HomeMy WebLinkAbout81-004 BaxterSTATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PENNSYLVANIA 17120
January 27, 1981
OPINION OF THE COMMISSION
The Honorable Brian T. Baxter
Deputy Secretary for Employee Relations
Office of Budget and Administration
207 Finance Building
Harrisburg, PA 17120
RE: Applicability, Impact of Ethics Act
Dear Deputy Secretary Baxter:
I. Issue:
II. Factal Basis for Determination:
81 -004
You request that we review the impact of the Ethics Act
upon the proposed Governor's Executive Exchange Program,
hereinafter referred to as the "program."
The Governor is interested in filling a small number of
key senior positions through the establishment and implementa-
tion of an exchange program. Basically, the idea is to provide
the Commonwealth with expertise of individuals from the private
sector through a service purchase contract mechanism (SPC).
The program is designed to bring into government some of the
best business and private talent while allowing the individuals'
in the program to remain on the payroll of their private employer.
Recognizing, the ever - growing disparity in renumeration of
executives in the private versus the public sector, such an
arrangement, you suggest, is the only practical manner by which
to attract certain talent to government service.
The SPC would typically and technically be made between
the Commonwealth and the private business or corporation by
whom the individual to be "exchanged" is employed. However,
you indicate that the essential services being "purchased"
under this contract are for the services of particular indivi-
duals on a continuing basis. The SPC that you provided to us
as an example of the one to be used in this Program, provides
that persons "exchanged" to serve the Commonwealth would in
relation to fiscal accounting services:
1. provide direct supervision and technical assistance
to agency comptrollers in the application of accoun-
ting policies and procedures;
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January 27, 1
Page 2
2. develop, design, and implement a centralized ADP /EDP
operation which meets the needs of the centralized
data management operations.
3. develop, coordinate, and integrate ADP /EDP operations
in the various agencies of the Commonwealth into a
unified, efficient, and economical data management
system.
4. evaluate the short- and long -term needs of the Common-
wealth in both the account management and data managem-
ent systems; and develop, with Commonwealth managers,
the alternatives to meet these needs.
5. advise the Governor and his Cabinet members on current
and developing "state of the art" factors which •
impact on the management of Commonwealth operations.
6. develop, design, and implement a fiscal accounting
system which efficiently meets the legal and manage-
ment needs of the Commonwealth of Pennsylvania.
These tasks would be performed using Commonwealth facili-
ties, supplies, etc.; and "exchanged" executives under this
program would operate out of a Commonwealth office and conform
to the typical work schedule of Commonwealth employees. They
would supervise regular complement employees. They would be
subject to the direction of a Commonwealth official. In the
above instance, for example, the Secretary of Budget and Admini-
stration would provide "work direction."
It should be noted that the sample contract you provided
in Section 3 states that the contractor is performing these
tasks as an "independent contractor."
III. Applicable Law:
The most pertinent provision of the Ethics Act is Section
2, which in its definition of "public employee" provides:
"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
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January 27, 1
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IV. Discussion:
ian T. Baxter
(5) any other activity where
the official action has an
economic impact of greater
than a de minimus nature on
the interests of any person.
Public employee shall not include
individuals who are employed by the
State or any political subdivision
thereof in teaching as distinguished
from administrative duties." 65 P.S. 402.
Also pertinent are the following sub - sections of Section 3:
(a) "No public official or public
employee shall use his public
office or any confidential
information received through his
holding public office to obtain
financial gain other than compen-
sation provided by law for himself,
a member of his immediate family,
or a business with which he is
associated." 65 P.S. 403(a). and
(e) "No former official or public
employee shall represent a person,
with or without compensation, on
any matter before the governmental
body with which he has been
associated for one year after he
leaves that body." 65 P.S. 403(e).
Initially, we must state clearly and unequivocally that
the Commission finds no prohibition under the Ethics Act to •
this proposed program, in general. In fact, the Ethics Act
does not bar the Commonwealth from implementing this laudable
program or even speak to this question, per se. Accordingly,
we can only address the question of the application or impact
of the Ethics Act to persons "exchanged" and supplying services
to the Commonwealth under this program. We note that the
corporations from which these persons come are not within the
scope of this decision.
