Revolving Door Employment

The Illinois State Officials and Employees Ethics Act (5 ILCS 430/5-45) states that an employee who was involved in awarding a contract of $25,000 or more to a company during their final year of employment may not go to work for that company for one year after terminating employment with the state/University.  The stipulation also applies to spouses and other immediate family members living in their household.  The purpose of this prohibition is to prevent any quid-pro-quo act of awarding a contract in exchange of other employment. 

University Ethics and Compliance Office staff maintains a listing, which is also provided to the Office of the Illinois Governor, that includes the names of those individuals subject to the revolving door prohibition.  The prohibition requires certain University employees to notify the Office of Executive Inspector General for the Agencies of the Illinois Governor (OEIG) when they or anyone in their immediate family living within their household, are offered employment or compensation from a non-state employer so that the OEIG can determine, within 10 calendar days, if accepting the employment or compensation is prohibited by law.

Additionally, as of February 15, 2015, per Ill. Exec. Order No. 15-09 (Jan. 13, 2015), no state employee or appointee can negotiate for employment or compensation with any lobbyist or lobbying entity for their agency of current employment. 

If an employee terminates their employment with a state agency, the prohibition expands to prohibit lobbying for any state agency, not just specifically the agency where they were employed during the previous year.  As such, for one year following employment with a state agency in Illinois, an individual may not accept compensation as a lobbyist for any state agency in Illinois.  This prohibition does not apply to students whose employment is directly associated with their enrollment (e.g., undergraduate students, graduate students, teaching assistants, or medical residents).

Revolving door forms and instructions are available on the OEIG website at: https://oeig.illinois.gov/revolving-door/revolving-door-instructions.html.

To determine if you are on the listing of individuals impacted by the revolving door prohibitions, please contact the University Ethics and Compliance Office at: ethicsofficer@uillinois.edu

 

Statutory Reference

Illinois State Officials and Employees Ethics Act (5 ILCS 430/5-45)

    Sec. 5-45. Procurement; revolving door prohibition.

  1. No former officer, member, or State employee, or spouse or immediate family member living with such person, shall, within a period of one year immediately after termination of State employment, knowingly accept employment or receive compensation or fees for services from a person or entity if the officer, member, or State employee, during the year immediately preceding termination of State employment, participated personally and substantially in the award of State contracts, or the issuance of State contract change orders, with a cumulative value of $25,000 or more to the person or entity, or its parent or subsidiary.

Executive Order Reference

Illinois Executive Order 15-09 (January 13, 2015) Section II, 1-3

 

  1. No State Employee, while employed by or serving as an appointee of a State Agency, shall negotiate for employment or other compensation with any person or entity that is registered as a Lobbyist or Lobbying Entity and has identified that State Agency on its then-current Lobbyist or Lobbying Entity registration filed with the Secretary of State.
  2. No former State Employee, within one year after leaving his or her position with a State Agency, shall accept compensation from any person or entity for Lobbying any State Agency.
  3. The restrictions of this Section II are in addition to, and not in place of, the restrictions set forth in applicable law, including the State Officials and Employees Ethics Act (5 ILCS 430/5) and the Illinois Procurement Code (30 ILCS 500/50-30).