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HomeMy WebLinkAbout80-648 KablachSTATE ETHICS COMMISSION 308 FINANCE BUILDING HARRISBURG, PENNSYLVANIA 17120 May 29, 1980 ADVICE OF COMMISSION Marjory E. Kablach Division of Internal Audits Governor's Office of Administration Dear Ms. Kablach: Advice #80 -648 On May 6, 1980, you asked whether you, as a Field Auditor in the Division of Internal Audits, Office of Administration would have a conflict if you accepted part -time employment with a local CPA firm. You noted that until July 1979 you were employed by the Bureau of Audits, Department of Public Welfare and had some responsibility for auditing nursing homes under the Medicaid Cost Reimbursement Program. Your new position has no responsi- bility for audits of nursing homes. The part -time position you are considering would consist of doing bookkeeping for clients of the CPA firm. In this position you would have no descretionary authority and would be performing ministerial responsibilities. Your holding both positions would not present a conflict under Act 170. Pursuant to Section 7(9)(ii), this advice is a complete defense in any enforcement proceeding initiated by the Commission, and evidence of good faith conduct in any other civil or criminal proceeding, providing the requestor has disclosed truthfully all the material facts and committed the acts complained of in reliance on the advice given. You may appeal this advice to the full Commission. This letter is a public record and will be available as such. PJS /rdp / / AUL J SMITH Chair