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HomeMy WebLinkAbout16-002 ConfidentialOPINION OF THE COMMISSION Before: Nicholas A. Colafella, Chair Mark R. Corrigan, Vice Chair Roger Nick Kathryn Streeter Lewis Maria Feeley Melanie DePalma DATE DECIDED: 1/20/16 DATE MAILED: 2/11/16 16 -002 This Opinion is issued in response to your advisory request letter of October 27, 2015. I. ISSUE: Whether, pursuant to the Public Official and Employee Ethics Act ( "Ethics Act "), 65 Pa.C.S. § 1101 et seq., an employee of the A of the B who is subject to the Ethics Act would be required to disclose on his Statement(s) of Financial Interests the value of attendance at a [number of days] training program, where: (1) the costs of the seminars and training, lodging and most of the food offered during this [number of days] period were paid by J; and (2) such expenses could have been, but were not, reimbursed by the Comptroller of the B; and if reportable, whether the costs paid for attendance at the training program would be considered gift(s) or transportation, lodging and /or hospitality. II. FACTUAL BASIS FOR DETERMINATION: As D to the B A, you have been authorized by Individual E to request a confidential advisory from this Commission on his behalf. You have submitted facts, the material portion of which may be fairly summarized as follows. Individual E is an employee of the B A and F of the G. You state that for purposes of analyzing your advisory request, we are to assume that Individual E is a public employee subject to the Ethics Act and, in particular, the Ethics Act's requirements forfiling Statements of Financial Interests. In 2015, Individual E attended Training Program H ( "the Training Program ") at Educational Institution I in [location]. The Training Program is a [type of program] sponsored by C. It is designed for government officials and staff. It covers topics including but not limited to: [list of topics]. C is part of a larger member organization known as J, which is specifically Confidential Opinion, 16 -002 February 11, 2016 Page 2 mentioned in Pennsylvania law and which includes [number] governmental jurisdictions represented by various government officials or their designees. You note that the Commonwealth of Pennsylvania pays dues to belong to J and also appropriates funds for attendance at its Ks. The costs of the seminars and training, lodging and most of the food offered during the [number of days] period of the Training Program were paid by J. However, you note that such expenses are considered reimbursable under the expense guidelines of the B, and that the expenses for Individual E's attendance at the Training Program could have been, but were not, reimbursed by the Comptroller of the B. You have submitted [organizational document] of J, which indicate that J is a [type of organization] that [performs a certain function]. You note that [a certain legislative Act], which created a [type of advisory board] known as [name of board], referred to J as an L of M. See, [cite]. You pose the following specific questions (1) Whether J is a "governmental body" within the meaning of that term as set forth in the Ethics Act; (2) Whether Individual E is required to disclose the value of his attendance at the Training Program on his Statement of Financial Interests; and (3) If disclosure is required, whether the value of Individual E's attendance at the Training Program would be reportable as a "gift" if the $250 reporting threshold would be met, or reportable as hospitality, transportation or lodging if the threshold of in excess of $650 would be met. By letter dated December 22, 2015, you were notified of the date, time and location of the Executive Meeting at which your request would be considered. At the Executive Meeting on January 20, 2016, you appeared for the purpose of answering questions of the Commissioners. You noted that in addition to governmental members, J includes /has relationships with private- sector or non - governmental entities, which also pay dues to and can participate in J. You stated that the funds J receives are commingled, but the monies used by J to pay for individuals such as Individual E to attend training seminars are predominantly [governmental] dollars. III. DISCUSSION: It is initially noted that pursuant to Sections 1107(10) and 1107(11) of the Ethics Act, 65 Pa.C.S. §§ 1107(10), (11), advisories are issued to the requester based upon the facts that the requester has submitted. In issuing the advisory based upon the facts that the requester has submitted, this Commission does not engage in an independent investigation of the facts, nor does it speculate as to facts that have not been submitted. It is the burden of the requester to truthfully disclose all of the material facts relevant to the inquiry. 65 Pa.C.S. §§ 1107(10), (11). An advisory only affords a defense to the extent the requester has truthfully disclosed all of the material facts. This Opinion assumes, without deciding, that as an employee of the B A and F of the G, Individual E is a public employee subject to the Ethics Act. Section 1104(a) of the Ethics Act provides that each public official /public employee must file a Statement of Financial Interests for the preceding calendar year, each yearthat he holds the position and the year after he leaves it. Confidential Opinion, 16 -002 February 11, 2016 Page 3 Section 1105(b)(6) -(7) of the Ethics Act provides as follows: § 1105. Statement of financial interests (b) Required information. - -The statement shall include the following information forthe prior calendar year with regard to the person required to file the statement: (6) The name and address of the source and the amount of any gift or gifts valued in the aggregate at $250 or more and the circumstances of each gift. This paragraph shall not apply to a gift or gifts received from a spouse, parent, parent by marriage, sibling, child, grandchild, other family member or friend when the circumstances make it clear that the motivation for the action was a personal or family relationship. However, for the purposes of this paragraph, the term "friend" shall not include a registered lobbyist or an employee of a registered lobbyist. (7) The name and address of the source and the amount of any payment for or reimbursement of actual expenses for transportation and lodging or hospitality received in connection with public office or employment where such actual expenses for transportation and lodging or hospitality exceed $650 in an aggregate amount per year. This paragraph shall not apply to expenses reimbursed by a governmental body or to expenses reimbursed by an organization or association of public officials or employees of political subdivisions which the public official or employee serves in an official capacity. 