The basic question becomes: Are persons "exchanged" and
serving the Commonwealth under this program "public employees"
within the coverage of the Ethics Act and if so, what standards
of conduct are expected of them by that Act? Answering this
question involves a review of the nature of the contract in
question, the manner in which the contract is performed and the
purposes of the Ethics Act, as well as its specific provisions.
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January 27, 14,__
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Turning to the contract first, we must deal with the fact
that the parties to the contract would typically be the Common-
wealth and the business or corporation for whom the "exchanged"
executive typically works. Typically, persons serving under
such a contract would not be deemed employees of the Common-
wealth; they would remain attached to the corporation's compli-
ment as employees. The corporation and persons it supplies to
perform the contract would be considered independent contrac-
tors. In the unique factual context of this contract, however,
we must look beyond the technical parties to this contract. In
doing so we find that, in most cases, the Commonwealth is, in
reality, purchasing the continuing services of particular
persons, executives or experts. The contract provides for this
relationship as opposed to one which might be limited in dura-
tion or scope.
The "exchanged" executive is in reality, not performing a
specific task as an employee of the coporation with whom the
Commonwealth contracted, but is engaged in supplying continuing
services to the Commonwealth. This person is no longer within
the control of the corporation, but the right to control and
direct the activities of this person in relation to the contract
has effectively been placed with the Commonwealth official who
is directing the work. This transfer of the right to control
the manner and execution of the work to be done is a basic
indicator that an employment relationship exists between the
Commonwealth and the "exchanged" executive.
In addition to meeting this basic test as an employee -
employer relationship, the work being done by the "exchanged"
executive is essentially work which would be done by full -time
regular employees of the Commonwealth. This work is done using
state equipment and supplies, during regular state work hours
and on state property. The role of this "exchanged" executive
is even more clear when the contract gives him the right to
supervise other state employees in meeting the contract goals.
In such a unique circumstance the Commission must conclude that
a person serving under this exchange program should be consi-
dered an "employee" in the generic sense. Accord Massiah- Jackson,
80 -036. Recently, the Commonwealth Court agreed with the
Commission that the presence of a common law relationship of
master - servant was not required in order to apply the Ethics
Act to "public employees." Accordingly, persons arguably and
technically thought of as independent contractors will have no
recourse to "finicky and precious considerations which attend
the process of distinguishing a servant from an independent
contractor." Ballou v. State Ethics Commission, Pa.
Cmwlth. Ct. , A.2d (No. 1013 C.D. 1980, issued January
22, 1981.)
Finally, the purpose of the Act states that the public has
a right to be assured that those in a position of public trust
should not have conflicts of interest or even a ear to have
such conflicts. See Section 1, 65 P.S. 401. t is evident
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January 27, 19.
Page 5
C
that persons serving in this program would serve at the higher
levels of state government. By your own description, they
would serve in "key" posts. As such, we must find that they
would serve in a position of trust which should be covered by
the Ethics Act to insure that the protections provided by that
Act prevail. These persons, typically would be in positions of
taking or recommending official action of a nonministerial
nature with respect to the areas outlined in the Ethics Act.
Accordingly, in light of the above discussion as a whole, we
must conclude that persons serving in this program would
generally be considered "public employees" within the coverage
of the Ethics Act.
Having arrived at this conclusion the impact of this
finding must be assessed. First, as "public employees ", persons
serving under this program would generally be required to file
Financial Interest Statements for each year they serve in the
program and for the year after they leave their position with
the Commonwealth. Second, no public employee may use confiden-
tial information gained while, in this instance, serving with
the Commonwealth. Thus, an exchange program worker could not
use information not available to the general public for his own
gain or forward such information to be used by his corporate
employer for that corporation's gain. Norris, 80 -053. Third,
this worker could not use his public employment to recommend
action which might uniquely benefit his corporate employer.
Kelmeckis, 80 -047. For example, if the person was developing
an efficient automated check processing method, he could not
recommend the purchase of a particular machine to process
checks, if his corporate employer happened to be the sole
supplier of the particular machine recommended.
