HomeMy WebLinkAbout97-007 ConfidentialSTATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PENNSYLVANIA 17120
OPINION OF THE COMMISSION
Before: Daneen E. Reese, Chair
Austin M. Lee, Vice Chair
Roy W. Wilt
Allan M. Kluger
Rev. Joseph G. Quinn
Julius Uehlein
DATE DECIDED: 5/29/97
DATE MAILED: 6/11/97
97 -007
Re: Commission A; Former Public Employee; Executive Director; Contract;
Association B; Representation; Section 3(g); Person; Compensation; Consultant;
Independent Contractor.
1997.
This Confidential Opinion is issued in response to your letter dated April 3,
I. ISSUE:
Whether the Public Official and Employee Ethics Law imposes any prohibition
or restrictions upon a former Executive Director in contracting with his former
governmental body to complete one of the functions he performed in his public
employment.
1I. FACTUAL BASIS FOR DETERMINATION:
Both Commission A and its former Executive Director request an opinion from
this Commission as to whether he is permitted under the Ethics Law to enter into a
contract with his former governmental body.
Commission A appointed Mr. C as Executive Director in May, 1986, in which
position he served until his retirement on January 31, 1997. In late 1991, Mr. C
became involved in the formation of a national organization whose objective is to
encourage more responsible and effective D. Membership focuses upon officials in
state executive and legislative branches, commissions similar to Commission A, and
private entities which regularly interact with government regulators. In December,
1993, Association B was officially formed. Mr. C served on Association B's first
Confidential Opinion, 97 -007
June 11, 1997
Page 2
executive committee. He was appointed First Vice Chair in December, 1994 and was
elected Chair in December, 1995 and again in December, 1996.
While employed with Commission A, Mr. C made a commitment to Association
B to serve as its Chair until his term expires in December, 1997. Commission A
approves of this commitment and continues to support Mr. C in his leadership of
Association B. In discharging his duties, Mr. C is satisfying a pledge he made as
Commission A's Executive Director which he could not have done if he were not
actively employed as a government official involved in E.
For several reasons, Commission A wants to take action, if legal, to enable Mr.
C to satisfy his commitment to Association B. First, Commission A is a charter
member of Association B and its system of E has been recognized as a model for other
member states. Second, because of his background and leadership role, Mr. C
continues to be an able representative in Association B. Finally, Commission A seeks
to enable Mr. C to fulfill his commitment which he made as Executive Director with
the full support and approval of Commission A. For personal reasons, Mr. C retired
before he could complete his current term as Chair.
Commission A and Mr. C want to enter into a contract whereby he would be
paid a stipend to enable him to complete his term with Association B. Funding for the
stipend is based upon previously submitted and approved budget estimates. The
contract would enable Mr. C to attend two meetings: the planning meeting in July and
the annual meeting in December. Mr. C would not be reimbursed for any travel
expenses. Mr. C's sole responsibility under the contract would be limited to
Association B activities. Mr. C would not resume any of his other former duties as
Executive Director and would be required to file periodic reports on his activities with
the new Executive Director. A draft copy of the contract has been submitted which
is incorporated herein by reference.
Commission A has reviewed Advice of Counsel No. 97 -537 and Confidential
Opinions 93 -005 and 89 -019 which are asserted to be not controlling in this matter.
Such rulings are argued to be distinguishable on the theory that they involve former
public employees who sought to contract with their former governmental bodies to
perform functions similar to those listed in their job descriptions for compensation
which was commensurate with their expertise. The Advice of Counsel is referenced
as involving an individual performing a specialized function for compensation based
upon her technical qualifications. The Opinions are interpreted as limited to fact
patterns involving employees who would terminate employment and seek to perform
the same functions as independent contractors. It is stated that the proposed contract
between Mr. C and Commission A is premised upon a different set of circumstances
in that he would not be performing any of the listed functions he performed as
Executive Director where he was responsible for overseeing all of Commission A's
internal operations. Rather, Mr. C would only be engaged for the limited purpose of
concluding his previous commitment made during his tenure with Commission A.
