PUBLIC SESSION
MEETING CONVENED
Chair Margot Botsford called the meeting to order at 9:32 a.m. Also in attendance were Vice Chair Thomas A. Connors, Commissioner Eron Hackshaw, Commissioner Patrick Hanley, and Commissioner Jeffrey T. Collins.
REMOTE PARTICIPATION
Chair Botsford 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 28, 2025. Chair Botsford noted that all votes at the meeting would be taken by roll call.
APPROVAL OF MEETING MINUTES
On the motion of Commissioner Hanley, seconded by Vice Chair Connors, the Commission voted 5-0 to waive the reading and approve the public session minutes of the October 23, 2025 Commission meeting.
| Vote: | |
|---|---|
| Chair Botsford | Yes |
| Commissioner Hackshaw | Yes |
| Vice Chair Connors | Yes |
| Commissioner Hanley | Yes |
| Commissioner Collins | Yes |
EXECUTIVE DIRECTOR’S REPORT
Executive Director David A. Wilson presented his monthly report.
Personnel
Mr. Wilson welcomed new Commission member Jeffrey T. Collins.
Budget
Mr. Wilson provided an update on the Commission’s budget. He reported that the Commission’s budget team of Chief of Finance and Operations Benjamin Bloomenthal, Government Affairs Officer Jennifer McCullough, and himself had submitted the Commission’s Fiscal Year 2027 budget request for $4.01 million, approximately $257,000 more than the Commission’s current level of funding, to the Executive Office for Administration and Finance (A&F) on November 3, 2025. Mr. Wilson explained that the Commission’s Fiscal Year 2027 budget request was for maintenance funding, including for modest cost-of-living, merit, and longevity adjustments for Commission staff, as well as for information technology expenditures. He noted that the likelihood of A&F, the House, and the Senate all agreeing to include all of the requested funding in their respective budgets was uncertain but further noted that the Commission must make the request for there to be any possibility of receiving the funding. Mr. Wilson stated that, while the next fiscal year is expected to be challenging, the Commission staff would do their best to get the most from available resources in order to continue delivering high-quality services to the public.
New Commissioner
Mr. Wilson stated that there was nothing new to report regarding the appointment of a new Commissioner to succeed Commissioner Hackshaw. He invited the Commissioners to provide him with the names of qualified persons interested in serving on the Commission as potential candidates, which he said he would pass along to the Attorney General’s Office.
Ongoing Projects
Mr. Wilson reported that substantial progress had been made in the project to replace the Commission’s existing SFI e-filing system, which would be discussed during the monthly report of the Legal Division. He further reported that the Commission staff were exploring possible means of reducing the chargeback by the Executive Office of Technology Services and Security (EOTSS) for the Commission’s website. Mr. Wilson stated that, while EOTSS had not yet provided a transparent breakdown of how the chargeback is calculated, the Commission’s website’s high volume of page views and large number of publicly accessible appears to contribute to the large size of the chargeback. He reported that Commission staff were looking into the possibility of transferring certain less frequently viewed website materials to the State Library to help reduce the overall cost, and that that effort would be discussed during the monthly report of the Public Education and Communications Division.
First Aid Training
Mr. Wilson reported that the Commission partnered with the Massachusetts Commission Against Discrimination to offer two two-hour Hands-Only CPR training sessions for staff on November 18, 2025, which were attended by a total of nineteen Commission staff members. He said the training was conducted by Deputy Taishana Lewis, head of the Boston Emergency Medical Services’ Community Initiatives Program, together with several other Boston EMTs. Mr. Wilson thanked Deputy Lewis and her colleagues for providing the training and Ms. McCullough for taking the lead in arranging it. Ms. Slattery noted that the Commission has an AED device located at the reception desk, and that part of the training includes instruction for staff on retrieving and utilizing the Commission’s AED, if needed.
COGEL Conference
Mr. Wilson reported that, in early December, Enforcement Staff Counsel Candies Pruitt, Information Technology Specialist Tony Webb, and he would attend the Council on Governmental Ethics Laws (COGEL) Annual Conference in Atlanta. He noted that the Commission’s delegation to the 2025 COGEL conference would be smaller than delegations in past years because reimbursement of the attendees for travel and lodging expenses was unlikely. He noted that the Commission had paid the attendees’ registration fees.
