| Advisory opinion request concerning post-employment restrictions that would apply to former employees of the Office of Group Benefits. |
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A request was made by Greg Cromer, the CEO of Louisiana Health Cooperative (LAHC), for an advisory opinion concerning post-employment restrictions that would apply to former employees of the Office of Group Benefits (OGB). Charles Calvi, Chief Executive Officer of OGB, resigned his position in January, 2014; Patrick Powers, Chief Operating Officer of OGB, resigned his position in January, 2014; and Sylvia Theriot, Director of Finance of OGB, resigned her position in March, 2014. Charles Calvi accepted a position as Executive President of Marketing with the LAHC; Patrick Powers accepted a position as Executive Vice President for Finance with LAHC; and Sylvia Theriot accepted a position as Controller with LAHC. LAHC is planning to submit a request to OGB to be offered as a participating health plan to its membership in 2015.
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Section 1121A(1) of the Code prohibits a former agency head, for a period of two years following the termination of his public service as the head of such agency, from assisting a person, for compensation, in a transaction or in an appearance in connection with a transaction, involving his former agency. Furthermore, Section 1121A(1) prohibits a former agency head from rendering, on a contractual basis, any service to or for his former agency for a period of two years.
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Adopt the proposed advisory opinion.
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| Assigned Attorney: |
Jennifer Land |
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