While the above three criteria relate to the restrictions
- placed on these persons as "public employees" the Ethics Act
also places restrictions on former public employees. Thus,
when these persons have left the exchange program with the
Commonwealth, they face restrictions under Section 3(e) of the
Ethics Act. Section 3(e) of the Act in this instance would
prohibit a former "public employee" from appearing and represen-
ting any person before the governmental body with which he was
associated for a one -year period following termination of state
service. It would be impossible to deliniate the scope of the
term "governmental body" here because that review requires
specific facts and individual analysis. This question must, if
required, be answered on a case -by -case basis. In general,
however, the Commission in determining the scope of the phrase
"governmental body with which he was associated" has applied a
simple concept. The "governmental body" with which a former
employee has been associated should cover the bodies where he
had influence. See Kline, 79 -001 and Seltzer, 80 -044.
The Commission has also interpreted the concept expressed
in the prohibition against a former employee "appearing" or
"representing" any person before this governmental body. In
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January 27, 19
Page 6
particular, the Commission has held that the conduct of former
employees should conform to the following standards:
1. Personal appearances before the former governmental
body are prohibited. Morris, 80 -039. This includes
negotiating contracts; except that a former employee
may administer a contract awarded to his employer by
his former governmental body.
2. Attempts to influence the former governmental body
are prohibited. Covill, 79 -041, Cutt, 79 -023 and
Seltzer, supra.
3. Generally, informational inquiries to the governmental
body and utilizing knowledge and expertise gained
through public employment are not barred. Morris,
supra.
4. Appearing in a third forum such as state or federal
court is not barred. Berger, 79 -060.
5. Expressing your own opinions and views on your own
behalf is not prohibited; Lloyd, 80 -040. This is to
be distinguished from representing the views and /or
interests of any other person either formally or
informally. This action which would include,
generally, the concept of "lobbying" is prohibited
for the one -year period as to the identified govern-
mental bodies.
6. Preparing bid proposals to be submitted to the former
governmental body by the executive's employer where
that preparation includes the executive signing those
proposals and /or if the former employee's name appears
on the proposal as the person primarily responsible
for providing technical assistance on or administer-
ing the contract, if awarded, is prohibited. A
former employee may assist in preparing bids where
none of the above references are made in the bid and
where the former employee is not to assume any of
these roles.
7. Participating in any manner in any case or contract
over which you had supervision, direct involvement,
or responsibility while employed by the Commonwealth
except as set forth in No. 1, above is prohibited.
V. Conclusion:
Under the unique factual circumstances presented by the
proposed exchange program and the purposes of the Ethics Act,
we concluded that persons serving in this program should be
considered "public employees" within the coverage of the Ethics
Act. This imposes the following duties and obligations upon a
person in this program:
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January 27, 19L
Page 7
1. He must file a Financial Interest Statement for each
year he serves the Commonwealth under this program
and for the year after he terminates such service.
2. He must not utilize confidential information gained
in his public employment for his private gain or that
of his family. He may not transmit any such infor-
mation to his corporate employer for the gain or
advantage of said employer. He must refrain from
voting or recommending actions which would inure
solely to his personal benefit or to the benefit or
gain of his corporate employer.
3 He may not appear or represent any person before the
governmental body with which he is found to have been
associated for a one -year period after he leaves
state service. The term "representing" includes
these activities listed below:
a.- personal appearance before the former govern-
mental body;
b. Negotiating contracts with that body;
c. attempting to influence that body by lobbying or
otherwise;
d. preparing, signing and submitting bid proposals
to that body or allowing his name to appear in
such a proposal as preparer or proposed parti-
cipant in the contract if awarded;
e. participating in any manner on a case or matter
over which he had direct supervision, involve-
ment, or responsibility while serving with the
program, except that he could administer a
contract as opposed to negotiating it as prohi-
bited in "b" above.
The corporation by which an exchanged executive is employed
is not affected by this ruling.
Pursuant to Section 7(9)(i), this opinion is a complete
defense in any enforcement proceeding initiated by the Commis-
sion, and evidence of good faith conduct in any 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.
PJS /rdp
AUL, s I H
Chai ►r an