Mr. Wilson noted that Commission staff participated in panels at past COGEL conferences, and that Senior Public Information Officer Gerry Tuoti was on a panel on e-learning at the 2023 COGEL Conference in Kansas City. At Mr. Wilson’s invitation, Mr. Tuoti stated that he served on a panel with representatives from the Colorado Independent Ethics Commission, Philadelphia Board of Ethics, and Ohio Ethics Commission, and that he presented about the Commission’s new online learning platform for the conflict of interest law training. Ms. Pruitt stated that she served on a panel with representatives from the Los Angeles City Ethics Commission and the Washington Public Disclosure Commission, and that she presented on the Commission’s public enforcement actions as part of an Enforcement Update panel at the conference. Mr. Wilson noted that significant preparation is required to serve on COGEL conference panels and that Commission staff, interested in serving on such a panel, must generally submit a proposal to COGEL for consideration early in the calendar year.
Chair Botsford asked whether similar agencies from other states have since adopted online training systems like the Commission’s learning management system. Mr. Tuoti responded that he was not aware of any agencies using a learning management system of a similar scale to the Commission’s but noted that attendees expressed interest in the Commission’s compliance-tracking capabilities and the scale of its online platform. He said that the Commission was fortunate to have received capital funding for the development and implementation of its conflict of interest law training, and that the panel discussion highlighted that the Commission is comparatively larger and better resourced than many peer agencies in other jurisdictions.
Commissioner Hackshaw stated that he recommended attending the COGEL conferences because they provide a broader understanding of how other agencies perform their work. He noted that the Commission’s statutory authority to enforce the conflict of interest law makes its work particularly distinctive and of interest to ethics officials in other jurisdictions.
Pie and Ice Cream Social
Mr. Wilson reported that the Commission’s annual Pie and Ice Cream Social would be held following the Commission meeting at 2:00 p.m. and invited the Commissioners to attend.
Next Meeting
Mr. Wilson reminded the Commission that the next Commission meeting was scheduled for December 18, 2025 at 9:30 a.m. Following discussion, the Commission scheduled its subsequent meetings for January 22, 2026 at 9:30 a.m. and February 26, 2026 at 9:30 a.m. Vice Chair Connors said that he would be unable to attend the December Commission meeting. Chair Botsford and Commissioner Hanley stated that they would be participating remotely for the January Commission meeting.
PUBLIC EDUCATION AND COMMUNICATIONS DIVISION MATTERS
Public Education and Communications Division Chief Don Siriani presented his memorandum reporting on the Public Education and Communications Division’s activities during October 2025.
Mr. Siriani reported that he conducted two 90-minute public education seminars, two 3-hour seminars, and a 10-minute introduction to the conflict of interest law in October collectively attended by a total of 210 public employees in-person and virtually.
Mr. Siriani stated that the Division was working to identify potential cost savings related to web hosting and had contacted the Massachusetts State Library to explore options for archiving the Commission’s web content.
At Mr. Siriani’s request, Senior Program Coordinator Arthur Xia provided an update on a new initiative the Commission had begun in partnership with the State Library through its State Documents Depository Program. Mr. Xia explained that the State Documents Depository Program is designed to preserve and provide public access to Massachusetts state publications, both digital and print, for permanent historical record. He stated that this effort would strengthen long-term preservation of the Commission’s public documents, improve public access, and better manage the Commission’s content footprint on Mass.gov. Mr. Xia noted that participation in the Depository Program is required by law, as state agencies must provide the State Library with copies of their official publications for permanent historic preservation. He said that, while the Commission had historically met that obligation by submitting its Annual Reports and its Public Resolutions and Rulings, the project would expand that practice so that more of the Commission’s archival materials would be preserved in a centralized, permanent repository.
Mr. Xia reported that the website project team, consisting of Mr. Wilson, Mr. Bloomenthal, Ms. McCullough, Mr. Siriani, Mr. Tuoti, Administrative Assistant/Receptionist Arisa Waguespack, and himself, met via videoconference with State Librarian Stacy DeBole on October 7, 2025 to learn more about the Depository Program and the submission process. He further reported that, following that meeting, he prepared and submitted the 2014 Commission meeting minutes as the first batch. Mr. Xia explained that these materials were converted into accessible PDFs as required by the Library, and that the Library was now reviewing them and working to create a dedicated digital collection for the Commission’s meeting minutes, organized by year to mirror the structure used on the Commission’s website. He stated that this collaboration would support statutory compliance, give the public a centralized and intuitive place to access historical documents, and complement the Commission’s website. Mr. Xia noted that the Library provided reference services at no cost, which allows members of the public seeking older documents to work directly with a state librarian, thereby reducing the amount of Commission staff time devoted to certain research inquiries. He explained that, over time, moving older, static content off Mass.gov may reduce the Commission’s content footprint and could help lower EOTSS chargeback costs. Mr. Xia said that the plan would entail continuing this work in phases, beginning with additional years of meeting minutes and other archival materials that are suitable for long-term preservation, starting small to confirm that the workflow operates smoothly before scaling up, and doing so without disrupting current public access.
