HomeMy WebLinkAbout97-012 ConfidentialI. ISSUE:
s .
STATE 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
Boyd E. Wolff
Julius Uehlein
DATE DECIDED: 8/14/97
DATE MAILED: 8/26/97
97 -012
Re: Commission A; Former Public Employee; Executive Director; Association B;
Expenses; Reimbursement; Payment; Confidential Opinion 97 -007.
This Confidential Opinion is issued in response to your letters dated June 30 and
July 2, 1997.
Whether the Public Official and Employee Ethics Law imposes any prohibition
or restrictions upon a former Executive Director in receiving payments from his former
governmental body for expenses incurred in attending meetings of an association of
which his former governmental body is a member.
II. FACTUAL BASIS FOR DETERMINATION:
An opinion is requested from this Commission as to whether the former
Executive Director of Commission A may obtain expense reimbursements from his
former governmental body under the Ethics Law.
This advisory request has its genesis in Confidential Opinion 97 -007 wherein we
concluded that the former Executive Director would be precluded by Section 3(g) of
Act 9 of 1989 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 -012
August 26, 1997
Page 2
The facts from the cited Opinion reflect that Mr. C prior to his retirement as the
Executive Director of Commission A was involved in the formation of a national
association which encourages more effective D. Mr. C is the current Chair of
Association B with his term expiring in December, 1997. Commission A approves of
Mr. C's association with Association B and wishes to take action, if legal under the
Ethics Law, to enable Mr. C to fulfill his commitment.
Commission A and Mr. C sought to enter into a contract whereby he would be
paid a stipend to enable him to complete his term with Association B by attending two
meetings.
The proposed contract for consulting services would allow Mr. C as a consultant
to continue to perform the functions and duties associated with Commission A's
membership in Association B which he performed while Executive Director. The
consultant would perform and file written reports with the current Executive Director
of Commission A. Compensation would be set not to exceed $400 per month.
Although the consultant would be responsible for his own expenses, he might receive
an office, supplies, telephone service, postage and photocopy services from
Commission A. The consulting agreement would place the consultant in the status of
an independent contractor. A dispute clause in the agreement would allow
Commission A to 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.
In ruling that Section 3(g) of the Ethics Law prohibited such an arrangement, we
noted:
... 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
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.
Confidential Opinion 97 -007 at 6.
Although the above decision is not challenged, it is now proposed that the
arrangement be modified so as to conform with the requirements of the Ethics Law.
Confidential Opinion 97 -007 is interpreted to mean that Mr. C is not prohibited
from serving as Commission A's representative at Association B provided he did not
receive promised or actual compensation as a monthly stipend and did not utilize
Commission A's office space, staff support, equipment or supplies.
It is now contemplated that Commission A will not enter into a consulting
contract with Mr. C and will not pay him a stipend nor permit him to use its facilities.
Confidential Opinion, 97 -012
August 26, 1997
Page 3
Instead, Mr. C will be appointed as an unpaid delegate which will allow him to
continue to serve as the Association B representative if he chooses. Mr. C may submit
a request for reimbursement of his reasonable expenses which the Commissioners in
the exercise of their discretion may pay to him. The decision of Commission A would
be final and not subject to challenge in any forum.
Mr. C attended Association B's planning meeting and has not received any
reimbursement for incurred expenses. If permissible under the Ethics Law,
Commission A will allow Mr. C to submit for its consideration a request for
reimbursement of expenses.
At the hearing on this case, Commission A's current Executive Director, Mr. G
and the Chief Counsel, Ms. H provided the following information and arguments.
As restated, the original proposed contract between Commission A and Mr. C
was to provide a monthly stipend so that Mr. C could represent Commission A before
Association B with Mr. C being responsible for his own expenses. Based upon our
Opinion that such conduct was prohibited by Section 3(g), the plan was revised so
that Mr. C would submit expenses to Commission A which has absolute discretion to
make whole, partial, or no expense reimbursement to Mr. C. The intent of the
agreement was to cover Mr. C's expenses and nothing else. The proposed agreement
was submitted to the Retirement Board which opined that such an arrangement was
consistent with the State retirement law.
After noting that Opinion 97 -007 contained dicta that Section 3(g) would not
prohibit such conduct provided there was no actual or promised compensation, it is
asserted that the reimbursement for Mr. C's expenses would merely make him whole
and could not be compensation since it is not equivalent to a salary or stipend. The
stipend was simply an estimate of expenses to reimburse Mr. C for his actual expenses
without any intent to provide compensation.
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 §11.1. Confidential Opinion 97 -007.
Section 3(g) provides:
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.
65 P.S. §403(g).
The term "represent" is defined as follows under the Ethics Law:
Confidential Opinion, 97 -012
August 26, 1997
Page 4
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.
65 P.S. §402.
Under the submitted facts, there is no contract between Commission A and Mr.
C nor is there any service to be provided by Mr. C to Commission A. Likewise,
Commission A will not provide any office equipment, personnel, or supplies to Mr. C.
All that Mr. C will do is submit expense invoices to Commission A which has absolute
discretion in paying or not paying such expenses. These unique facts in our view do
not constitute representation under Section 2 of the Ethics Law. There is no operative
interaction between Mr. C and Commission A so that representation cannot occur.
Stephens v. State Ethics Commission, 571 A.2d 1120 (1990). These facts constitute
an activity which is not the type of conduct that Section 3(g) of the Ethics Law
proscribes. Accordingly, the activity would not be prohibited by Section 3(g) of Act
9 of 1989.
In Tight of our holding, we need not address the issue of whether a payment of
a former employee's expenses is compensation. However, we question whether a
reimbursement of expenses (to a former employee) is not compensation but merely a
"wash" transaction making a person whole as to expenses. See, Synoski v. Hazle
Township, 500 A.2d 1282 (1985). We conclude that Section 3(g) does not apply to
these facts because there is no representation. Since one of the requisite elements
(represent) of Section 3(g) is not present, the Section does not apply. McGuire and
Marchitello v. SEC, 657 A.2d 1346 (1995).
This Opinion has addressed the applicability of the Ethics Law based upon the
facts which have been submitted. It is expressly assumed that there has been no use
of authority of office for a private pecuniary benefit as prohibited by Section 3(a) of
the Ethics Law. Further, Sections 3(b) and 3(c) of the Ethics Law provide in part that
no person shall offer to a public official /employee and no public official /employee shall
solicit or accept anything of monetary value based upon the understanding that the
vote, official action, or judgment of the public official /employee would be influenced
thereby. Reference is made to these provisions of the law not to imply that there has
been or will be any transgression thereof but merely to provide a complete response
to the question presented.
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 Law has not been considered in that they do not
involve an interpretation of the Ethics Law.
Confidential Opinion, 97 -012
August 26, 1997
Page 5
IV. CONCLUSION:
An Executive Director of an administrative agency of the Commonwealth of
Pennsylvania is a public employee subject to the Ethics Law. The former Executive
Director may receive payments from his former governmental body for expenses
incurred in attending meetings of an association of which his former governmental
body is a member.
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 party 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 party requesting reconsideration should present a
detailed explanation setting forth the reasons why the Opinion requires reconsideration.
B the Commission,
6
Daneen E. Reese
Chair