsylvania and forwarded to this Commission within thirty (30) days of the issuance of
the final adjudication in this matter; and (2) $1,000 in reimbursement representing a portion
of the expenses and costs incurred by this Commission in the investigation and
administrative prosecution of the instant matter, payable by certified check or money order
made payable to the Pennsylvania State Ethics Commission and forwarded to this
Commission within thirty (30) days of the issuance of the final adjudication in this matter.
Respondent has agreed to not accept any reimbursement, compensation or other
payment from the Commonwealth of Pennsylvania representing a full or partial
reimbursement of the amount paid in settlement of this matter.
Respondent has further agreed to file SFIs for calendar years 2006, 2007, 2008,
2009 and 2010 with DPW, through this Commission, within thirty (30) days of the issuance
of the final adjudication in 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 Krull is directed
to make payment in the amount of $2,250.00 payable as follows: (1) $1,250.00 payable by
certified check or money order made payable to the Commonwealth of Pennsylvania and
th
forwarded to this Commission by no later than the thirtieth (30) day after the mailing date
of this adjudication and Order; and (2) $1,000 in reimbursement representing a portion of
the expenses and costs incurred by this Commission in the investigation and
administrative prosecution of the instant matter, payable by certified check or money order
made payable to the Pennsylvania State Ethics Commission and forwarded to this
th
Commission by no later than the thirtieth (30) day after the mailing date of this
adjudication and Order.
Per the Consent Agreement of the parties, Respondent is directed to not accept any
reimbursement, compensation or other payment from the Commonwealth of Pennsylvania
representing a full or partial reimbursement of the amount paid in settlement of this matter.
To the extent he has not already done so, Respondent is further directed to file SFIs
for calendar years 2006, 2007, 2008, 2009 and 2010 with DPW, through this Commission,
th
by no later than the thirtieth (30) day after the mailing date of this adjudication and Order.
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 an Income Maintenance Caseworker for the Pennsylvania Department of Public
Welfare (“DPW”) from approximately January 11, 1982, to June 29, 2011,
Respondent Mark Krull (“Krull”) was a public employeesubject to the provisions of
the Public Official and Employee Ethics Act (“Ethics Act”), 65 Pa.C.S. § 1101 et
seq.
2. No violation of Section 1103(a) of the Ethics Act, 65 Pa.C.S. § 1103(a), occurred in
relation to Krull’s attempts to contact and contract with applicants/clients of DPW
seeking Social Security Disability and Social Security Income benefits; nor when he
utilized the facilities, equipment and supplies of DPW in furtherance of his private
Krull, 11-017
Page 20
business interest, based upon the parties’ agreement that there is insufficient
evidence to establish a violation by way of clear and convincing evidence.
3. A violation of Section 1104(a) of the Ethics Act, 65 Pa.C.S. § 1104(a), occurred
when Krull failed to file Statements of Financial Interests for the 2006, 2007, 2008,
2009 and 2010 calendar years.
In Re: Mark Krull, : File Docket: 11-017
Respondent : Date Decided: 9/24/12
: Date Mailed: 10/9/12
ORDER NO. 1609
1. As an Income Maintenance Caseworker for the Pennsylvania Department of Public
Welfare (“DPW”), Mark Krull (“Krull”) did not violate Section 1103(a) of the Public
Official and Employee Ethics Act (“Ethics Act”), 65 Pa.C.S. § 1103(a), in relation to
Krull’s attempts to contact and contract with applicants/clients of DPW seeking
Social Security Disability and Social Security Income benefits; nor when he utilized
the facilities, equipment and supplies of DPW in furtherance of his private business
interest, based upon the parties’ agreement that there is insufficient evidence to
establish a violation by way of clear and convincing evidence.
2. A violation of Section 1104(a) of the Ethics Act, 65 Pa.C.S. § 1104(a), occurred
when Krull failed to file Statements of Financial Interests for the 2006, 2007, 2008,
2009 and 2010 calendar years.
3. Per the Consent Agreement of the parties, Krull is directed to make payment in the
amount of $2,250.00 payable as follows: (a) $1,250.00 payable by certified check
or money order made payable to the Commonwealth of Pennsylvania and
forwarded to the Pennsylvania State Ethics Commission by no later than the
th
thirtieth (30) day after the mailing date of this Order; and (b) $1,000 in
reimbursement representing a portion of the expenses and costs incurred by the
Pennsylvania State Ethics Commission in the investigation and administrative
prosecution of the instant matter, payable by certified check or money order made
payable to the Pennsylvania State Ethics Commission and forwarded to this
th
Commission by no later than the thirtieth (30) day after the mailing date of this
Order.
4. Per the Consent Agreement of the parties, Krull is directed to not accept any
reimbursement, compensation or other payment from the Commonwealth of
Pennsylvania representing a full or partial reimbursement of the amount paid in
settlement of this matter.
5. To the extent he has not already done so, Krull is further directed to file Statements
of Financial Interests for calendar years 2006, 2007, 2008, 2009 and 2010 with
DPW, through the Pennsylvania State Ethics Commission, by no later than the
th
thirtieth (30) day after the mailing date of this Order.
6. Compliance with Paragraphs 3, 4 and 5 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,
___________________________
Name, Case #
Page 22
John J. Bolger, Chair