PUBLIC SESSION
MEETING CONVENED
Vice Chair Thomas A. Connors chaired the meeting, which he called to order at 9:31 a.m. Also in attendance were Chair Margot Botsford, Commissioner Wilbur P. Edwards, Jr., and Commissioner Eron Hackshaw. Chair Botsford and Commissioner Hackshaw participated remotely.
REMOTE PARTICIPATION
Vice Chair Connors announced that the meeting would take place in-person with remote access provided to the public pursuant to the law signed by Governor Healey on March 29, 2023. Vice Chair Connors noted that all votes at the meeting would be taken by roll call.
APPROVAL OF MEETING MINUTES
On the motion of Vice Chair Connors, seconded by Commissioner Edwards, the Commission voted 4-0 to waive the reading and approve the public session minutes of the February 24, 2025 Commission meeting.
| Vote: | |
|---|---|
| Chair Botsford | Yes |
| Commissioner Edwards | Yes |
| Commissioner Hackshaw | Yes |
| Vice Chair Connors | Yes |
EXECUTIVE DIRECTOR’S REPORT
Executive Director David A. Wilson presented his monthly report.
Budget
Mr. Wilson provided an update on the Commission’s Fiscal Year 2026 budget. He reported that, on March 28, 2025, he will provide testimony before the Joint Committee on Ways and Means at a hearing at Clinton Town Hall in support of the Commission’s Fiscal Year 2026 budget request. Mr. Wilson noted that Government Affairs Officer Jennifer McCullough and Senior Public Information Officer Gerry Tuoti, who helped him to prepare and submit his written testimony to the Joint Committee, will also attend the hearing. He stated that he and Ms. McCullough have already met with several members of the House and Senate Committees on Ways and Means to discuss the Commission’s work and provide support for the Commission’s Fiscal Year 2026 budget request. Mr. Wilson noted that the coming fiscal year presents an unusual degree of uncertainty due to broader economic conditions. He stated that the Commission’s final Fiscal Year 2026 budget outcome will likely be influenced by factors beyond the Commission’s control at both the state and national levels.
Vice Chair Connors inquired about any further developments regarding the substantial chargeback imposed by the Executive Office of Technology Services and Security (EOTSS) and its impact on the Commission’s budget. Mr. Wilson responded that Commission staff have discussed the EOTSS chargeback matter with EOTSS and legislators and raised it as a concern. Vice Chair Connors asked whether these costs could continue to increase as new items are added to the Commission’s website. Mr. Wilson said that the cost of maintaining the Commission’s website could rise, which would be problematic if the Commission does not receive sufficient funding to support those increases. Public Education and Communications Division Chief David Giannotti stated that, while some agencies have launched their own websites independent of Mass.gov, he would not recommend that the Commission to do so due to the high associated costs. Mr. Giannotti noted that, while the Commission is now charged based on its web traffic, this outreach is critical to fulfilling the Commission’s mission of educating public employees about the conflict of interest law.
Vice Chair Connors stated that increased web traffic should be viewed as a measure of the Commission’s success, not a liability, and asked whether EOTSS is aware of how the new cost structure undermines the Commission’s operating budget. Mr. Wilson confirmed that EOTSS has also been made aware and stated that no alternative arrangement has been presented. Ms. McCullough noted that many other agencies were also unaware of the pricing changes implemented by EOTSS. Vice Chair Connors asked whether the Commission intends to raise this issue during upcoming budget testimony. Mr. Wilson confirmed that the issue would be raised. He further stated that the proposed funding for the Commission in the Governor’s H.1 budget is, given the increase in the EOTSS chargeback, an increase of less than 1% over Fiscal Year 2025, and would be insufficient to maintain the Commission’s current level of service in Fiscal Year 2026.
Ongoing Projects
Mr. Wilson reported that substantial progress has been made with the additional branched content in the Commission’s online conflict of interest law training program, the implementation of the new Legal Case Management System, and the replacement of the Commission’s existing SFI filing system, which will be discussed during the monthly reports of the Public Education and Communications Division and the Legal Division.
New Commissioners
Mr. Wilson reported that he has been in contact with the Governor’s Boards and Commissions Office and has been told that the Governor is currently reviewing candidates for appointment as new commissioners to succeed Vice Chair Martinez and Commissioner Edwards.
Next Meeting
Mr. Wilson reminded the Commission that the next Commission meetings are scheduled for April 17, 2025 at 9:30 a.m. and May 13, 2025 at 9:30 a.m.
PUBLIC EDUCATION AND COMMUNICATIONS DIVISION MATTERS
Public Education and Communications Division Chief David Giannotti presented his memorandum reporting Public Education and Communications Division’s activities during February 2025. Mr. Giannotti thanked the Commissioners and staff for their kind messages following his retirement announcement and expressed his appreciation for the opportunity to work with such a talented group during his tenure.
