| Advisory Opinion request from James Carinio, Jr., a former employee and district supervisor with Louisiana Rehabilitation Services ("LRS"), regarding his post-employment restrictions as a Job Placement Vendor for LRS. |
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From November 2013 until September 8, 2023, Mr. Carinio was employed by Louisiana Rehabilitation Services ("LRS") within the Louisiana Workforce Commission ("LWC"). He was a Rehabilitation Employment Development Specialist ("REDS") in the Shreveport Regional Office from November 2013 to May 1, 2022. The Shreveport Regional Office serves LSR Region 7, which consists of the following parishes: Bienville, Bossier, Caddo, Claiborne, DeSoto, Lincoln, Natchitoches, Red River, Sabine, and Webster.
As a REDS, Mr. Carinio's job duties included direct job placement, on-the-job training development, vocational assessment and counseling, employment development and follow-up, resource and consumer development, case management, public speaking, and job fair participation. His services were provided to eligible individuals with disabilities who were cleared for employment by Vocational Rehabilitation ("VR") Counselors.
From May 2, 2022 until his retirement on September 8, 2023, Mr. Carinio was a Region 7 District Supervisor in the LRS Shreveport Regional Office. Mr. Carinio supervised and approved the caseloads of three VR Counselors, whose duties were to determine individual eligibility, develop a specific Individualized Plan for Employment ("IPE") for an eligible individual, refer approved individuals to Job Placement Vendors, and approve Job Placement Vendor authorizations. Mr. Carinio also supervised and approved the work duties of two Rehabilitation Counselor ("RC") Associates, who reviewed and submitted payment authorizations for services rendered by Job Placement Vendors, such as colleges/universities, vocational-technical schools, and supportive employment vendors, supported VR Counselors by keeping up with individual records for select caseloads, and contacted individuals with expired cases and liaisons of colleges/universities. Mr. Carinio completed Performance Evaluations (PES) for the staff under his supervision. Mr. Carinio assisted his supervisor, the Regional Manager, in hiring new personnel.
Now, Mr. Carinio would like to become a Job Placement Vendor for LRS by providing direct job placement services in Region 7 for approved individuals who will be referred to him by VR Counselors in the Shreveport Regional Office. To be a Job Placement Vendor for the Shreveport Regional Office in Region 7, Mr. Carinio's application will have to be approved by the Regional Manager, the LWC Appointing Authority, and the LRS State Director.
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La. R.S. 42:1121B(1) provides that no former public employee shall, for a period of two years following the termination of his public employment, assist another person, for compensation, in a transaction, or in an appearance in connection with a transaction in which such former public employee participated at any time during his public employment and involving the governmental entity by which he was formerly employed, or for a period of two years following termination of his public employment, render, any service which such former public employee had rendered to the agency during the term of his public employment on a contractual basis, regardless of the parties to the contract, to, for, or on behalf of the agency with which he was formerly employed.
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Adopt the proposed advisory opinion.
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| Assigned Attorney: |
Jessica Meiners |
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