Conflict of Interest Disclosures

Effective January 1, 2016, Chapter 176 of the Texas Local Government Code requires local government officers (LGOs) to disclose relationships with certain vendors. Employees and agents subject to the conflict’s disclosure requirements must complete the online CIS Form.

Important Changes to Previous Reporting Requirements

  • Local Government Officer (LGO) now includes any person who undertakes to transact some business or manage some affair for the local government and who exercises discretion in the planning, recommending, selecting, or contracting of a vendor. No longer is the requirement for board members and superintendents. Any employee or agent who fits the above definition is subject to the disclosure requirement.
  • The threshold for reporting gifts in a 12-month period has been lowered from $250 to $100.
  • Lodging, transportation, and entertainment, even when accepted as a guest, are included in the $100 gift threshold.
  • Family relationships with a vendor must be disclosed. “Family relationship” is defined as someone within a third degree of consanguinity (blood) or second degree of affinity (marriage).

Conflict of Interest FAQs for Employees

Question: What is an Organizational Conflict?

An organizational conflict of interest may result when IDEA Public Schools conduct a business transaction with an affiliate or subsidiary organization and, as a result this relationship, the IDEA Public Schools is unable or appears to be unable to be impartial in conducting a procurement action involving its affiliate or subsidiary. Generally, because of its relationship with an affiliate or subsidiary, IDEA Public Schools may encounter one or more of the following types of organizational conflict of interest.

  • (a) Unequal access to information
  • (b) Biased ground rules
  • (c) Impaired objectivity

Thus, when using federal funds to procure goods and services from an affiliate or subsidiary organization, the Board and School officers and employees are to avoid and take other actions to mitigate the potential for significant organizational conflicts of interest that may result in an unfair competitive advantage to an affiliate or subsidiary. If IDEA Public Schools personnel identify an organizational conflict of interest, the employee must prepare a memorandum for the Superintendent identifying the proposed procurement, the conflicted entity, and circumstances giving rise to the conflict. Upon review, the Superintendent must submit the memorandum and a proposed remedy to the Board for consideration and approval.

Question: What is IDEA’s Gift Policy?

No employee shall accept or solicit any gifts, favor, services, or other benefit that could reasonably be construed to influence the employee’s discharge of assigned duties and responsibilities or could be perceived as having been offered because of an existing or potential business relationship. Employees shall disclose any gifts, favors, services, or benefits received with an aggregate value of $100 or more from any one individual over the course of one school year to the Delegates. This includes items of food, lodging, transportation, tickets, or business entertainment accepted as a guest. When the employee is in doubt of the value of the gift, he or she should report it to the Delegates. If an employee has any questions regarding acceptable conduct or the interpretation of this policy, or if he or she is in doubt about the best course of action in a particular situation, the employee must seek clarification from his or her supervisor or the Delegates. Failure by an employee to disclose gifts pursuant to this policy could result in adverse personnel action against the employee.