Serving as Commission A's Association B representative will entail substantial
travel and registration expenses; however, Mr. C will not be separately reimbursed for
such expenses. It is asserted that the monthly stipend paid to Mr. C will probably not
cover his out -of- pocket expenses, such that there will be virtually no consideration
accruing to him under the contract. Finally, unlike the requestors in the cited rulings,
Confidential Opinion, 97 -007
June 11, 1997
Page 3
Mr. C is fully retired, is not the owner of a consulting firm or any other business and
is not self - employed in any capacity.
The proposed contract for consulting services provides that Mr. C as a
consultant will continue to perform the functions and duties associated with
Commission A's membership in Association B which he performed while Executive
Director. The consultant will perform and file written reports to the current Executive
Director of Commission A. Compensation is set not to exceed $400 per month.
Although the consultant is responsible for his own expenses, he may receive an office,
supplies, telephone service, postage and photocopy services from Commission A. The
consulting agreement has a term from February 15, 1997 to December 15, 1997 with
the consultant in the status of an independent contractor. The consulting agreement
contains a dispute clause whereby Commission A will make the final decision subject
to the right of the consultant to file a claim with the Board of Claims of the
Commonwealth of Pennsylvania.
At the hearing on this case, Commission A's Chairman, Mr. F; the current
Executive Director, Mr. G; and the Chief Counsel, Ms. H provided the following
additional information and arguments.
Mr. C's participation and commitment to Association B was as an employee of
Commission A with its encouragement. Since Mr. C's term of office with Association
B is longer than his employment at Commission A, Association B has been given an
implied commitment from Commission A that Mr. C will serve out his term at
Association B. It is asserted that there would be no financial advantage because the
contract stipend covers only expenses for Mr. C as to Association B which would not
include any duties of the Executive Director.
When Mr. G was hired as the Executive Director of Commission A in December,
Mr. C had already made the commitment to Association B. Mr. C continued his
employment until January to assist in the transition. There is no intention for Mr. C
to perform any activities related to the operation of Commission A, only to fulfill a
commitment made as a Commission A employee to complete his term with
Association B.
Although Commission A could have retained Mr. C as an employee with a
changed job description limited to the Association B activity, Commission A proceeded
as set forth above. Because Mr. C as a non - employee cannot be reimbursed by
Commission A for his expenses, a stipend is proposed via the Agreement. However,
if a dispute would occur between Mr. C and Commission A under the Agreement, Mr.
C would be representing his own interests in such a dispute.
III. DISCUSSION:
In his former capacity as Executive Director of Commission A, Mr. C 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, 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,
Confidential Opinion, 97 -007
June 11, 1997
Page 4
leasing, regulating, auditing or other activities where the economic impact is greater
than de minimis on the interests of another person.
Consequently, upon termination of public service, Mr. C 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.
The governmental body with which Mr. C was employed was Commission A.
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.
The governmental body with which Mr. C was associated prior to termination
of public service would be Commission A. The above is based upon the language of
the Ethics Law, the legislative intent (Legislative Journal of House, 1989 Session, No.
15 at 290, 29 and the prior precedent of this Commission.
Therefore, within the first year after retirement by Mr. C from Commission A,
Section 3(g) of the Ethics Law would apply and restrict his representation of persons
or new employers vis -a -vis Commission A.
As to the restrictions under Section 3(g), we have enunciated such restrictions
in Popovich, Opinion 89 -005 and in other Opinions. However, we shall attempt to
summarize such restrictions. The Ethics Law does not affect one's ability to appear
before agencies or entities other than with respect to the former governmental body.
There is no general limitation on the type of employment in which a person may
engage, following departure from their governmental body. The intent of the Ethics
Law 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.
Confidential Opinion, 97 -007
June 11, 1997
Page 5
The one year restriction prohibits "representation." The Ethics Law defines
"Represent" as follows:
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.
