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On November 21, 2024, the Cook County Board of Commissioners amended the Cook County Procurement Code. As a result, County agencies/departments entering into contracts over $25,000 – up from $15,000 – must work with the Office of the Chief Procurement Officer (“OCPO”) to facilitate the contractual process. This impacts the Ethics Ordinance’s definition of “doing business with the County,” which is now based on companies that have contracts totaling $25,000 or more over the preceding four years – up from $10,000.
What does this mean for you, as a Cook County employee or official?
1. Agency Contracting Authority
Purchases of the same or similar supplies, goods, equipment or services by a County Using Agency in an aggregate amount from the same vendor of less than $25,000.00 in the same fiscal year do not require a competitive procurement method. Such purchases must be made in accordance with the Office of the Chief Procurement Officer’s Small Purchase Policy.
Departments and agencies executing contracts under $25,000 are not required to collect familial relationship disclosures. Please note that officials and employees are still prohibited from (1) participating in the decision to award a contract of any value or (2) manage a contract of any value if their relative has a financial interest in the contract.
2. Post Employment Restrictions
County employees who separate from the County are subject to the following:
- County employees who participated in the decision to award a contract valued at more than $25,000 or multiple contracts with a cumulative value exceeding $25,000 may not work for the entity for one year after they separate from County employment.
- County agencies may contract with a former employee if retention of that employee is necessary to continue operations for a contract amount that does not exceed $25,000.
3. Contributions to Elected Officials
The County contribution limit of $1,500 remains unchanged. Individuals or entities doing business with the County in excess of $10,000 over the four preceding years are prohibited from contributing more than $1,500 to an elected official or candidate for County office in a single calendar year.
4. Interactions with the Gift Ban
Cook County vendors, lobbyist, and those seeking action from the government are prohibited from giving gifts to a County employee, official, or department in exchange for preferential treatment or favors (quid pro quo). This prohibition applies regardless of the value of contracts with the County.
County employees, appointees, and officials and their relatives cannot accept or solicit gifts of cash, gift card(s), or cash equivalent from any prohibited source, which includes persons doing business with the County for more than $25,000 over the last four years. Gifts cumulatively valued below $100 within a single calendar year (January 1 – December 31) are permitted.
Reminder: The Board of Ethics’ Online Disclosure Forms
In September 2024, the Board of Ethics launched its case management system, streamlining the process to file disclosures, requests for advice and investigations.
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File the Disclosure Form for reporting conflicts of interest, gifts/favors, agency post-employment certifications and employment of relatives.
- Please note that the Board of Ethics only accepts the dual employment records of Elected Officials only.
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File a Request for an Advisory Opinion to receive staff or formal board opinions. Cook County employees should also use this form to report conference invitations and training requests. Please submit requests to attend conferences as soon as possible.
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File a Request for Investigation form to report potential violations of the Ethics Ordinance, such as misuse of County property or violations of the post-employment restrictions.
If you have any questions about these updates, please contact the Board of Ethics at (312) 603-4304, cookcounty.ethics@cookcountyil.gov or by submitting a request for advice using this online form.
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