Untitled Texas Attorney General Opinion

. Honorable Robert S’.Calve& ,Opinion Noo, M-138 Comptroller of’Public Accounts State Capitol Building Ret Whether a policy for group Austin, ,Texas life insurance coverlng,employees of the Comptroller’s Department, executed prior .to the effective date of Senate Bill 294, Acts of the 6Qth Zegialrture, Regular Session, Chapter 437, authorizes the Comptroller“ t.6 ma,ke pr~emium payments therefor from State funds, Dear Mr 0 Calvert: and certain ‘relatedquestions. Reference is made to your letter in which you request an opinion from this office as to’the captioned matter. We,quote from your letter, in part, as follows: ,,. “I am the policyholder of a ‘group policy ~~. . covering employees of my department, such con- tract being made~prfor to the effective ‘date ?P ” Senate Bill 294, Acts of the 60th Legislature. “(1) Does this,contract permit me to maka premium payment.8from State funds, or must a new contract be obtained before payments can be made? ‘(2) Zs group 1%f8 insuTanC8 elltgiblefor premium payments by the state? 8(31,.,Arye,,funds appropriated to ‘me for the ‘: I .. .:. ,,,~ ~,’operatlon of th s department for the ‘, 6 fisca) year ending August 31, 1968, : available for the payment of insuraW3 prcaiums? ..‘., ..$ll%h’reference to question number (1 , you are advised that State funda may be utilized as,wntribut for premium ,’ ‘, ),, . 3 Honorable Robert~S.., Calvert,:page 2,(M- 138) ., ? ,..,, .,y payments .under,jroslr'present'gr~~~. insurance.contrait. ', .Senate,' 'Bill~294 Acts,of ,the'69th :Legi~slatur~e,~~~~Rsgular .Session,.I$$ :"~~' :~~ Chapter &37,-,:Pages:::lOO7, Its,* devoid .,of'~, any '1'anguagt:'which would? '~, require 'a~ departmental head~to..ex.ecut:e a~,new.gro~p,pcQ$+con- ,’ tract for the purpose of making,premlum peg?aents,there,for"from state.funds. ~. The an&war to question ~~ber'(2),ire.~in.th8:.gffi~T.::,. tive.~ ,The caption of .SenateBill ,294'providesas follows: '~'~ ~' "AR:ACT'ampndlng Paragraph (b)',.of Subsection '. ~'&3) Of Sectionlof Article,3050 of the~Insuranc8, ode and amending Subsection(a) of Section 1 of .~~. .Article 3.51 of th8~InsUranC8 Code,to pein&t th8 '~ .: expenditure of stat8 fund,sto paysall nor any par- " tiOn of tht~.p.remiums for Certain group~.insurance contracts'coverln& employees of the state;.. .~." With relation to the expenditurc,of,state funds for life pOliCy premiums;'Senate Bill,2g&ar@ndQd,Paragraph Subsection (3) of Section.1, Article 3.50, 'by striking the .~ " ~"Thepremium for the policg'shall be paid by~the policyholder~wholly'from funds contribu- ted.by the in,suredemployees?, .~ ~~. .~., ',and inserting in 'lieu.,the&f the following:, premium it& the.pol+cy may be paid '.'?!be in whol~eorln part,fromfunds contributed ,by the,policyholder or in whole or inpart'from ,fundscont,ributedby~the insured employees." Subsection (3~),, Section l,,/Article3*5O’bf the~Insurance Code ,. provides Sn part: .~ .i '((3), A policy ls$Ged tb: 0’D’~ ; any aaso- ..~ : ciation~of state employees . D a and any de- ..,partmentof~the state government which employer or association shall be deeme~tthe',pollcyholder. to insure the ~employeesho D *, .' ,.: .,, 'I ~.~'.- : :- .. . Honorable Robert s..calvert, page 3 (M- 138) I, ‘.. From the foregolrigit is,apparent ~that state funds may be used as contributions.toward group life premium payments when the employer is the policyholder. Lothas been heretofore held by this offlde that a state agency may contribute state funds in payment of the premiums ,of, group insurance covering its employees under the p.rovih$onaof Subsection (a) of Section 1 of Article 3.51, ‘of the Insurance Code, as amended by Senate Bill 294, Acts of the 60th Legisla-’ ture e Such is a public governmental purpose benefltting the state a Opinion by the Justices, 30 So.2d 14 (Ala.Sup.1947 ; ?