Texas Ethics Commission Conflict of Interest
Chapter 176 of the Texas Local Government Code describes who must file conflict of interest questionnaires (CIQ), when the forms must be filed, and the posting requirements.
At its November 30, 2015, meeting, the Texas Ethics Commission adopted amendments to Forms CIS and CIQ, that had been previously adopted on August 7, 2015. The Commission adopted these forms as required by H.B. 23, 84th Leg., Regular Session, which became effective September 1, 2015. Please note that the commission does NOT have jurisdiction to interpret or enforce Chapter 176 of the Local Government Code. Prior to H.B. 23, the Office of the Attorney General issued the following advisory opinion: Opinion No. GA-0446. Also, please note that these forms are NOT filed with the Texas Ethics Commission.
CIQ Reporting
A vendor to the District must file a CIQ form if the vendor has a business relationship with the District, AND:
1. has an employment or other business relationship with an officer (school board member) or the superintendent of the District, or a family member of the officer or superintendent; or
2. has given an officer or the superintendent, or a family member of either, one or more gifts with the aggregate value of more than $250 in the 12-month period preceding the date the officer or superintendent becomes aware that such a contract has been executed or the District is considering entering into a contract with the vendor, and the gift was not (1) given by a family member of the person accepting the gift, (2) a political contribution, or (3) food, lodging, transportation, or entertainment accepted as a guest.
The completed form must be filed by a vendor with the Director of Business Services not later than the seventh business day after the date that the vendor:
1. begins discussions or negotiations to enter into a contract with the District;
2. submits to the District an application, response to a request for proposals or bids, correspondence, or “another writing” related to a potential contract with the District; or
3. becomes aware:
1. of an employment or other business relationship with a board member, the superintendent, or a family member of either that requires disclosure; or
2. that the vendor has given one or more gifts that require disclosure.
Only a knowing failure to comply with the CIQ reporting requirements will subject an individual to discipline. Therefore, a person does not commit an offense if he or she files the required questionnaire within seven business days after receiving notice of an alleged violation. Board policies and Texas Government Code Section 176.009 require school districts to post online all CIQ forms that are required to be filed.
CIQ Reporting
A vendor to the District must file a CIQ form if the vendor has a business relationship with the District, AND:
1. has an employment or other business relationship with an officer (school board member) or the superintendent of the District, or a family member of the officer or superintendent; or
2. has given an officer or the superintendent, or a family member of either, one or more gifts with the aggregate value of more than $250 in the 12-month period preceding the date the officer or superintendent becomes aware that such a contract has been executed or the District is considering entering into a contract with the vendor, and the gift was not (1) given by a family member of the person accepting the gift, (2) a political contribution, or (3) food, lodging, transportation, or entertainment accepted as a guest.
The completed form must be filed by a vendor with the Director of Business Services not later than the seventh business day after the date that the vendor:
1. begins discussions or negotiations to enter into a contract with the District;
2. submits to the District an application, response to a request for proposals or bids, correspondence, or “another writing” related to a potential contract with the District; or
3. becomes aware:
1. of an employment or other business relationship with a board member, the superintendent, or a family member of either that requires disclosure; or
2. that the vendor has given one or more gifts that require disclosure.
Only a knowing failure to comply with the CIQ reporting requirements will subject an individual to discipline. Therefore, a person does not commit an offense if he or she files the required questionnaire within seven business days after receiving notice of an alleged violation. Board policies and Texas Government Code Section 176.009 require school districts to post online all CIQ forms that are required to be filed.
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