HomeMy WebLinkAbout92-604Mr. Claire L. Peeling
R.D. #10, Box 108
York, PA 17404
Dear Mr. Peeling:
STATE ETHICS COMMISSION
309fINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 17108 -1470
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
June 18, 1992
92 -604
Re: Claims Investigation Agent II; Office of Fraud and Abuse
Investigations and Recovery; Bureau of Child Support
Enforcement; Department of Public Welfare; Public Employee;
FIS.
This responds to your Financial Disclosure Appeal dated May 1,
1992, which will be treated as a request for advice from the State
Ethics Commission.
Issue: You ask whether in your capacity as a Claims Investigation
Agent II with the Office of Fraud and Abuse Investigations and
Recovery (OFAIR), Bureau of Child Support Enforcement, Department
of Public Welfare (DPW), you are to be considered a "public
employee" as that term is defined in the Public Official and
Employee Ethics Law.
Facts: You state that you do not have anything to disclose and
should not be required to file a Statement of Financial Interests.
You question whether your activities and functions fall within the
purview of the definition of "public employee" as that phrase is
defined in the Ethics Law and the regulations of this Commission.
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 for this position. Your job
description and your organizational chart have been obtained from
DPW and are incorporated herein by reference.
According to your job description, you function as a Field
Agent II for the Bureau of Child Support Enforcement. You are
required to work closely with and coordinate the activities: of
various judicial and governmental agencies involved with the Child
Support Program in an assigned geographical area. This includes
providing assistance and guidance in the completion and proper
handling of support referrals; representing the Department's
Mr. Claire L. Peeling
June 18, 1992
Page 2
interest in support conferences and hearings; clarifying and
interpreting policy; monitoring case work load to ensure efficient
and timely handling of cases; preventing backlogs and identifying
and initiating enforcement actions for support collection and
paternity establishment. In dealing with the public and judicial/
governmental officials, you are to promote working relationships
which assure the effectiveness of DPW's programs and that the
obligations due the Commonwealth are protected and satisfied.
Agents in your classification are required to be thoroughly
knowledgeable of State and Federal child support program law and
regulations and application at the local program level so as to be
able to assess the degree and effectiveness of its implementation.
Your compliance review function requires an ability to inculcate
policy and recommend necessary programatic alterations to produce
needed improvements.
The duties of your position require that you investigate,
assemble, analyze data and prepare the needed documentation and /or
reports to effectively complete case assignments. You are required
to perform your work at a level that assures the proper selection,
preparation and prosecution of fraud cases to achieve a high level
of successful prosecutions. You operate under moderate
supervision. Your duties and responsibilities may also include
such other duties as are set forth in the incorporated job
description.
Discussion: The question to be answered is whether, in your
capacity as a Claims Investigation Agent II for OFAIR, Bureau of
Child Support Enforcement, Department of Public Welfare (DPW), you
are to be considered a "public employee." The Ethics Law defines
that term as follows:
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 aide minimis nature on the in tere
of any person.
Mr. Claire L. Peeling
June 18, 1992
Page 3
65 P.S. §402.
"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.
The regulations of the State Ethics Commission similarly
define the term - public employee as above and also set forth that
the term includes any individual:
(B) Who meets the criteria of either
subcl.ause (I) or (II):
(I) The individual is:
(a) a person who normally performs his
responsibility in the field without on-
site supervision;
(b) the immediate supervisor of a person
who normally performs his responsibility
in the field without on -site supervision;
or
(c) the supervisor of any highest level
field office.
(II) The individual is a person:
(a) who:
(1) has the authority to make final
decisions;
(2) has the authority to forward or
stop recommendations from being sent
to the person or body with the
authority to make final decisions;
(3) prepares or supervises the
preparation of final recommen-
dations; or
(4) makes final technical recommen-
dations; and
(b) whose recommendations - or
actions:
Mr. Claire L. Peeling
June 18, 1992
Page 4
(1) are an inherent and recurring
part of his position; and
(2) affect organizations other than
his own organization.
(ii) 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.
(iii) Persons in the positions listed below
are generally considered public employees.
(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 before
the public.
(D) Solicitors, engineers,
managers, and secretary- treasurers
acting as managers, police chiefs,
chief clerks, chief purchasing
agents, grant and contract managers,
housing and building inspectors,
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 business managers and
principals.
(iv) Persons in the positions listed below are
generally not considered public employees.
Mr. Claire L. Peeling
June 18, 1992
Page 5
51 Pa. Code S1.1.
(A) City clerks, other clerical
staff, road masters, secretaries,
police officers, welfare case
workers, maintenance workers,
construction workers, detectives,
equipment operators, and recreation
directors.
(B) Law clerks, court criers, court
reporters, probation officers,
security guards, and writ servers.
(C) School teachers and clerks of
the schools.
We must review the question you present 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. Our
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. Cmwlth. 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 us to construe
coverage of the Ethics Act 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, we must conclude that you are a
"public employee" subject to the financial reporting and disclosure
requirements of the Ethics Law.
It is clear that in your capacity as a Claims Investigation
Agent II for DPW's OFAIR, Bureau of Child Support Enforcement, you
have the ability to .recommend official action with respect to
subparagraph (5 within the definition "public employee" as set
forth in the Ethics Law, 65 P.S. 8402. Specifically, you
investigative, assemble, analyze data and prepare needed
documentation and /or reports to effectively complete case
assignments. You provide assistance and guidance in the completion
and proper handling of support referrals. You represent DPW
interest in support conferences and hearings and identify . and
initiate enforcement actions for support collection and paternity
Mr. Claire L. Peeling
June 18, 1992
Page 6
establishment. You perform your work at a level that assures the
proper selection, preparation and prosecution of fraud cases to
achieve a,high level of successful prosecutions. •Additionally, you
perform a compliance review function which requires an ability to
inculcate policy and to make recommendations for necessary
programatic alterations to produce needed improvements. These
activities fall within the definition of public employee as
contained in the regulations of the Commission in Section 1.1,
subparagraph (i)(A) and (B)(II). 51 Pa. Code 1.1. 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. See, Garlan Opinion 89 -004 (Professional
Conduct Investigator for the Department of State is a public
employee required to file the Statement of Financial Interests; see
also, Phillips v. Com., State Ethics Commission, 79 Pa. Commw. 491,
470 A.2d 659 (1984) (Affirming the Commission's adjudication that
a Claim Settlement Agent I for DPW is a public employee pursuant to
the Ethics Act and required to file a Statement of Financial
Interests).
Conclusion: You are to be considered a "public employee" in your
capacity as a Claims Investigation Agent II for the Office of Fraud
and Abuse Investigations and Recovery (OFAIR), Bureau of Child
Support Enforcement with the Commonwealth of Pennsylvania,
Department of Public Welfare (DPW). 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 with your Department within 15 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
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 request that the full Commission
review this Advice. A personal appearance before the Commission
will be scheduled and a formal Opinion from the Commission will be
issued. Any such appeal must be in writing and must be received at
rir. Claire L. Peeling
June 18, 1992
Page 7
the Commission within 15 days of the date of this Advice pursuant
to 51 Pa. Code S2.12..
Sincerely,
Vincent J. Dopko
Chief Counsel
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