|Revision Date||October 1, 2020|
Under statute, a Single Source Continuum Contractor (SSCC) must give preferential employment opportunities to DFPS employees impacted by the implementation of the Community Based Care (CBC) program, provided the employee is in good standing with DFPS. This allows staff to transfer DFPS programmatic knowledge, which is instrumental to the success of the SSCC, meeting the intent of the legislation.
When hiring past or current DFPS employees, the SSCC must ensure any potential conflicts of interest are addressed prior to extending an offer of employment. The SSCC must contact DFPS Ethics Policy to request determination for eligibility of employment for any DFPS staff or DFPS consultant who:
- is currently, or has previously been, in a restricted position (as detailed below), or
- may pose a potential conflict of interest due to nepotism.
DFPS has determined specific positions pose higher risk of a conflict of interest and therefore established restrictions.
Regional Staff Restrictions
Community Based Care regional administrators and CPS regional directors are prohibited from direct employment with an SSCC in the region in which they worked for one year from the date they left employment with DFPS or moved to a position within DFPS in which they had no responsibility or authority over any SSCC contract or the CBC program.
State Office Restrictions
The following state office positions are prohibited from direct employment with an SSCC for one year from the date they left DFPS or moved to a position within DFPS in which they had no responsibility or authority over any SSCC contract or the CBC program:
- CPS Associate Commissioner,
- CPS Deputy Director,
- CPS Conservatorship Director,
- Community Based Care Director, or
- any other DFPS staff who had decision making authority over the drafting, administration, interpretation, or implementation of an SSCC contract.
Any contract staff who has had direct contract management, monitoring, or oversight responsibilities for an SSCC contract or an attorney who provided direct legal advice concerning an SSCC contract or who represented DFPS in contracting issues are permanently barred from working for an SSCC.
Conflict of Interest and Nepotism
The SSCC contracts contain terms and conditions to address nepotism between the SSCC’s workforce and DFPS. The SSCC cannot hire or assign a staff member within the SSCC’s organization that would directly or indirectly create a conflict of interest involving a relative employed by DFPS or the SSCC.
Relatives or people living in the same household as employees in the following positions may constitute a conflict of interest for which the SSCC must notify DFPS:
- CPS Regional Directors;
- CPS CBC Regional Administrators;
- CBC Contract Management Staff;
- DFPS Contracts Legal Staff;
- CPS State Office Leadership who oversee CBC; and,
- DFPS staff who developed procurement documents, contract documents, or have had responsibility for negotiations with the SSCC.