Mr. Giannotti provided an update on the online conflict of interest law training platform. He reported that he, Senior Public Information Officer Gerry Tuoti, and Senior Program Coordinator Arthur Xia responded to 886 calls and e-mails regarding the online learning platform in February, a significant decrease from 1,286 calls and e-mails as reported in January. Mr. Giannotti noted that the volume of calls and e-mails has slowed in recent weeks.
At Mr. Giannotti’s request, Mr. Tuoti provided an update on the new branched content for the online training program. Mr. Tuoti reported that the vendor, SkillBurst Interactive, is currently producing the developed module, which includes recorded narration, visuals, and interactive elements, based on the draft script of the new branched content that was finalized on February 26, 2025. He explained that since the finalized script is longer than originally anticipated, the Commission and the vendor amended the contract to accommodate the additional work. Mr. Tuoti noted that the existing budget for this fiscal year is sufficient to cover the expanded scope. He stated that the Commission expects to receive a draft version of the developed module for review by early April. Mr. Tuoti explained that once the module is approved, the vendor will produce closed caption translations in Spanish, Portuguese, Haitian Creole, and simplified and traditional Chinese. He noted that the project remains on track for completion by the end of June.
Mr. Giannotti thanked Mr. Tuoti for recently issuing the Fiscal Year 2024 Annual Report, which is now available on the Commission website. He noted that the report may be an effective resource in connection with budget testimony before the Joint Committee on Ways and Means.
Mr. Giannotti provided an update on the Legal Case Management System project. He reported that the system successfully launched on March 4, 2025, and that the project vendor established a support bridge line to provide immediate assistance to Commission staff for a three-week period following the launch, scheduled to conclude on Monday, March 24th. Mr. Giannotti explained that, during this period, Commission staff submitted 147 support requests, the majority of which have been resolved, with five items that remain pending, and seven that are scheduled for further discussion. He stated that Commission staff are actively using the new system and reporting any issues directly to the vendor through the bridge line. Mr. Giannotti explained that the new system includes an internal e-mail feature, and the Commission is exploring integration with Microsoft Outlook to streamline communications. He noted that the Commission also intends to work with the vendor in the coming weeks to develop public-facing portal pages that will allow the public to submit documents, such as conflict of interest law disclosures and requests for advice, electronically to the Commission. Vice Chair Connors asked whether there was any need to extend the deadline for the support bridge line. Mr. Giannotti responded that he would discuss the matter with the vendor but did not believe an extension was necessary, particularly since the vendor has confirmed that support will continue beyond the bridge line period.
LEGAL DIVISION MATTERS
General Counsel/Legal Division Chief Eve Slattery reported on the activities of the Legal Division.
Legal Division Metrics for February 2025
Ms. Slattery presented the following Legal Division metrics for February 2025.
- Written advice. The Legal Division answered by letter or e-mail 49 written requests for advisory opinions under G.L. c. 268A and c. 268B. Of these requests, 4 pertained to SFIs.
| For comparison: | |
|---|---|
| February 2024 (same month prior year) (total/SFI): | 69/30 |
| January 2025 (previous month) (total/SFI): | 82/29 |
- Oral advice. The Legal Division attorneys provided advice by telephone in response to 361 requests for advice from state, county, and municipal officials. Of these requests, 7 pertained to SFIs.
| For comparison: | |
|---|---|
| February 2024 (same month prior year) (total/SFI): | 410/18 |
| January 2025 (previous month) (total/SFI): | 430/51 |
- Review of municipal letters. Division staff reviewed 1 letter issued by city solicitors/town counsel pursuant to G.L. c. 268A, § 22 and 930 CMR 1.03.
| For comparison: | |
|---|---|
| February 2024 (same month prior year): | 2 |
| January 2025 (previous month): | 0 |
- Backlog. As of March 13, 2025, the Division has 6 pending requests for written advice that are more than 30 days old. There are a total of 28 pending requests for written advice.
Adjudicatory Matters
Ms. Slattery presented the March/April calendar of conferences/hearings in pending Commission adjudicatory proceedings.
Litigation Matters
Ms. Slattery reported that there are no updates on pending litigation matters.
