HomeMy WebLinkAbout96-612 ErneyJoan L. Erney
Department of Public Welfare
Office of Mental Health
PO Box 2675
Harrisburg, PA 17105 -2675
STATE ETHICS COMMISSION
309 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 17108 -1470
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
December 4, 1996
96 -612
Re: Former Public Employee; Section 3(g); Department of Public Welfare, Office of
Mental Health, Executive Assistant to Deputy Secretary.
Dear Ms. Erney:
This responds to your letter of October 31, 1996 in which you requested advice
from the State Ethics Commission.
Issue: Whether the Public Official and Employee Ethics Law presents any
restrictions upon employment of an Executive Assistant to the Deputy Secretary of the
Office of Mental Health following termination of service with the Department of Public
Welfare.
Facts: You have served as the Executive Assistant to Deputy Secretary Charles
Curie in the Office of Mental Health (OMH), Department of Public Welfare (DPW). You
have resigned that position effective November 29, 1996. As of December 1, 1996,
you have assumed the position of Chief Operating Officer at Community Behavioral
HealthCare Network of Pennsylvania (CBHNP).
CBHNP is a new provider organization established to do managed care
contracting in both the commercial and public sectors, including 104 community
mental health, mental retardation and drug and alcohol agencies across Pennsylvania.
CBHNP has submitted an application to the Departments of Insurance and Health for
licensure as a risk bearing PPO. Your position at CBHNP is to prepare the providers
for managed care business as well as oversee the operations of the company. You are
a licensed attorney, however you state that you do not anticipate representing CBHNP
in that capacity.
As Executive Assistant in the OMH, you have been a member of the OMH
Executive Staff. You state that you have acted on behalf of the Deputy in many
arenas including upper level DPW executive meetings and in presentations to the
community. You have been actively involved with the behavioral health managed care
project and have assisted the OMH project manager in developing the HealthChoices
Ernev, 96 -612
December 4, 1996
Page 2
behavioral health RFP and the federal waiver application. You state that you have
acted as a contact person for other program offices including the Office of Children,
Youth and Families and the Office of Mental Retardation; however, you have not had
any operational responsibility or decision making authority for any program office
outside of the OMH. Copies of your job description, classification specifications, and
organizational chart have been obtained and are incorporated herein by reference.
You seek an advisory as to the restrictions of the Ethics Law which apply to
former public officials /public employees during the one year period following
termination of their public service. You pose the following specific inquiries:
1. You ask whether you are precluded from representing CBHNP for one year in
matters dealing with the OMH or whether the prohibition includes all offices
within DPW.
2. You ask whether you are precluded from representing CBHNP in matters dealing
with the Department of Insurance or Health, such as, for example, in meeting
with the Departments of Insurance and Health related to the licensure
application that has been submitted by CBHNP.
3. You ask whether you can participate in meetings that OMH convenes to develop
policies and /or procedures for mental health or drug and alcohol services, and
whether you are prohibited from attending public meetings or workgroups which
are convened by any program office within DPW, such as the Medical
Assistance Advisory Committee or an Office of Children, Youth and Families
workgroup on managed care.
4. You ask whether you can represent CBHNP at non - adversarial public hearings
(not constituting litigation) hosted by OMH /DPW, such as public hearings hosted
by the Office of Medical Assistance regarding statewide expansion of Medicaid
managed care.
5. You ask whether your employment at CBHNP affects the ability of any other
executive staff of CBHNP from representing CBHNP in matters dealing with
OMH /DPW, and whether CBHNP would be prohibited from submitting a
response to an RFP issued by either OMH /DPW.
Discussion: It is initially noted that you have requested advice under a specific
provision of the Ethics Law, Section 3(g). This advice is limited to addressing that
specific section.
It is also initially noted that you are a lawyer, and that Section 3(g) does not
apply to restrict a lawyer insofar as his conduct constitutes the practice of law.
Spataro, Opinion 89 -009. To the extent his conduct does not constitute the practice
of law, however, the restrictions do apply to restrict a former public official /public
employee even though he is a lawyer.
