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the program to provide qualified services to Medicaid eligible clients. As a result, LSUHSC-S physicians are enrolled in the Medicaid program to provide services to Medicaid clients; they do not manage or run the Medicaid program itself Ochsner LSU Health is responsible for the submission of claims to LDH for the Medicaid services provided by LSUSHC-S physicians. On March 15, 2021, Mr. Reynolds became an employee of Ochsner Clinic Foundation, which operates a network of thirty-one hospitals in Louisiana and is a separate entity from Ochsner LSU Health. In his employment with Ochsner Clinic Foundation, Mr. Reynolds will provide financing and management of Medicaid reimbursements programs, the development of supplemental payment methodology to maximize Medicaid reimbursements,and consulting and interfacing with public officials and other persons in creating legislation and administrative rules regarding Medicaid reimbursements. Mr. Reynolds will also serve as the Chief Financial Officer ("CFO") for Ochsner Clinic Foundation's fifteen community health clinics. In his CFO role, Mr. Reynolds will be responsible for the tracking of revenue and expenditures and the projection of future financial activities associated with the health clinics. Mr. Reynolds will not engage any of the agencies in his former chain of command for any issues related to the Medicaid/Medicare hospital cost reports or billings of LSUHSC-S. ISSUES Whether the Code of Governmental Ethics prohibits Mr. Reynolds's employment with Ochsner Clinic Foundation within two years of his resignation as Vice Chancellor for Administration & Finance at LSUHSC-S? LAW La. R.S. 42:1121(A)(1)provides: No former agency head or elected official shall,for a period of two years following the termination of his public service as the head of such agency or as an elected public official serving in such agency, assist another person, for compensation, in a transaction, or in an appearance in connection with a transaction, involving that agency or render any service on a contractual basis to or for such agency. La. R.S. 42:1121(B)(1)provides: No former public employee shall, for a period of two years following the termination of his public employment, assist another person, for compensation, in a transaction, or in an appearance in connection with a transaction in which such former public employee participated at any time during his public employment and involving the governmental entity by which he was formerly employed, or for a period of two years following termination of his public employment, render, any service which such former public employee had rendered to the agency during the term of his public employment on a contractual basis, regardless of the parties to the contract, to, for, or on behalf of the agency with which he was formerly employed.