Request for Revolving Door Determination 

Typically, employees whose state work includes being involved with contracting, fiscal administration, licensing or regulating are required to request a revolving door determination. Most agencies have a “c-list” that sets forth the agency positions that are included. If you are not certain whether you are required to seek a determination or have general questions concerning the determination process, please speak with your agency’s ethics officer.

Yes, if you have been involved in contracts, change orders, fiscal administration or regulatory/licensing decisions. You can check with your Ethics Officer if you are still unsure whether you have to file a Revolving Door request. But generally, you should seek a Revolving Door determination to avoid violating Revolving Door subsections (a) and (b), because such violations could result in large financial penalties.

No. The OEIG uses your responses to determine your level of involvement with contracting, fiscal administration, or regulatory / licensing decisions involving the potential employer. No one answer is singularly determinative of an outcome.

No. The OEIG does not issue advisory determinations or opinions concerning potential job offers or business arrangements. An actual job offer must be made before the OEIG will process a determination request.

The Revolving Door prohibitions are triggered when state employees leave, or are about to leave, their employment with the state. The situation described here is generally referred to as “secondary employment” and is not covered by the Revolving Door prohibitions. However, you will need to inform the OEIG about this job if you wish to continue doing it when you leave state employment, and, depending on your agency’s policies, you may need to notify your supervisor of any secondary employment. You should contact your agency’s ethics officer for more information.

No. As long as you continue to fill the position on a volunteer basis and receive no fees or compensation for one year immediately following your termination of state employment, you are not required to seek a Revolving Door determination.

Yes, if you have an offer for another job you would like to accept and it is still within one year after you left your state job. You need to seek a determination for each job within that year.

Yes, the Ethics Act requires c-listers to notify the OEIG of all prospective non-state job offers received for one year after leaving state employment, regardless of any working relationship to the state (or the lack thereof). It is the OEIG’s role to evaluate the employment offer, not you. Failing to seek a Revolving Door determination subjects you to Revolving Door violations that could result in financial penalties.

Depending upon your employment relationship with the state, you may be treated the same as any other state employee for purposes of the Revolving Door prohibitions and notification requirements. Section 1-5 of the Ethics Act defines employee as, among other things, “any person employed full-time, part-time, or pursuant to a contract and whose employment duties are subject to the direction and control of an employer with regard to the material details of how the work is to be performed….” 

Typically, yes. You need to request a determination for each new client during the year following your termination of state employment. The OEIG must determine if you, while serving as a state employee, participated personally and substantially in the award of state contracts or in the making of a regulatory or licensing decision with respect to each new client.

H-listers are employees in positions listed in subsection "h" of Section 5-45 of the Ethics Act that are prohibited from accepting employment or compensation from a non-state prospective employer if the prospective employer, during the year immediately before the employee’s termination from state employment, was a party to state contracts with a cumulative value of $25,000 or more involving the employee's state agency, or was the subject of a regulatory or licensing decision involving the employee's state agency regardless of whether the h-lister was involved in those regulatory or licensing decisions, contract awards, or the fiscal administration of contracts.
 

These broader Revolving Door restrictions apply to certain high-ranking positions, such as agency heads, board members, and chiefs of staff, as well as certain positions involved in procurement, and all employees of the Illinois Racing and Gaming Boards. 

No, because h-listers are strictly prohibited from accepting certain jobs regardless of their participation (or lack thereof), the OEIG does not make “h-list” Revolving Door determinations. H-listers should contact their ethics officer for guidance prior to accepting post-state employment.

Yes. Attach additional pages if necessary. The purpose of these forms is to gather as much accurate information as quickly as possible. Any factual information you believe is relevant to the determination should be included.

Pursuant to the administrative code, the RD-102 must be submitted to the OEIG within 5 calendar days after receiving the RD-101 form from the employee.

Contact the EEC to file an appeal. The EEC is the entity that decides whether to uphold the OEIG's determination. The EEC may be reached via email at EEC@illinois.gov.
 

Please note that you only have 10 calendar days after receiving a restricted letter from the OEIG to appeal the determination. The EEC has concluded that if the last day to perform an act (such as filing or deciding on an appeal) falls on a Saturday, Sunday, or State holiday, then the time period is extended until the next business day. Additional rules concerning the appeals process may be found at 5 ILCS 430/5-45(g), Ill. Admin. Code Tit. 2, §1620.610, et seq., and on the EEC website.

Yes, the Ethics Act requires c-listers to notify the OEIG of all prospective non-state job offers received for one year after leaving state employment, regardless of the job type or any ties to the state (or the lack thereof).
 

In addition, state employees becoming lobbyists should keep Executive Order 15-09 in mind, as it prohibits state employees from being paid to lobby any state executive agency for one year after the employee leaves their state position.  Please consult your Ethics Officer for further guidance on lobbying restrictions.