In your former capacity as an Executive Assistant to the Deputy Secretary in the
OMH of DPW, you would be considered a "public employee" within the definition of
that term as set forth in the Public Official and Employee Ethics Law and the
Regulations of this Commission. 65 P.S. §402; 51 Pa.Code § 1 1.1. This conclusion
is based upon the job description, which when reviewed on an objective basis,
Ernev, 96 -612
December 4, 1996
Page 3
indicates clearly that the power exists to take or recommend official action of a non -
ministerial nature with respect to contracting, procurement, planning, inspecting,
administering or monitoring grants, leasing, regulating, auditing or other activities
where the economic impact is greater than de rninimis on the interests of another
person.
Consequently, upon termination of public service, you became a "former public
employee" subject to Section 3(g) of the Public Official and Employee Ethics Law.
Section 3(g) of the Ethics Act provides that:
Section 3. Restricted activities.
(g) No former public official or public employee
shall represent a person, with promised or actual
compensation, on any matter before the governmental body
with which he has been associated for one year after he
leaves that body.
Initially, to answer your request the governmental body with which you were
associated while working with the OMH must be identified. Then, the scope of the
prohibitions associated with the concept and term of "representation" must be
reviewed.
The term "governmental body with which a public official or public employee
is or has been associated" is defined under the Ethics Law as follows:
Section 2. Definitions.
"Governmental body with which a public official or
public employee is or has been associated." The
governmental body within State government or a political
subdivision by which the public official or employee is or
has been employed or to which the public official or
employee is or has been appointed or elected and
subdivisions and offices within that governmental body.
It is noted that Act 9 of 1989 significantly broadened the definition of the term
"governmental body with which a public official or public employee is or has been
associated." It was the specific intent of the General Assembly to define the above
term so that it was not merely limited to the area where a public official/ employee had
influence or control but extended to the entire governmental body with which the
public official /employee was associated. The foregoing intent is reflected in the
legislative debate relative to the amendatory language for the above term:
We sought to make particularly clear that when we
are prohibiting for 1 year that revolving -door kind of
conduct, we are dealing not only with a particular
subdivision of an agency or a local government but the
entire unit..." Legislative Journal of House, 1989 Session,
No. 15 at 290, 291.
Erney, 96 -612
December 4, 1996
Page 4
The Ethics Law must be construed to ascertain and effectuate the intent of the
General Assembly under 1 Pa. C.S.A. §1901.
Based upon the above, the governmental body with which you were associated
upon termination of public service would be DPW in its entirety, including but not
limited to the OMH. The above is based upon the language of the Ethics Law, the
legislative intent (Legislative Journal of House, 1989 Session, No. 15 at 290, 291) and
the prior precedent of this Commission. Thus, in Sirolli, Opinion 90 -006, the
Commission found that a former Division Director of the Department of Public Welfare
(DPW) was not merely restricted to the particular Division as was contended but was
in fact restricted to all of DPW regarding the one year representation restriction.
Similarly in Sharp, Opinion 90- 009 -R, it was determined that a former legislative
assistant to a state senator was not merely restricted to that particular senator but to
the entire Senate as his former governmental body.
Therefore, within the first year after termination of service with the OMH,
Section 3(g) of the Ethics Law would apply and restrict representation of persons or
new employers vis -a -vis DPW in its entirety.
Turning now to the scope of the restrictions under Section 3(g), the Ethics Law
does not affect one's ability to appear before agencies or entities other than with
respect to the former governmental body. Likewise, there is no general limitation on
the type of employment in which a person may engage, following departure from their
governmental body. It is noted, however, that the conflicts of interest law is primarily
concerned with financial conflicts and violations of the public trust. The intent of the
law generally is that during the term of a person's public employment he must act
consistently with the public trust and upon departure from the public sector, that
individual should not be allowed to utilize his association with the public sector,
officials or employees to secure for himself or a new employer, treatment or benefits
that may be obtainable only because of his association with his former governmental
body.
In respect to the one year restriction against such "representation," the Ethics
Law defines "Represent" as follows:
The Commission, in Popovich, Opinion 89 -005, has also interpreted the term
"representation" as used in Section 3(g) of the Ethics Law to prohibit:
1. Personal appearances before the former governmental body or bodies,
including, but not limited to, negotiations or renegotiations in general or as to
contracts;
Section 2, Definitions.
"Represent." To act on behalf of any other person in
any activity which includes, but is not limited to, the
following: personal appearances, negotiations, lobbying and
submitting bid or contract proposals which are signed by or
contain the name of a former public official or public
employee.