65 Pa.C.S. § 1105(b)(6) -(7) The Ethics Act defines the terms "gift" and "hospitality" as those terms are defined in Section 13A03 of Pennsylvania's lobbying disclosure law ( "Lobbying Disclosure Law "), 65 Pa.C.S. § 13A03 (see, 65 Pa.C.S. § 1102): § 13A03. Definitions. "Gift." Anything which is received without consideration of equal or greater value. The term shall not include a political contribution otherwise reportable as required by law or a commercially reasonable loan made in the ordinary course of business. The term shall not include hospitality, transportation or lodging. "Hospitality." Includes all of the following: (1) Meals. (2) Beverages. Confidential Opinion, 16 -002 February 11, 2016 Page 4 (3) Recreation and entertainment. The term shall not include gifts, transportation or lodging. 65 Pa.C.S. § 13A03. The Ethics Act defines the terms "source," "person," "business," "governmental body," and "political subdivision" as follows: § 1102. Definitions "Source." Any person who is a provider of an item reportable under section 1105 (relating to statement of financial interests). "Person." A business, governmental body, individual, corporation, union, association, firm, partnership, committee, club or other organization or group of persons. "Business." Any corporation, partnership, sole proprietorship, firm, enterprise, franchise, association, organization, self - employed individual, holding company, joint stock company, receivership, trust or any legal entity organized for profit. "Governmental body." Any department, authority, commission, committee, council, board, bureau, division, service, office, officer, administration, legislative body or other establishment in the executive, legislative orjudicial branch of a state, a nation or a political subdivision thereof or any agency performing a governmental function. "Political subdivision." Any county, city, borough, incorporated town, township, school district, vocational school, county institution district, and any authority, entity or body organized by the aforementioned. 65 Pa.C.S. § 1102. There is no statutory exclusion to disclosure where training ortravel expenses could have been —but were not —paid /reimbursed by the filer's own governmental body. We shall now consider the specific questions that you have posed. We first determine that J is not a "governmental body" as that term is defined in the Ethics Act. J is not an establishment in the executive, legislative or judicial branch of a state, a nation or a political subdivision thereof, and there is no indication that J performs a governmental function. Based upon the submitted facts, you are advised that assuming the respective reporting thresholds would be met, Individual E would be required to disclose on his Statement of Financial Interests the amount(s) paid by J for his attendance at the Training Program. The amount attributable to costs for the seminars and training itself would be considered a "gift" and would be reportable as such if the reporting threshold ($250 in the aggregate for the calendar year) would be met. The amounts attributable to transportation, lodging and /or hospitality (meals, beverages, and recreation /entertainment would be reportable as such if the reporting threshold for that category (in excess of 650 in the Confidential Opinion, 16 -002 February 11, 2016 Page 5 aggregate for the calendar year) would be met. Cf., McCormick, Opinion 15 -1001 at 7 The propriety of the proposed conduct has only been addressed under the Ethics Act; the applicability of any other statute, code, ordinance, regulation or other code of conduct other than the Ethics Act has not been considered in that they do not involve an interpretation of the Ethics Act. IV. CONCLUSION: This Opinion assumes, without deciding, that as an employee of the A of the B and F of the G, Individual E is a public employee subject to the Public Official and Employee Ethics Act, 65 Pa.C.S. § 1101 et seg. ( "Ethics Act "). Under the submitted facts that: (1) in 2015, Individual E attended Training Program H ( "the Training Program ") at Educational Institution I in [location]; (2) the Training Program is a [type of program] sponsored by C; (3) the Training Program is designed for government officials and staff; (4) the Training Program covers topics including but not limited to: [list of topics]; (5) C is part of a larger member organization known as J, which is specifically mentioned in Pennsylvania law and which includes [number] governmental jurisdictions represented by various government officials or their designees; (6) the Commonwealth of Pennsylvania pays dues to belong to J and also appropriates funds for attendance at its Ks; (7) the costs of the seminars and training, lodging and most of the food offered during the [number of days] period of the Training Program were paid by J; (8) such expenses are considered reimbursable under the expense guidelines of the B, and the expenses for Individual E's attendance at the Training Program could have been, but were not, reimbursed by the Comptroller of the B; (9) [organizational document] of J indicate that J is a [type of organization] that [performs a certain function]; (10) [a certain legislative Act], which created a [type of advisory board] known as [name of board], referred to J as an L of M; (11) in addition to governmental members, J includes /has relationships with private- sector or non - governmental entities, which also pay dues to and can participate in J; and (12) the funds J receives are commingled, but the monies used by J to pay for individuals such as Individual E to attend training seminars are predominantly [governmental] dollars, you are advised as follows. J is not a "governmental body" as that term is defined in the Ethics Act. Assuming the respective reporting thresholds would be met, Individual E would be required to disclose on his Statement of Financial Interests the amount(s) paid by J for his attendance at the Training Program. The amount attributable to costs for the seminars and training itself would be considered a "gift" and would be reportable as such if the reporting threshold ($250 in the aggregate for the calendar year) would be met. The amounts attributable to transportation, lodging and /or hospitality (meals, beverages, and recreation /entertainment) would be reportable as such if the reporting threshold for that category (in excess of $650 in the aggregate for the calendar year) would be met. The propriety of the proposed conduct has only been addressed under the Ethics Act. Pursuant to Section 1107(10) of the Ethics Act, the person who acts in good faith on this Opinion issued to him shall not be subject to criminal or civil penalties for so acting provided the material facts are as stated in the request. This letter is a public record and will be made available as such By the Commission, Nicholas A. Colafella Chair Confidential Opinion, 16 -002 February 11, 2016 Page 6