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HomeMy WebLinkAbout95-580 SwantkoSTATE ETHICS COMMISSION 309 FINANCE BUILDING P.O. BOX 11470 HARRISBURG, PA 17108 -1470 TELEPHONE (717) 783 -1610 ADVICE OF COUNSEL July 6, 1995 Daniel Swantko Pennsylvania Department of Revenue Bureau of Individual Taxes Strawberry Square, 6th Floor Harrisburg, PA 17128 Re: Tax Examiner III; Department of Revenue; Public Employee; FIS. Dear Mr. Swantko: 95 -580 This responds to your letter dated June 13, 1995, or Financial Interest disclosure appeal, which will be treated as a request for advice from the State Ethics Commission. Issue: You ask whether in your capacity as a Tax Examiner III with the Department of Revenue, you are to be considered a "public employee" as that term is defined in the Public Official and Employee Ethics Law. Facts: As a Tax Examiner III for the Pennsylvania Department of Revenue (Revenue), you filed a Financial Disclosure Appeal Form which your employer has forwarded to us and which has been docketed as an advisory request as to whether you are required to file the Financial Interests Statement (FIS). In the Financial Disclosure Appeal you assert that your position duties and responsibilities fail to meet the definition of a public employee. You then cite portions of Section 2 of the Public Official and Employee Ethics Law definition of "Public employee." "Any individual employed by the Commonwealth . who is responsible for taking or recommending official action in[sic] a nonministerial nature with regards[sic] to: (1) contracting or procurement; (2) administering or monitoring grants or subsidies; (3) planning or zoning; (4) inspecting, licensing, regulating or auditing any person; or (5) any other activity where the official action has an economic impact or(sic] greater than a de minimis nature on the nature[sic] of any person." You contend that the "job duties and responsibilities of Tax Examiner III position #018304003680 meets the classification definition of anyone who is involved exclusively in the ministerial activity. "[sic] You claim that ministerial action is a person who performs in a prescribed manner without regards to or the exercise Swantko, Daniel, 95 -580 July 6, 1995 Page 2 of the persons own judgement as to the desirability of the action being taken. You state that all section work assignments are predetermined sactioned[sic] lists (suspension, audit, IRS findings) that are formulated, requested, directed and authorized by superior officials (Rev. Sec. Bureau Directors, Div. Chiefs) and that these T /per lists are nonaltered and nonadulterated. You further declare that the assignment, examination, review /audit of these lists are governed and subscribed to Departmental procedures, Pennsylvania Rules and Regulations mandated by Revenue through the legislative process and the passage of the Income Tax Act of 1971. You maintain that there are no independent judgmental actions taken and all work assignments are performed in obedience to legal authority through the income tax laws without the regard or the exercise of any personal judgement as to the desirability of action being taken since the application of written procedures and law dictate the outcome. No final decisions /recommendations are rendered at this level nor is there any written authority granted to forward or stop recommendations from being sent to those in authority to make final decisions and there are no final technical recommendations at this level effecting other organizations. The decision of the Revenue Job Evaluation Committee fails to meet /represent the Pennsylvania Ethics Commission's intentions of this law in definition and context as it relates to the Tax Examiner III position. In summation, position #01830403680 is magisterial[sic] in origin and function and fails to meet the definition of a public employee as defined by the State Ethics Commission, Commonwealth of Pennsylvania. Finally, a copy of your job description classification/ specification has been submitted which is incorporated herein by reference. In order to review the question presented, we will briefly outline the duties and responsibilities associated with your position as contained in your job description and the classification specifications for this position. Your duties and responsibilities as set forth in these two documents are incorporated herein by reference. The classification /specification for a Tax Examiner III provides for the following duties and responsibilities: performing advance examinations and supervisory work in reviewing tax documents; supervising a group of subordinate employees engaged in reviewing and processing tax documents; supervising the review of tax documents or individual taxpayer's accounts that have been liened; corresponding with field personnel, attorneys, banks and other governmental agencies and the general public as to individual cases; supervising a group of subordinates by defining examination objectives, reviewing results and answering questions on technical applications of Revenue and working with a great deal of independence under the general supervision of an administrative superior. Swantko, Daniel, 95 -580 July 6, 1995 Page 3 The job description provides that your work is specialized managerial work in planning, organizing and directing work assignments in various areas of taxes; managing a work force of approximately of ten examiners who review, examine and analyze different taxes and rebate claims; directing, planning and implementing billing collection and payment posting activities as to certain audits; analyzing certain transfers and transactions, missing tax schedules and related correspondence for tax liability; planning, directing, coordinating and controlling Unit activities to ensure a smooth, efficient and positive flow of work; maintaining liaison with other bureau areas and reviewing on a sampling basis processed documents to determine that the documents are in accordance with the Pennsylvania law and regulations and procedures, supervising the Employee Incentive Program; directing the activities of subordinates and providing guidance and assistance; insuring the review of the listing of non processed or suspended documents; reviewing existing procedures and processing documents; performing other delineated duties and related duties as required. Discussion: The question to be answered is whether you, in your capacity as a Tax Examiner III for Revenue, are to be considered a "public employee." The Ethics Law defines that term as follows: 65 P.S. §402. Section 2. Definitions "Public employee." Any individual employed by the Commonwealth or a political subdivision who is responsible for taking or recommending official action of a