HomeMy WebLinkAboutAgenda 04-14-22; 2 - Discussion on Board Members Voting on County Funding for, or Contracts with, a Non-Profit While Serving on a Non-Profit’s Governing Board 1
ORANGE COUNTY
BOARD OF COMMISSIONERS
ACTION AGENDA ITEM ABSTRACT
Meeting Date: April 14, 2022
Action Agenda
Item No. 2
SUBJECT: Discussion on Board Members Voting on County Funding for, or Contracts with,
a Non-Profit While Serving on a Non-Profit's Governing Board
DEPARTMENT: County Attorney
ATTACHMENT(S): INFORMATION CONTACT:
John Roberts, County Attorney,
919-245-2318
PURPOSE: To discuss and consider options for addressing a new state law regarding BOCC
members voting on County funding for, or contracts with, a non-profit while serving on a non-
profit's governing board.
BACKGROUND: The state adopted a new law last year prohibiting elected public officials from
participating "in making or administering a contract, including the award of money in the form of a
grant, loan, or other appropriation, with any nonprofit with which that public official is associated."
The law describes the covered officials as those who serve on nonprofit boards or entities that
are "organized or operating in the State primarily for religious, charitable, scientific, literary, public
health and safety, or educational purposes and of which the public official is a director, officer, or
governing board member." It further requires covered officials to recuse themselves from votes
on funding for or contracts with these nonprofits. Since outside agencies are funded by County
grants through contracts with those agencies, the determination of how much funding to give to
individual outside agencies is most likely covered by this prohibitive language. Violation of this
law is a Class 1 misdemeanor. The prohibition does not extend to nonprofits or other entities that
are created by the state or a local government.
This is a prohibition on individuals engaging in activity while serving as elected officials rather than
a prohibition on the BOCC itself, and ultimately it will be up to covered commissioners to determine
for themselves whether they may be in violation of the statute. As noted above, the statute
requires covered commissioners to recuse themselves from voting on these matters presumably
because each individual commissioner is in the best position to know on what outside boards that
Board member sits.
Although there may be other ways to address this issue, four options in order of the ease with
which they may be implemented include:
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1) BOCC members may resign positions as directors, officers, or governing board members
of any nonprofit covered by the new law if that nonprofit receives outside agency funds
from or otherwise contracts with the County.
2) The BOCC approves 1.2% of general fund county revenue to be awarded to outside
agencies and authorizes the County Manager to allocate the funds. If the BOCC does not
agree with any allocation, that particular allocation could be addressed through a budget
amendment at which time a commissioner with a conflict could be easily excused or
recused. This would eliminate direct involvement in an award by a covered commissioner.
3) An alternative suggested by the UNC School of Government is to adopt "a practice of
stripping non-profits from (the) general budget ordinance and then including those
nonprofits later via budget amendments. That procedure allows conflicted-out board
members to vote on the general budget ordinance but recuse themselves from amendment
voting." Similar to the first two options, utilizing this approach would eliminate the risk to
individual board members. This could be done at the same meeting at which the budget is
adopted because North Carolina Generl Statute (NCGS) 159-15 allows amendments, with
few limitations, at any time after the budget ordinance is adopted.
4) Another alternative suggested by the UNC School of Government is to "vote on pieces of
the budget in stages prior to adopting the final budget ordinance. While these votes are not
binding, they allow the board to make individual policy decisions as they work through the
budgeting process. This preliminary vote process offers a potential strategy for handling
conflicts arising from a member's financial interest in a particular budget provision. Under
this approach, the Board would take a preliminary (nonbinding) vote on the budget
provision that involves the Board member's interest and excuse the interested member
from voting on it. If the matter passes, then it can be incorporated into the final version of
the budget ordinance. When the board member later votes on the final version of the
budget ordinance, it will be clear from the preliminary vote that the member's vote was not
necessary to approve the provision that involves his or her financial interest." This
approach still carries risk due to the fact that impacted commissioners are still voting on
the problematic item even though they earlier recused themselves. The new law prohibits
any involvement.
The first three options eliminate risk to covered commissioners. In addition to minimizing or
eliminating risk to covered commissioners, options one through three also eliminate even the
appearance of impropriety under the new law. As noted above, option four does not eliminate all
risk.
FINANCIAL IMPACT: There is no financial impact associated with this item.
SOCIAL JUSTICE IMPACT: There is no Orange County Social Justice Goal impact associated
with this item.
ENVIRONMENTAL IMPACT: There is no Orange County Environmental Responsibility Goal
impact associated with this item.
RECOMMENDATION(S): The Manager recommends the Board discuss the options presented
and any others that may be discussed, make a selection, and provide any other direction to staff.