Conflict Disclosure

Conflict Disclosure

House Bill 914 and the updated Conflict of Interest Questionnaire (CIQ) requirements create two parallel—but connected—disclosure obligations in Texas: one for local government officers (including superintendents and school board members) and one for vendors doing or seeking to do business with a school district. Together, they form the state’s framework for transparency in public purchasing.

Conflict Disclosure Requirements for Local Government Officers (HB 914)

The 79th Texas Legislature enacted House Bill 914, effective January 1, 2006, adding Chapter 176 to the Texas Local Government Code. This law requires superintendents and school board members to file a Conflicts Disclosure Statement (Form CIS) when certain conditions are met.

When a CIS must be filed

A superintendent or trustee must file a CIS if:

• The district has contracted with or is considering doing business with a vendor and

• The officer or a first‑degree family member has:

  • An employment or business relationship with the vendor that results in taxable income, or

  • Received gifts totaling more than $250 from the vendor in the 12 months before becoming aware of the conflict.

Filing deadline

The CIS must be filed with the district’s records administrator no later than 5 p.m. on the 7th day after the officer becomes aware of the facts requiring disclosure.

Purpose

The law promotes transparency by ensuring the public can see when district decision‑makers have relationships that could influence purchasing decisions. The Texas Ethics Commission oversees compliance and provides guidance.

Conflict of Interest Questionnaire (CIQ) for Vendors

Vendors have their own disclosure obligation under Chapter 176, updated by H.B. 23 (84th Legislature).

When a vendor must file a CIQ

A vendor must submit a CIQ if:

• The vendor has a business relationship with the district as defined in §176.001(1‑a), and

• The vendor becomes aware of:

  • An employment or business relationship with a district officer or their first‑degree family member, or

  • Gifts to an officer or their family member that meet or exceed the statutory threshold.

Filing deadline

The CIQ must be filed with the district’s records administrator no later than the 7th business day after the vendor becomes aware of the facts requiring disclosure.

Penalties

A vendor who knowingly fails to file the CIQ commits a misdemeanor offense under §176.006