Advisory Opinion No. 1996-4
Provisions To
An Individual Who Served As Commissioner
Of Both The
Commission On Hospitals And Health Care
And The Office Of Health Care Access
Ms. Gwen Beryl Weltman was
appointed by Governor Lowell Weicker to serve from
Ms. Weltman has now asked how the post-state employment provisions of the Code of Ethics for Public Officials will restrict her future employment opportunities.
Four generally applicable post-state employment, i.e., revolving door, provisions of the Code apply to Ms. Weltman:
She may never use confidential information gained in state service for the financial benefit of any person. Conn. Gen. Stat. §1-84a.
She may never represent anyone other than the State concerning any particular matter in which she participated personally and substantially as a state servant, if it is one in which the State has a substantial interest. Conn. Gen. Stat. §1-84b(a).
For one year after leaving state service, she may not represent anyone, other than the State, for compensation before OHCA concerning a matter in which the State has a substantial interest. Conn. Gen. Stat. §1-84b(b).
If she participated personally and substantially in the negotiation or award, or supervised the negotiation or award, of a contract, valued at $50,000 or more, within a year before leaving state service, she could not accept employment with a party to that contract other than the State for a year after leaving state service. Conn. Gen. Stat. §1-84b(d).
Furthermore, as a former public member of the CHHC, Ms. Weltman must also comply with the additional restrictions
contained in §1-84b(c). That section
imposes more stringent limitations upon certain current and former executive
branch public officials and state employees.
These restrictions are imposed only upon persons with significant
decision-making or supervisory responsibility in the listed agencies, including
the public member of CHHC; and preclude the public official for one year after
leaving the agency from accepting employment with any business subject to
regulation by that agency. Regulations
of
Following the
In summary, specific limitations on seeking or accepting employment are established by Conn. Gen. Stat. §§1-84b(c) and (d), described above. The limitations upon a former public officials activities on behalf of a new employer, established by Conn. Gen. Stat. §§1-84a, 1-84b(a) and 1-84b(b), may be more meaningfully addressed once the proposed employment has been identified. Ms. Weltman may, therefore, wish to submit a more specific inquiry when she has a particular position in mind.
By order of the Commission,
David T. Nassef
Chairperson