Office of State Auditor Audit
Ms. Slattery provided an update on the ongoing audit of the Commission by the State Auditor’s Office. She explained that the Commission was notified in February that the audit will primarily focus on how the Commission conducts reviews and investigations regarding the filing of statements of financial interests, the receipt and processing of written requests for advisory opinions, and the issuance of advisory opinions for the period of July 1, 2022 to June 30, 2024. Ms. Slattery reported that the Commission has met with the auditors five times to review the Commission’s processes for both SFIs and advisory opinions, and that the Commission has responded to six separate requests for documentation with an additional request scheduled for the following Monday. She noted that the State Auditor’s Office may narrow the scope of its review and that the Commission continues to cooperate fully. Vice Chair Connors asked whether the State Auditor’s Office would prepare a written report of its findings at the conclusion of the audit. Ms. Slattery confirmed that the State Auditor’s Office would issue a written report and noted that a written report was still produced even though no “findings” were made during the last audit.
SFI Report
Legal Division Deputy Chief/SFI Lauren Duca provided an update on Statements of Financial Interests (SFI) for Calendar Year 2024. She reported that, to date, 1,205 of the approximately 4,000 people required to file have already filed their Calendar Year 2024 SFI, which is nearly 300 more than previously reported in February. Ms. Duca further reported that the SFI Team handled a total of 109 phone calls, emails, and walk-ins for SFI assistance in February.
Ms. Duca provided an update on the replacement of the Commission’s existing SFI filing system. She reported that the SFI Team provided information and documentation about the current SFI system to the EOTSS Strategy Team for their use in preparing materials to assist the Commission and its consultant with the development of a replacement SFI system. Ms. Duca stated that the SFI Team worked with Ms. McCullough to draft a Request for Proposals, which was posted on March 7, 2025, to procure a consultant to assist with the development of a replacement SFI system. She noted that responses to the Request for Proposals are due on April 18, 2025. Ms. Duca further reported that the SFI Team will post a Request for Information, which was drafted by the EOTSS Strategy Team, later today seeking information from prospective vendors regarding a set of recommendations and technical requirements for the development of a replacement SFI system. She noted that responses to the Request for Information are due on April 11, 2025.
ENFORCEMENT DIVISION MATTERS
Enforcement Division Chief Monica Brookman presented the Enforcement Intake Metrics for February. Ms. Brookman reported that the volume of complaints continues to rise, with a total of 92 in February. She explained that with the new Legal Case Management System, complaints will be considered ‘intake,’ and that only credible conflict of interest allegations will be converted to ‘matters,’ instead of treating each complaint that is received as a new case. Ms. Brookman noted that the metrics presented at the Commission meeting will now distinguish between the intake received and matters that are under review. She thanked Enforcement Division staff for their adaptability during the transition to the new system and said that she hopes these changes will contribute to their increased efficiency.
EXECUTIVE SESSION
At 10:08 a.m., on the motion of Vice Chair Connors, seconded by Commissioner Edwards, the Commission voted 4-0 to enter executive session to discuss matters subject to the provisions of G.L. c. 30A, § 21, subparagraph (a)(7), and § 18, and G.L. c. 268B, §§ 3 and 4, including investigatory matters, preliminary inquiries, summons authorization requests, and adjudicatory matters.
| Vote: | |
|---|---|
| Chair Botsford | Yes |
| Commissioner Edwards | Yes |
| Commissioner Hackshaw | Yes |
| Vice Chair Connors | Yes |
Vice Chair Connors stated that the Commission would not reconvene in public session following the executive session.
MEETING RECONVENED
At 11:08 a.m., the meeting reconvened in public session. Chair Botsford, Commissioner Edwards, Commissioner Hackshaw, and Vice Chair Connors were present.
Next Meeting
Vice Chair Connors explained that due to unforeseen scheduling conflicts that were discussed during executive session, the Commission rescheduled its next meetings for April 29, 2025 at 9:30 a.m. and May 22, 2025 at 9:30 a.m.
ADJOURN MEETING
At 11:09 a.m., on the motion of Vice Chair Connors, seconded by Commissioner Edwards, the Commission voted 4-0 to adjourn.
| Vote: | |
|---|---|
| Chair Botsford | Yes |
| Commissioner Edwards | Yes |
| Commissioner Hackshaw | Yes |
| Vice Chair Connors | Yes |
LIST OF DOCUMENTS USED AT THIS MEETING
- Agenda for the Commission Meeting of March 20, 2025
- Minutes of the Commission Meeting of February 24, 2025, Public Session
- Memorandum, dated March 13, 2025, from Public Education and Communications Division Chief David Giannotti to the Commission concerning Public Education and Communications Division activities in February 2025
- Memorandum, dated March 13, 2025, from General Counsel/Legal Division Chief Eve Slattery to the Commission setting forth Legal Division matters for the meeting
- Calendar of hearing dates and pre-hearing conferences in pending Commission adjudicatory matters
- Enforcement Intake Metrics
Respectfully submitted,
Arthur Xia
Senior Program Coordinator