2. Attempts to influence;
Ernev, 96 -612
December 4, 1996
Page 5
3. Submission of bid or contract proposals which are signed by or contain
the name of the former public official /employee;
4. Participating in any matters before the former governmental body as to
acting on behalf of a person;
5. Lobbying, that is representing the interests of any person or employer
before the former governmental body in relation to legislation, regulations, etc.
The Commission has also held that listing one's name as the person who will
provide technical assistance on such proposal, document, or bid, if submitted to or
reviewed by the former governmental body constitutes an attempt to influence the
former governmental body. Section 3(g) would also prohibit in general the inclusion
of the name of a former public official /public employee on invoices submitted by his
new employer to the former governmental body, even though the invoices pertain to
a contract which existed prior to termination of public service. Shay, Opinion 91 -012.
However, in the event of work performed on a contract already awarded and not
involving the unit where the former public employee worked, the name of the former
public employee may appear on routine invoices if required by the regulations of the
agency to which the billing is being submitted. Abrams /Webster, Opinion 95 -01 1.
Therefore, within the first year after termination of service, you should not engage in
any of the prohibited activities outlined above.
You may assist in the preparation of any documents presented to DPW.
However, you may not be identified on documents submitted to DPW. You may also
counsel any person regarding that person's appearance before DPW. Once again,
however, the activity in this respect should not be revealed to DPW. Of course, any
ban under the Ethics Law would not prohibit or preclude the making of general
informational inquiries of DPW to secure information which is available to the general
public. This must not be done in an effort to indirectly influence the former
governmental body or to otherwise make known to that body the representation of,
or work for the new employer.
In addition, the term "Person" is defined as follows under the Ethics Law:
Section 2. Definitions.
"Person." A business, governmental body, individual,
corporation, union, association, firm, partnership,
committee, club or other organization or group of persons.
In applying the definition of "Person" quoted above, the Commission has held
that the term includes a former public employee representing himself in providing
consulting services to his former governmental body. Confidential Opinion 93 -005.
Further, the term "Person" includes a new government employer which is represented
by the former public employee before his former governmental employer. Ledebur,
Opinion 95 -007.
Turning to your specific inquiries, in response to your first specific inquiry, as
noted above, the restrictions of Section 3(g) apply as to representation before DPW
in its entirety, including but not limited to the OMH.
Ernev, 96 -612
December 4, 1996
Page 6
As for your second specific inquiry, as noted above, the restrictions of Section
3(g) are applicable as to your former governmental body, DPW, and do not apply to
restrict you in your conduct before other governmental bodies.
As for your third specific inquiry, you may not engage in any participation at
meetings, public or otherwise, which would constitute prohibited representation before
your former governmental body. However, mere attendance at a public meeting in
your capacity as a member of the general public, where you would conduct yourself
as a member of the general public and would not engage in conduct constituting
representation of your new employer, would not contravene Section 3(g).
As for your fourth specific inquiry, representation of CBHNP before your former
governmental body in any matter (other than as a lawyer engaged in the practice of
law) would be prohibited.
As for your fifth specific inquiry, you are advised that the restrictions of Section
3(g) apply to restrict you as a former public employee, and do not apply to restrict
CBHNP itself or others employed by it who are not themselves subject to Section 3(g).
Lastly, the propriety of the proposed conduct has only been addressed under the
Ethics Law; 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 Law. Specifically not addressed herein is the
Governor's Code of Conduct.
Conclusion: In your former capacity as Executive Assistant to the Deputy
Secretary of the Office of Mental Health (OMH) in the Department of Public Welfare
(DPW), you would be considered a "public employee" as defined in the Ethics Law.
Upon termination of service with the OMH, you became a "former public employee"
subject to Section 3(g) of the Ethics Law. The former governmental body is DPW in
its entirety, including but not limited to the OMH. The restrictions as to representation
outlined above must be followed. The propriety of the proposed conduct has only
been addressed under the Ethics Law.
Further, should service be terminated, as outlined above, the Ethics Law also
requires that a Statement of Financial Interests be filed for the year following
termination of service.
Pursuant to Section 7(11), 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.
This letter is a public record and will be made available as such.
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.
Ernev, 96 -612
December 4, 1996
Page 7
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 § 13.2(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.
Vincent J. Do ko
Chief Counsel