STATE OF CONNECTICUT
OFFICE OF STATE ETHICS

June 14, 2016
Charles F. Chiusano, Chainnan
and Members of the
Citizen's Ethics Advis01y Board
Office of State Ethics
18-20 Trinity Street, Suite 205
Hartford, CT 06106-1660

Re. Petition for Declaratory Ruling
Dear Chai1man Chiusano and Board Members:
In accordance with the Code of Ethics for Public Officials and applicable Regulations of
Connecticut State Agencies, and in my capacity as General Counsel of the Office of State Ethics, I
hereby recommend that the Citizen's Ethics Advisory Board issue a declaratory ruling addressing the
following questions raised by Cheri Quickmire, of Common Cause of Connecticut, in her June 13,
2016 Petition for Declaratory Ruling, attached:
•

Whether the Connecticut Insurance Commissioner - a former vice-president of (and registered
lobbyist for) Cigna whose husband cunently works as counsel for the insurance company and
whose mother and brother previously worked for it - has a conflict of interest, real or apparent,
concerning the proposed merger between Cigna and Anthem and must, therefore, recuse
herself from the matter.

Sincerely,

Barf ; Housen
General Counsel
Office of State Ethics
18-20 Trinity Street, Suite 205
Hartford, CT 06106-1660
Enclosure

Phone (860) 263-2./00 Fax (860) 263-2402
18-20 T rinity Street - Hartford, Connect icut 06 106- 1660
www.ct.gov/ethics
An Equal Opportunity Employer

 STATE OF CO NN ECTICUT
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BEFOij.E THE CITIZEN'S ETHICS ADVISORY BOARI)

'JUN 1:l 2016

OFFICE OF STATE ETHICS

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In the matter of the petition for a declaratory ruling of: §
§
§
§
§
§

Cheri Quickmlre, Common Cause In Connecticut

- -- - -- - - - -- ---Petitioner

No.
(Assigned by OSE)

PETITION FOR DECLARATORY RULING
Cheri Qulckmlre, Common Cause In Connecticut

- - - - - - - - - - - - - P e t i t i o n s the Citizen's Ethics Advisory Board to issue a
(Name of Petitioner)
declaratory ruling in this matter.
The factual background of the issue is as follows:

Note: Ifyou 1·eq11fre additional space ypu mqy attacli separate pages ancl any srtppol'tfng doc11me11tat/011 to tire petttlon fol'm .

Long-time Cigna lobbyist Katherine Wade was appointed Connecticut insurance commissioner in April,
2015 when Anthem's pla11 to acquire Cigna was being negotiated. Prior to this time Ms. Wade worked at
Cigna from 1992-2013; she wa~ a vice president, overseeing government affairs for the company in all 50
states. In addition she was an tjfficer In the CT Association of Health Plans from 2005-2013 and cu rrently
serves as health Insurance and managed care chair of the National Association of Insurance
Commissioners. Ms. Wade's husband works as counsel for Cigna and her mother and brother previously
worked there. Ms. Wade overs~es Connecticut's review of Clgna's merger.
Information regarding a conflict ·is unavailable because of a bill passed at midnight and signed by the
Governor on June 10 shields insurance Information from public release. Open records requests for
information about the merger through freedom of information have been rejected.

The question upon which Petitioner seeks a ruling is as follows:
Note: Ifyou requir·e additiurwl space yp11 mqy attach separate pages a11d mty support/119 docume11tatio11 to the petition form.

Is it permissable under the Code of Ethics for a registered lobbyist to become a state
employee who regulates the industry for which s/he lobbied? We write requesting a
thorough review of insurance commissioner Katherine Wade's apparent conflict of
interest regarding the proposed merger of Cigna and Anthem.

['Jume (860) 263··2400

Fax

(.~'60)

203 -2402

J S-20 Trinity Street·- Harl lord, C:lim1.ccticnt 06106" 1660

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 Petition for Declaratory Ruling
Page 2 of2

Petitioner's position with respect to the question is as follows:
Note: I/you require additional space you may attach separate panes 11nd u1ui support/119 doc11me11tatio11 ta t/1e petition form.

Common Cause in Connecticut questions the ability of Ms. Wade to conduct a review of
the merger of Anthem and Cigna in an unbiased way. CCCT believes that Ms. Wade's
close relationsip with Cigna and her position as lead regulator of the National
Association of Insurance Commissioners will adversely affect her abilty to conduct a
review of the merger and take action that is fair or objective. We do not believe that she
can be an impartial regulator and should recuse herself from the Cigna Anthem merger
review.

Petitioner's argument (if any) in support of his or her position (with such legal citations as are
considered appropriate) is as follows:
Nate: Ifyou l'eq11Jre additional spaceyou may attach separate panes aud mui support/no doc11me11tat/011 to tf1e petition fol'm.

Under Part 2 Section 1-85 of the Connecticut General Statue there is substantial conflict of interest
detailed.
In addition in the Code of Ethics Advisory Opinion Number 79-4 Permissibility of Lobbying by an
Attorney-Member of the Board of Higher Education refers to an unpaid member of the Board of Higher
Education having the authority to expend public funds and to exercise the power of the state. Ms. Wade Is
a (highly) paid state employee with the authority to excerclse the power of the state in her review of a
multi-billion dollar merger.

Wherefore, petitioner requests that the Citizen's Ethics Advisory Board grant this petition and
issue a declaratory ruling in this matter.

6/13/2016
Date

gerford Street
Mailing Address

Hartford, CT 06106
City, State, Zip Code

860-549-1220
Daytime Phone No.

Deliver or Mail to:
Citizen's Ethics Advisory Board
Office of State Ethics
18-20 Trinity Street
Hartford, CT 06106-1660

Pho1w (<~60) 263-2400 Fox (860) 263-24/12
18-20 Trinity Street ·- l:laitfortl, Connecticut 06 l 06-1.660
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tin Equal Opp11r11mify H111ploycr