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2018-1304
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Last modified
7/12/2021 10:24:44 AM
Creation date
12/17/2018 11:47:12 AM
Metadata
2018-1304
Fields
Template:
Opinion Item
Opinion Type
Advisory Opinion
Docket Number
2018-1304
Requesting Party
Matthew K. Brown
Decision Date
12/14/2018
Law
42:1113A(1)(a)
42:1111C(2)(d)
Caption
The Code of Governmental Ethics would not prohibit Marsha Siebert from working for Riverside Emergency Physician Partners, LLC (REPP), while REPP has a contract with Riverside Medical Center and Ms. Siebert's husband is employed at Riverside Medical Center; however Ms. Siebert would be prohibited from working in the Emergency Department at Riverside Medical Center.
Ethics Subject Matters
Prohibited Contracts
Prohibited Transactions
Prohibited Sources
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Mr. Matthew K. Brown <br /> December 17, 2018 <br /> Page -2- <br /> You provided information that Marsha Siebert is a salaried or wage-earning employee of REPP,her <br /> salary would be unaffected by the contractual relationship between REPP and Riverside, and Ms. <br /> Siebert owns no more than twenty-five percent of REPP and is not an officer, director,trustee, nor <br /> partner of REPP. Given those facts,the Board applied the exception in Ethics Board Docket No.82- <br /> 02D, a copy of which is attached, and concluded that the Code would not prohibit Marsha Siebert <br /> from working for REPP while REPP has a contract with Riverside. <br /> Section 1114 of the Code requires Marsha Siebert to file a statement every May 15th disclosing <br /> income received from REPP in the prior calendar year. Enclosed is Form 405 to facilitate the <br /> disclosure. <br /> However, Marsha Siebert would be prohibited by the Code from working in the Emergency <br /> Department at Riverside. La. R.S. 42:1113A(l)(a) prohibits a public servant or a member of the <br /> public servant's immediate family,or legal entity in which he has a controlling interest from bidding <br /> on or entering into any contract, subcontract, or other transaction that is under the supervision or <br /> jurisdiction of the agency of such public servant. The Emergency Department is in the agency of <br /> Jimmy Siebert as Chief Nursing Officer. Thus,Ms. Siebert could not provide services on behalf of <br /> REPP to the Emergency Department of Riverside,but she could provide services on behalf of REPP <br /> to any department at Riverside that is not within the agency of Jimmy Siebert as Chief Nursing <br /> Officer, or any facility other than Riverside. <br /> This advisory opinion is based solely on the facts as set forth herein. Changes to the facts presented <br /> may result in a different application of the provisions of the Code of Ethics. The Board issues no <br /> opinion as to past conduct or laws other than Code of Governmental Ethics. If you have any <br /> questions, please contact me at (225) 219-5600 or(800) 842-6630. <br /> Sincerely, <br /> LOUISIANA BOARD OF ETHICS <br /> Gregory L. Thibodeaux <br /> For the Board <br />
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