We have interpreted the term "representation" 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;
2. Attempts to influence;
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.
We have 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. An example of an
application of the representation restriction of Section 3(g) would be that Mr. C may
not be identified on documents submitted to Commission A.
As to the prohibition against representing a "person" before the former
governmental body, we have held that the term includes a former public employee
representing himself in providing consulting services to his former governmental body.
Confidential Opinion 93 -005.
In applying Section 3(g) and our prior precedent to the instant matter, we
conclude that Mr. C is prohibited from representing himself for compensation before
his former governmental body, Commission A, within one year of termination of
service. The service Mr. C would perform is one of the functions he performed as
Executive Director. Mr. C would also be submitting "periodic reports" under his
signature to Commission A, his former governmental body. The compensation of
$400 per month is hardly a "nominal stipend," not to mention the office and services
he may receive from Commission A. Mr. C would be representing himself as is
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June 11, 1997
Page 6
evidenced by the description in the contract which designates him as a consultant
acting in the capacity of an independent contractor. In such capacity, Mr. C would no
longer be representing Commission A as an employee subject to all the strictures and
controls of Commonwealth employment. Mr. C would be representing himself and his
own interests which may not align with those of Commission A as is evidenced by the
"Dispute" clause in the proposed contract. Although it is argued that Mr. C's situation
is distinguishable from our prior precedent, no such distinctions are made in Section
3(g) or in our prior decisions. Mr. C's case is similar in all material respects to those
prior decisions. Accordingly, Section 3(g) of the Ethics Law precludes such
representation by Mr. C before his former governmental body, Commission A for a
period of one year after termination of service.
Our decision in this matter is consistent not only with the letter but also the
spirit of the Ethics Law. Section 3(g) of the Ethics Law aptly has been named as the
"revolving door" prohibition. The provision seeks to curtail the scenario of public
officials /employees leaving governmental service and then coming back before their
former governmental bodies to capitalize on their prior service by using their
connections with those bodies to their advantage in their new private endeavors for
financial gain. Two major areas of concern are: first, former public officials /employees
using their contacts or knowledge of operations within their former governmental
bodies for the benefit of their new employers or clients; and second, former public
officials /employees using their former employment to their advantage in obtaining
consulting contracts with their former governmental bodies.
The Ethics Law in our view is not harsh in its application to this case for two
reasons. First, if Mr. C had completed his public employment at the end of the year,
he could have accomplished this particular service. However, he chose an early
retirement which subjects him to the prohibition of Section 3(g) for the one -year
period. Commission A has acknowledged that there was an awareness of this option
but for whatever reasons, that course of action, which could have alleviated this
problem under the Ethics Law, was not pursued. Second, Mr. C could perform such
service as long as he would not take any "promised or actual compensation" which
would consist of the monthly "stipend" plus any other benefits such as an office, staff
support, equipment or supplies. Thus, Section 3(g) would not bar Mr. C from
engaging in the consulting services for Commission A provided he did not receive any
promised or actual consideration.
Lastly, the propriety of the proposed conduct has only been addressed under
Section 3(g) of 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.
IV. CONCLUSION:
An Executive Director of an administrative agency of the Commonwealth of
Pennsylvania is a public employee subject to the Ethics Law. Section 3(g) of the
Ethics Law precludes a former public employee from entering into a contract with his
former governmental body within one year of termination of service to provide services
for compensation.
Confidential Opinion, 97 -007
June 11, 1997
Page 7
Pursuant to Section 7(10), 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.
Finally, any person may request the Commission to reconsider its Opinion. The
reconsideration request must be received at this Commission within thirty days of the
mailing date of this Opinion. The person requesting reconsideration should present a
detailed explanation setting forth the reasons why the Opinion requires reconsideration.
By the Commission,
iroamu6 aL41._J
Daneen E. Reese
Chair
Vice Chair Austin M. Lee and Commissioner Julius Uehlein dissent.