HomeMy WebLinkAbout22-516 Kishbaugh
PHONE: 717-783-1610 STATE ETHICS COMMISSION FACSIMILE: 717-787-0806
TOLL FREE: 1-800-932-0936 FINANCE BUILDING WEBSITE: www.ethics.pa.gov
613 NORTH STREET, ROOM 309
HARRISBURG, PA 17120-0400
ADVICE OF COUNSEL
March 31, 2022
To the Requester:
Kay E. Kishbaugh
22-516
Dear Kay E. Kishbaugh:
This responds to your letter dated March 14, 2022, by which you requested an advisory
from the Pennsylvania State Ethics Commission (Commission), seeking guidance as to the
general issue presented below:
Issue:
Whether the Public Official and Employee Ethics Act (Ethics Act), 65 Pa.C.S. § 1101 et
seq., would impose restrictions upon you with regard to working as a consultant to the
Pennsylvania Department of State following termination of
service with the Department of State as an annuitant under the 95-
Brief Answer: YES. During the first year following termination of your service with the
Department of State as an annuitant, Section 1103(g) of the Ethics Act would apply and
prohibit you from working as a consultant to the Department of State as such activity would
constitute prohibited representation of a person specifically, yourself as a consultant
before your former governmental body, the Department of State.
Facts:
You request an advisory from the Commission based upon submitted facts that may be
fairly summarized as follows.
In August 2019, you retired from your employment with the Pennsylvania Department of
Transportation. In October 2020, you returned to work with the Department of State as an
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March 31, 2022
Page 2
annuitant under the 95-rovision at 71 Pa.C.S. § 5706(A.1) -
Director of the Bureau of Corporations and Charitable Organizations within the Department of
State. From October 2021 to the present, you have served as the Executive Assistant to the Deputy
Secretary for Regulatory Programs. You have submitted a copy of a position description (the
by
reference. A copy of the job classification specifications for the position of Executive Assistant
(job code 08260) has been obtained and is also incorporated herein by reference.
Because you are involved in multiple modernization efforts, you were asked if you would
consider working as a consultant to the Department of State under the Commonwealth OST
contract once your service as an annuitant has terminated. This is primarily because your annuitant
service would terminate prior to one modernization effort going live in September 2022 and while
the other modernization effort is still in the requirement gathering stage.
Based upon the above submitted facts, you seek guidance as to whether the Ethics Act
would impose any prohibitions or restrictions upon you following termination of your service as
an annuitant under the 95-day Annuitant Program. In particular, you ask whether you would be
permitted to work as a consultant to the Department of State under the Commonwealth OST
contract.
Discussion:
It is initially noted that pursuant to Sections 1107(10) and 1107(11) of the Ethics Act, 65
Pa.C.S. §§ 1107(10), (11), advisories are issued to the requester based upon the facts that the
requester has submitted. In issuing the advisory based upon the facts that the requester has
submitted, the Commission does not engage in an independent investigation of the facts, nor does
it speculate as to facts that have not been submitted. It is the burden of the requester to truthfully
disclose all material facts relevant to the inquiry. 65 Pa.C.S. §§ 1107(10), (11). An advisory only
affords a defense to the extent the requester has truthfully disclosed all material facts.
When an individual who has retired from Commonwealth employment returns to
Commonwealth service as an annuitant to perform services
see
eSee, Graves, Opinion 00-009; McGlathery, Opinion 00-004.
Based upon the duties and authority set forth in the Position Description and the job
classification specifications for the position of Executive Assistant, the necessary conclusion is
that when you commenced providing services to the Department of State as an annuitant in the
position of Executive Assistant to the Deputy Secretary for Regulatory Programs, you became a
Ethics Act and the Regulations of the State Ethics Commission.
See, 65 Pa.C.S. § 1102; 51 Pa. Code § 11.1; Graves, supra; McGlathery, supra. Consequently,
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March 31, 2022
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While Section 1103(g) does not prohibit a former public official/public employee from
accepting a position of employment, it does restrict the former public official/public employee
§ 1103. Restricted activities
(g) Former official or employee.--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 Pa.C.S. § 1103(g) (Emphasis added).
governmental body with which a public official or
public employee is or has been associated are specifically defined in the Ethics Act as follows:
§ 1102. 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.
Person. A business, governmental body, individual,
corporation, union, association, firm, partnership, committee, club
or other organization or group of persons.
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.
65 Pa.C.S. § 1102.
The term person is very broadly defined. It includes, inter alia, corporations and other
businesses. It also includes the former public official/public employee himself, Confidential
Opinion, 93-005, as well as a new governmental employer. Ledebur, Opinion 95-007.
