HomeMy WebLinkAbout22-553 Foreman
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
December 16, 2022
To the Requester:
Michael Foreman
22-553
Dear Mr. Foreman:
This responds to your letter dated November 9, 2022, by which you requested an advisory
, seeking guidance as to the issue
presented below:
Issue:
Whether Section 1103(g) of the Public O
65 Pa.C.S. § 1103(g), would impose any prohibitions or restrictions upon you following
your retirement from your employment as a Local Government Policy Specialist with the
Pennsylvania Department of Community and Economic Development DCED and your
subsequent service with DCED as an annuitant, carrying out special projects and training
your successor.
Brief Answer: YES. During the first year following termination of your service with DCED
as an annuitant, Section 1103(g) of the Ethics Act would apply and restrict you from
including but
not limited to yourself or a new employer before DCED.
Facts:
You request an advisory from the Commission based upon submitted facts, the material
portion of which may be fairly summarized as follows.
Foreman, 22-553
December 16, 2022
Page 2
On April 1, 2022, you retired from your employment as a Local Government Policy
Specialist with DCED after thirty-four years of employment. You have submitted a copy of your
official DCED position description, which document is incorporated herein by reference.
In May 2022, you returned to work with DCED as an annuitant. Your duties as an annuitant
have included carrying out special projects and training your successor, as well as doing many of
the duties set forth in the position description for a Local Government Policy Specialist. However,
you are no longer actively involved in the review, management, and administration of DCED grant
and loan programs to local governments throughout the southwest region.
You state that your annuitant status with DCED will end on December 31, 2022. Following
the end of your annuitant status, you might pursue consultant work with PP, providing professional
services to local governments.
Based upon the above submitted facts, you seek guidance as to whether Section 1103(g) of
the Ethics Act would impose any prohibitions or restrictions upon you following termination of
your service with DCED as an annuitant. In particular, you pose the following questions:
(1) Whether the one-year post-employment restrictions of Section 1103(g) of the
Ethics Act would apply to you as of April 1, 2022, when you retired from DCED,
or as of December 31, 2022, when your annuitant status with DCED will end;
(2) Whether the Ethics Act would permit you to be paid with DCED funds as a
consultant with PP providing professional services to local governments as of
January 1, 2023;
(3) Whether the Ethics Act would permit you to do consulting work for PP through an
open and competitive DCED selection process (Invitation to Quote ITQ) in which
LGA is selected and in turn subsequently appoints PP to carry out professional
services work in which you would be part of and would be paid from DCED funds
flowing to LGA and then to PP for payment based upon a reimbursement request;
and
(4) If your proposed consulting work for PP would be prohibited to the extent you
would be paid from DCED funds, whether you would be permitted to do consulting
work for PP without compensation when DCED funds would be involved.
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 of the 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 of the material facts.
Foreman, 22-553
December 16, 2022
Page 3
When an individual who has retired from Commonwealth service returns to
see
See, Graves, Opinion 00-009, McGlathery, Opinion 00-004.
Based upon the position description for your former position as a Local Government Policy
Specialist for DCED and the submitted facts as to your duties and authority as an annuitant with
DCED, carrying out special projects and training your successor, the necessary conclusion is that
when you commenced providing services to DCED as an annuitant
See, 65
Pa.C.S. § 1101; 51 Pa. Code § 11.1; Graves, supra; McGlathery, supra.
Consequently, when you cease providing such annuitant services, you will become a
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 with regard to
Section 1103(g) of the Ethics Act provides:
§ 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).
The following terms related to Section 1103(g) are 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.
The governmental
body within State government or a political subdivision by which
Foreman, 22-553
December 16, 2022
Page 4
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 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;
(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.
Listing one's 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 the 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 person's 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 restricted as to representation before other agencies or entities. However, the "governmental
body with which a public official/public employee is or has been associated" is not limited to the
particular subdivision of the agency or other governmental body where the public official/public
Foreman, 22-553
December 16, 2022
Page 5
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 with DCED as an annuitant would be DCED in its entirety. Therefore,
for the first year following termination of your service with DCED as an annuitant, Section 1103(g)
of the Ethics Act would apply and restrict "representation" of a "person" including but not limited
to yourself or a new employer before DCED.
Having set forth the restrictions of Section 1103(g) of the Ethics Act, your specific
questions shall now be considered.
Your first question has been addressed above.
In response to your second and third questions, you are advised that Section 1103(g) of the
Ethics Act would not prohibit you from: (1) being paid with DCED funds as a consultant with PP
providing professional services to local governments as of January 1, 2023; or (2) doing consulting
work for PP through an open and competitive DCED selection process (Invitation to Quote ITQ)
in which LGA is selected and in turn subsequently appoints PP to carry out professional services
work in which you would be part of and would be paid from DCED funds flowing to LGA and
then to PP for payment based upon a reimbursement request, subject to the condition that in
performing such consulting work/professional services and/or being paid for such work/services,
you would not engage in prohibited representation before DCED as set forth above.
In response to your fourth question, you are advised that to the extent your proposed
consulting work where you would be paid from DCED funds would cause you to engage in
prohibited representation before DCED, Section 1103(g) of the Ethics Act would not prohibit you
from performing such consulting work for PP without compensation.
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 than the
Ethics Act has not been considered in that they do not involve an interpretation of the Ethics Act.
Conclusion:
Based upon the submitted facts, when you commenced providing services to DCED as an
annuitant, carrying out special projects and training your successor in the position of Local
Government Policy Specialist,
Regulations of the State Ethics Commission. When you cease providing such services to DCED,
you will bec
governmental body with which you would be deemed to have been associated upon termination of
your service as an annuitant with DCED would be DCED in its entirety. Therefore, until the
expiration of a full one-year period following termination of your service with DCED as an
annuitant,
including but not limited to yourself or a new employer before DCED. The
restrictions as to representation outlined above must be followed.
Foreman, 22-553
December 16, 2022
Page 6
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.
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