Conflict of Interest Disclosure

  •                                                                                                                                                                                                                                                                           Effective January 1, 2016, Chapter 176 of the Texas Local Government Code requires local government officers 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).
    Links Comments
    CIQ Form Blank Form for Vendor
    CIS Form Blank Form for Employees


    Conflict of Interest FAQs for Employees

    Question: How do I know if I fit the definition of an LGO?
    In Killeen ISD, all directors and above on the organizational chart fit within the definition of an LGO; including the Superintendent and the Board of Trustees. All of these individuals are required to complete the CIS form for any gift from a vendor that is valued at $100 or more or has been multiple items during a 12-month period that add up to $100 or more. Principals and other administrators who exercise discretion in the planning, recommending, selecting, or contracting with a vendor also qualify as an LGO and are required to report gifts.

    Questions: I attended a professional convention and received a tote bag, mouse pad, and a pen from one of the vendor booths. Do I need to report this on the CIS form?
    No, because the value of the items does not total $100, no reporting requirement is triggered, even if the District contracts with the vendor.

    Question: Do classroom teachers need to report gifts / gift certificates from parents?
    No, most gifts to teachers do not need to be disclosed. However, if the parent is a vendor and the teacher exercises discretion in selecting the vendor, then a disclosure would need to be submitted if the value of the item exceeds $100.

    Question: During a conference, I attend a dinner sponsored by a vendor. Do I need to report this?
    No, dinner as a guest of a vendor (where the vendor is present) is not included in the disclosure requirements. This is one of the remaining exceptions from the previous disclosure requirements.

    Question: What if I have a family member that is a District vendor or works for a District vendor?
    If you qualify as an LGO, you must disclose if you or your family member have received income over $2,500 from a District vendor or if you or your family member have received a gift with a value of over $100 in a 12-month period.
    Family members include: parents, children or your spouse.

    Question: What if I have a "family relationship" with a vendor?
    An LGO must disclose a relationship with a vendor if the officer or a member of his family (see below) receives taxable income because of an employment or business relationship with the vendor. An LGO must also disclose gifts offered to the LGO or his family members by a vendor within the past 12 months if the value of the gifts was $250 or more.

    Question: What family relationships are covered?
    If you qualify as an LGO, you must disclose if you have a "family relationship" with a District vendor.
    Family relationship includes: siblings, cousins, nieces, nephews, grandparents, grandchildren, great-grandchildren (3rd degree by blood; 2nd degree by marriage).
     
    Conflict of Interest FAQs for Vendors

    Question: What forms are vendors required to file?
    An individual or business entity that contracts or seeks to contract for the sale or purchase of property, goods, or services with Killeen ISD must file a Conflict of Interest Questionnaire. This includes individuals and entities that seek to purchase goods and services from Killeen ISD, as well as those who seek to sell goods and services to the District. An "agent" of a vendor in the vendor’s business with the District must also file a CIQ.

    Question: When and where must a vendor file the CIQ?
    The CIQ must be filed with Killeen ISD’s Purchasing Services department within seven (7) days of beginning contract negotiations, or submitting an application, bid, response to a request for proposal, correspondence, or other writing related to a potential agreement with Killeen ISD. The forms must be updated annually.

    Question: How do I submit the form?
    Vendors may complete the form electronically.

    Question: What will happen once I submit the form?
    Killeen ISD has a responsibility to make public the information received under this statute and Killeen ISD must post CIS forms received from LGOs and CIQ forms received from vendors on the Killeen ISD Web site.

    Question: What happens if a vendor does not submit a CIQ form?
    Vendors may face criminal penalties for failing to submit the CIQ form in a timely manner.