nonministerial nature with regard to: (1) contracting or procurement; (2) administering or monitoring grants or subsidies; (3) planning or zoning; (4) inspecting, licensing, regulating or auditing any person; or (5) any other activity where the official action has an economic impact of greater than a de minimis nature on the interests of any person. "Public employee" shall not include individ- uals who are employed by the State or any political subdivision thereof in teaching as distinguished from administrative duties. Swantko, Daniel, 95 -580 July 6, 1995 Page 4 The regulations of the State Ethics Commission similarly define the term public employee as above with the additional following criteria: (ii) The following criteria will be used, in part, to determine whether an individual is within the definition of "public employee ": (A) The individual normally performs his responsibility in the field without onsite supervision. (B) The individual is the immediate supervisor of a person who normally performs his responsibility in the field without onsite supervision. (C) The individual is the supervisor of a highest level field office. (D) The individual has the authority to make final decisions. (E) The individual has the authority to forward or stop recommendations from being sent to the person or body with the authority to make final decisions. (F) The individual prepares or supervises the preparation of final recommendations. (G) The individual makes final technical recommendations. (H) The individual's recommendations or actions are an inherent and recurring part of his position. (I) The individual's recommendations or actions affect organizations other than his own organization. (iii) The term does not include individuals who are employed by the Commonwealth or a political subdivision of the Commonwealth in teaching as distinguished from administrative duties. Swantko, Daniel, 95 -580 July 6, 1995 Page 5 (iv) Persons in the following positions are generally considered public employes: (A) Executive and special directors or assistants reporting directly to the agency head or governing body. (B) Commonwealth bureau directors, division chiefs or heads of equivalent organization elements and other governmental body department heads. (C) Staff attorneys engaged in representing the department, agency or other governmental bodies. (D) Engineers, managers and secretary - treasurers acting as managers, police chiefs, chief clerks, chief purchasing agents, grant and contract managers, administrative officers, housing and building inspectors, investigators, auditors, sewer enforcement officers and zoning officers in all governmental bodies. (E) Court administrators, assistants for fiscal affairs and deputies for the minor judiciary. (F) School superintendents, assistant superintendents, school business managers and principals. (G) Persons who report directly to heads of executive, legislative and independent agencies, boards and commissions except clerical personnel. (v) Persons in the following positions are generally not considered public employes: (A) City clerks, other clerical staff, road masters, secretaries, police officers, maintenance workers, construction workers, equipment operators and recreation directors. (B) Law clerks, court criers, court reporters, probation officers, security guards and writ servers. Swantko, Daniel, 95 -580 July 6, 1995 Page 6 51 Pa. Code §11.1. (C) School teachers and clerks of the schools. The question you present must be reviewed under these provisions of the statute and the regulations of the Commission in light of your duties and obligations as described in your job description and /or classification specifications, under which you operate. The inquiry necessarily focuses on the job itself and not on the individual incumbent in the position, the variable functions of the position, or the manner in which a particular individual occupying a position may carry out those functions. See Phillips v. State Ethics Commission, 79 Pa. Commw. 491, 470 A.2d 659 (1984) ; and Mummau v. Ranck, 531 Fed. Supp. 402 (E.D. Pa. 1982). Also, in reviewing your question, the Commonwealth Court in its ruling in Phillips, supra, at page 661, directs that coverage of the Ethics Act be construed broadly, rather than narrowly, and conversely, directs that exclusions from the Ethics Law should be narrowly construed. Based upon this directive and reviewing the definition of "public employee" in the statute and the regulations and opinions of this Commission, in light of your job functions and the information available to us, the necessary conclusion that you are a "public employee" subject to the financial reporting and disclosure requirements of the State Ethics Act. It is clear that in your capacity as a Tax Examiner III, you have the ability to recommend official action with respect to subparagraphs 3, 4, and 5 within the definition of "public employee" as set forth in the Ethics Law, 65 P.S. §402. These activities fall within the definition of public employee as contained in the regulations of the Commission in Section 11.1, subparagraph E, F, G, H, and I. 51 Pa. Code §11.1. Under these circumstances and given your duties and responsibilities as outlined above, you are a "public employee" as that term is defined in the Ethics Law. Conclusion: You are to be considered a "public employee" in your capacity as a Tax Examiner III with the Department of Revenue. Accordingly, you must file a Statement of Financial Interests for each year in which you hold the position outlined above and for the year following your termination of this service. If you have not already done so, a Statement of Financial Interests must be filed within 30 days of this Advice. This Statement of Financial Interests would report information of the prior calendar year. Pursuant to Section 7(11), this Advice is a complete defense Swantko, Daniel, 95 -580 July 6, 1995 Page 7 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. such. This letter is a public record and will be made available as Finally, if you disagree with this Advice or if you have any reason to challenge same, you may appeal the Advice to the full Commission. A personal appearance before the Commission will be scheduled and a formal Opinion will be issued by the Commission. Any such appeal must be in writing and must be actually received at the Commission within thirty (30) days of the date of this Advice pursuant to 51 Pa .Code 513.2(h). The appeal may be received at the Commission by hand delivery, United States mail, delivery service, or by FAX transmission (717- 787 - 0806). Failure to file such an appeal at the Commission within thirty (30) days may result in the dismissal of the appeal. i cerely, Vincent Dopk+o Chief Counsel