The term represent is also broadly defined to prohibit acting on behalf of any person in
any activity. Examples of prohibited representation include: (1) personal appearances before the
former governmental body or bodies; (2) attempts to influence; (3) submission of bid or contract
proposals which are signed by or contain the name of the former public official/public employee;
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March 31, 2022
Page 4
(4) participating in any matters before the former governmental body as to acting on behalf of a
person; (5) lobbying; and (6) acting to make known to the former governmental body the
representation of, or work for, a new employer. Popovich, Opinion 89-005; Edley, Opinion 17-
002; Confidential Opinion, 17-007; Valentine, Opinion 20-003.
During the one-year period of applicability of Section 1103(g) of the Ethics Act, Section
1103(g) generally would prohibit a former public official/public employee from contracting with
the former governmental body (see, Shaub, Order 1242; Confidential Opinion, 97-008;
Confidential Opinion, 93-005) or providing consulting services constituting representation before
the former governmental body (see, Claycomb, Opinion 14-004; Schrempf, Opinion 13-004).
Listing ones name as the person who will provide technical assistance on a proposal,
document, or bid (if submitted to, or reviewed by, the former governmental body) constitutes an
attempt to influence the former governmental body. Section 1103(g) also generally prohibits 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 if the invoices pertain to a contract that
existed prior to termination of service with such governmental body. Shay, Opinion 91-012.
However, if such a pre-existing contract does not involve the unit where a 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
95-011.
A former public official/public employee may assist in the preparation of any documents
presented to his former governmental body. However, the former public official/public employee
may not be identified on documents submitted to the former governmental body. The former
public official/public employee may also counsel any person regarding that persons appearance
before his former governmental body. Once again, however, the activity in this respect should not
be revealed to the former governmental body. The Ethics Act would not prohibit or preclude
making general informational inquiries to the former governmental body to secure information
which is available to the general public, but 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.
Section 1103(g) only restricts the former public official/public employee with regard to
representation before his former governmental body. The former public official/public employee
is not rest
particular subdivision of the agency or other governmental body where the public official/public
employee had influence or control but extends to the entire body. See, Legislative Journal of
House, 1989 Session, No. 15 at 290, 291; Sirolli, Opinion 90-006; Sharp, Opinion 90-009-R.
The governmental body with which you would be deemed to have been associated upon
termination of your service as an annuitant with the Department of State would be the Department
of State in its entirety. Therefore, until the expiration of a full one-year period following
termination of your service as an annuitant with the Department of State, Section 1103(g) of the
including but not limited to
yourself before the Department of State. (It is noted that if you would return to work with the
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March 31, 2022
Page 5
Department of State as an annuitant prior to the expiration of the one-year period, the restrictions
of Section 1103(g) of the Ethics Act would cease to apply to you.)
You are advised that during the first year following termination of your service as an
annuitant with the Department of State, Section 1103(g) of the Ethics Act would prohibit you from
working as a consultant to the Department of State under the Commonwealth OST contract as such
activity would constitute prohibited representation of a person specifically, yourself as a
consultant before your former governmental body, the Department of State. See, Shaub, supra;
Claycomb, supra; Schrempf, supra; Confidential Opinion, 97-008; Confidential Opinion, 93-005.
Lastly, the propriety of the proposed conduct has only been addressed under the Ethics Act;
the applicability of any other statute, code, ordinance, regulation or other code of conduct other
than the Ethics Act has not been considered.
Conclusion:
When you commenced providing services to the Department of State as an annuitant under
the 95-day Annuitant Program in the position of Executive Assistant to the Deputy Secretary for
Regulatory Programs, you became
Regulations of the State Ethics Commission. When you would cease providing such services to
to Section 1103(g) of the Ethics Act. The governmental body with which you would be deemed
to have been associated upon termination of your service as an annuitant with the Department of
State would be the Department of State in its entirety. Therefore, until the expiration of a full one-
year period following termination of your service as an annuitant with the Department of State,
including but not limited to yourself before the Department of State. The restrictions as to
representation outlined above must be followed.
During the first year following termination of your service as an annuitant with the
Department of State, Section 1103(g) of the Ethics Act would prohibit you from working as a
consultant to the Department of State under the Commonwealth OST contract as such activity
would constitute prohibited representation of a person specifically, yourself as a consultant
before your former governmental body, the Department of State.
Pursuant to Section 1107(11) of the Ethics Act, an 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, provided the requester 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.
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March 31, 2022
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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.
Respectfully,
Martin W. Harter
Acting Chief Counsel