Chair Botsford asked whether members of the public would have the same level of access to Commission materials if some of those materials were being moved to the State Library. Mr. Xia responded that, ideally, accessing Commission materials would be seamless for visitors, who would be able to move between the Commission’s website and the State Library’s website without noticing any difference. Vice Chair Connors asked what the downside would be of moving Commission materials to the State Library. General Counsel/Legal Division Chief Eve Slattery responded that the advantage of retaining Commission materials on Mass.gov is that members of the public can search for Commission materials directly on the Mass.gov platform. Vice Chair Connors said that it was unfortunate that the Commission was being penalized for maintaining a robust website and asked whether there were other ways for reducing chargeback costs. Ms. McCullough reported that the chargeback cost for Fiscal Year 2027 was reduced from $55,000 to $39,000. Mr. Wilson stated that EOTSS had not explained the reason for the reduction. Chair Botsford asked whether members of the public would be required to go in-person to the State Library to access Commission materials. Mr. Wilson explained that they would not, as the materials would be available through the Library’s digital repository. He noted that the State Library had not been subject to the same accessibility standards as agencies using the Mass.gov platform but had indicated that it was revamping its website to improve accessibility.
Mr. Siriani reported that 43 conflict of interest law disclosures were filed in October. He stated that Mr. Tuoti regularly responds to reporters who submit public records requests for those disclosures. Mr. Siriani further reported that the Division responded to 32 press and non-press inquiries concerning conflict of interest law issues during the month.
Mr. Siriani reported that the Division responded to 424 helpdesk calls and emails, averaging approximately 16 calls per day, in October. He thanked Ms. Waguespack for her substantial assistance in responding to public employees with inquiries about the conflict of interest law training.
Commissioner Hackshaw asked what the Division was planning to put out to the public as the holiday season approached. Mr. Siriani responded that the Division would post a notice on the Commission’s website. Chair Botsford asked how the Division would explain conflict of interest law issues related to gifts. Mr. Siriani explained that the Division regularly received requests for guidance, and if public employees had questions regarding their particular circumstances, they would be referred to the Legal Division.
LEGAL DIVISION MATTERS
General Counsel/Legal Division Chief Eve Slattery reported on the activities of the Legal Division in October 2025.
Ms. Slattery reported that the Division had no pending requests for written advice that were more than 30 days old. Chair Botsford asked whether the number of letters issued by city solicitors and town counsel that are reviewed by the Legal Division has been trending downward over the years. Ms. Slattery explained that municipal employees may request a written opinion from the Commission directly rather than their own city solicitors or town counsel, which may reflect a decrease in the number of municipal opinions received by the Commission than in years past. Mr. Wilson noted that because city solicitors and town counsel are often private attorneys on retainer, municipal employees are often discouraged from seeking advice from them as their doing so may result in legal expenses for their municipalities. He further noted municipal employees seeking to obtain confidential conflict of interest law advice must request it from the Commission, as advice given in response to inquiries to city solicitors or town counsel is public.
Legal Division Metrics for October 2025
Ms. Slattery presented the following Legal Division metrics for October 2025.
- Written advice. The Legal Division answered by letter or e-mail 41 written requests for advisory opinions under G.L. c. 268A and c. 268B. Of these requests, 1 pertained to SFIs.
| For comparison: | |
|---|---|
| October 2024 (same month prior year) (total/SFI): | 55/3 |
| September 2025 (previous month) (total/SFI): | 47/3 |
- Oral advice. The Legal Division attorneys provided advice by telephone in response to 320 requests for advice from state, county, and municipal officials. Of these requests, 2 pertained to SFIs.
| For comparison: | |
|---|---|
| October 2024 (same month prior year) (total/SFI): | 338/0 |
| September 2025 (previous month) (total/SFI): | 361/4 |
- Review of municipal letters. Division staff reviewed 0 letters issued by city solicitors/town counsel pursuant to G.L. c. 268A, § 22 and 930 CMR 1.03.
| For comparison: | |
|---|---|
| October 2024 (same month prior year): | 1 |
| September 2025 (previous month): | 0 |
- Backlog. As of November 13, 2025, the Division had 0 pending requests for written advice that were more than 30 days old. As of that date, there were a total of 13 pending requests for written advice.
