ETH 2017-08
Opinion No. 2017-08
Kansas Ethics Opinion
November 29, 2017
Ms.
Julene L. Miller, General Counsel
Kansas
Board of Regents
1000 SW
Jackson, Suite 520
Topeka,
Kansas 66612-1368
Synopsis:
Under the facts presented, Kansas Board of Regents employees
may solicit gifts of sponsorships from persons that do not
have a special interest in the Board's actions, with the
provision that accepting the sponsorships meet K.S.A. 46-237a
exceptions.
Cited
herein: K.S.A. 46-228, 46-236, 46-237, 46-237a, and 46-254.
Dear
Ms. Miller:
We
understand, in your capacity as general counsel for the
Kansas Board of Regents, you request our opinion concerning
application of the state governmental ethics law, K.S.A.
46-215 et seq. Our opinion in response to your
request is limited to its applicability. This opinion does
not address whether some other statutory system, common law
theory, or agency rule or regulation applies to your inquiry.
FACTUAL
STATEMENT
The
Board of Regents office traditionally holds semi-regular
conferences that are attended by various constituency groups,
such as adult education leaders and teachers or data
collection personnel from the public postsecondary
institutions in the state. These conferences often include
training sessions for leaders and employees of such programs
or institutions. Related conference costs can include, but
are not limited to meals provided to attendees (none of which
exceed $25 per meal), snacks at conference breaks, materials
(such as written information for classes, paper, pencils,
etc.), conference room rental, training provided by paid
experts, and guest speaker fees. Registration fees charged by
the Board office to the attendees ordinarily pay for the
conference costs.
The
Board office is attempting to find ways to continue providing
quality training and information to conference attendees and
decrease registration fees, which for fiscal reasons, may not
allow some local educational programs or institutions to
continue to send their staff.
The
Board office is interested in exploring such cost sharing.
Three private...