Adjudicatory Matters
Ms. Slattery presented the November/December calendar of conferences/hearings in pending Commission adjudicatory proceedings.
In the Matter of Gary Shepherd, Docket No. 25-0008 (Order to Show Cause issued November 13, 2025): Commissioner Hanley was assigned as the presiding officer. Senior Assistant General Counsel T. Michael McDonald will serve as legal advisor.
In the Matter of Joseph Solomon, Docket No. 23-0010 (Order to Show Cause issued July 6, 2023): Commissioner Collins was assigned as the presiding officer, replacing former Commissioner Edwards. Assistant General Counsel Ting Chiu will continue to serve as legal advisor.
SFI Report
Legal Division Deputy Chief/SFI Lauren Duca provided an update on Statements of Financial Interests (SFI) for Calendar Year 2025. Ms. Duca said that the SFI Team had begun preparing for the SFI filing season by updating the annual request for Designation Lists of filers from agencies, which are due in January 2026, and conducting training sessions for agency SFI liaisons on their responsibilities under the financial disclosure law and how to use the SFI system. She noted that Special Assistant to Administration and SFI Rose Costa would conduct four training sessions in total, as well as two Q&A sessions, for agency liaisons in October and November. Ms. Duca reported that the SFI Team handled a total of 48 inquiries for SFI assistance in October.
Ms. Duca provided an update on the project to replace the Commission’s existing SFI filing system. She reported that the Commission’s Strategic Sourcing Team, consisting of Mr. Wilson, Mr. Bloomenthal, Ms. McCullough, Mr. Siriani, Special Assistant to Administration and SFI Rose Costa, IT Specialist Tony Webb, and herself, had reviewed and scored the bids received in response to the request for quotation (RFQ). She further reported that as a result of that review and initial scoring of the bids, the team invited several vendors to present their proposed systems, which occurred the prior Tuesday and Wednesday. Ms. Duca said that the team would convene to determine whether there was agreement on the evaluations before proceeding to the Best and Final Offer stage, after which the Commission would select an apparent successful bidder and begin contract negotiations.
Chair Botsford asked whether there was a ceiling on what the Commission can pay the selected vendor. Ms. Duca responded that the Commission received $1.2 million in capital funding for the project including the cost of a consultant, and noted that Ms. McCullough, who was instrumental in securing that funding, was working to determine whether additional funds may be available. She said that the team would be mindful of its current budget and cannot assume that further funding will be obtained. Ms. Duca explained that, although capital funding would cover the development of the system, the Commission would also need to pay for licensing and production costs going forward, which she described as the most significant financial concern. She stated that the Commission’s existing system was relatively inexpensive to maintain because the vendor had provided minimal services, and that the cost of maintenance for a modernized system had increased substantially.
Chair Botsford asked for Ms. Duca’s impressions of the vendor responses. Ms. Duca responded that the oral presentations were helpful because they made it easier to visualize the proposed systems. She said that the Commission’s consultant, Gartner, Inc., was highly knowledgeable and had been invaluable in guiding the team, explaining technical aspects, and advising on what features are typical or atypical for the type of system the Commission was seeking. Ms. Duca noted that the Commission’s current SFI system was developed in 2015. Mr. Wilson stated that meeting with the vendors through oral presentations had been instrumental in enabling the Commission to make a more informed decision.
ENFORCEMENT DIVISION MATTERS
Enforcement Division Chief Monica Brookman presented the Enforcement Intake and Matter Metrics for October 2025. Ms. Brookman reported that, while the number of complaints received had increased slightly in October, the complaint backlog remained relatively the same.
EXECUTIVE SESSION
At 10:27 a.m., on the motion of Chair Botsford, seconded by Commissioner Hanley, the Commission voted 5-0 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 Hackshaw | Yes |
| Vice Chair Connors | Yes |
| Commissioner Hanley | Yes |
| Commissioner Collins | Yes |
Chair Botsford stated that the Commission would not reconvene in public session following the executive session.
LIST OF DOCUMENTS USED AT THIS MEETING
- Agenda for the Commission Meeting of November 20, 2025
- Minutes of the Commission Meeting of October 23, 2025, Public Session
- Memorandum, dated November 13, 2025, from Public Education and Communications Division Chief Donald Siriani to the Commission concerning Public Education and Communications Division activities in October 2025
- Memorandum, dated November 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 and Matter Metrics
Respectfully submitted,
Arthur Xia
Senior Program Coordinator