&.M:291,20. p.421 (19211; 658, 251 SW 46 (1923 ; 42 Cal. App..2d,40.9,108 ib 2d ,’ ,. We are in agreement with the reasoning of the Supreme Couri of Hisslsslppl in Mayor and Alderman of City of Vicksburg v. Crichlow, 196 Miss, 239 lb Smy~ whereln the statute concernina benefit; to ao&mental emDlouee8 was UD- ,held as not gratl;ties and as not extra compensation, but - being prospective ,lt serves ,abeneficient and useful govern- mental function in Its propensfty for stimulating and’renardtig faithful public servic,esV The same reasoning would hav,eapplication $0 the gxpendi- ture of’state finds to pay.prem$wns on insurance ccktracts con- cerning ‘state employees 1 Question number (3) as posed ln’your letter, “Are funds appropriated to me for the operation of this deptitment for the fiscal year ending August 31, 1968, available for the payment of insurance premiums?” is also answered .ln the affirmative. Of course , you are aware that Senate Rill 15, Acts of’ the 60th Zegislature, Regular Session, 1967, which is.the- ‘7 4 Appropriation Bill for the fiscal year September 1, 1967, to’ August 31, 1968,.contains no specific appropriation for the Comptroller of Public Accounts to make premlum~payments in whole ,or in part, on group insurance contracts asp authorized by Senate ” Bill 294. In our opinion no specific appropriation is requfred. In Senate Bill 15, p* IZf-33, the following appropria- t$on has been made for the Comptroller of Publ&c Accounts: : * . ,.~ ,,~ ‘.,‘, ( .. I, 1 .~: -640- ..~ 1, , . I ,,, . . Honorable Robert S. Calvert, page 4 (M- 138) "For the year ending'August 31>‘&8 ,.~.. ” . . e 1115. Consumable supplies and, materials, current and recurring operating expense, and capital Z, $1,846,340” outlay ~~....~e.~e*.........*.....es~....~~., It is noted that on page v-34 of Senate Bill 15 the Legislature placed certain limitationson the use of the expense funds as reflected in item number 15 as shown above. These limitations are, in part, as follows: "Section 11. LIMITATIOES ON USE OF OTREI'EXPERSE FOR m S-S AWD WAC%% "Funds appropriated in Articles I, II, .and III of this Act, or for the Central Education Agency.in Article IV of this Act, in items design- ,:~ nated for consumable supplies and materials, current and recurring operating expense or capital outlay shall be expended only for items set out in the Comptroller's Manual of Accounts, Expendi- . ture Classification, effective November 1, 1965; as.~amend,ed, and numbered from.lO.to.19'for,.!'.don~~,~..:. sumable supplies and materials", 20 through 28 for "current and recurring operating expense," and 60 through 69 for "capital outlay". It is further provided that such terms shall not include expenditures for personal services including salaries and wages, unless the langua e of those items explicitly authorizes such use.if An examination of the Manual of kckounts, State of Texas, Comptroller of Public Accounts, reflects on page 4-25 under Current or Recurring Operating Expense, Expenditure Code 'number 027, in part, the following: n027 IRSUl&ECE AND BOND PREMIUMS Authority: Legislative Appropriation , Purpose: To .recordpayment of in- surance and surety bond, premiums. . . . . 1 3onorable Robert S. Calveat, page ,5 (W- 138) ,. As was stated in Attorney General's Opinion.130.j wi,f-888 (1960): "The house and utilities to be.furnished s the business manager are not a part of his salary. .They are.something in addition thereto,,..... . That is to say, they are Incident to the position j of businoss,manager, something gained from the employment above and beyond the salary or wages for services rendered. Therefore, the rental payments are 8 general operating expense,properly payable from Line Item 8 of the appropriation to the Denton State School." The reasoning of Attorney General's Opinion No. WW-888 appe,arsapplicable to our situation at hand. Insurance pre: mium payments made on behalf of state employees with state funds are not salaries or wages to that employee but are a benefit to the employer. Therefore, in conjunction with question number (3), you are advised that the payment of group insurance premiums as authorized by Senate Bill 294 may be paid frommoneysappropriated to your agency for the fiscal year ending August 31, 1968, for operational expenses. SUMMARY ------- Senate Bill 294 does not require the department head of a state agency to execute a new group policy contract before premium payments can be made with state funds wherein the department head is the policyholder of,a group policy contract, wh.ichwas executed prior to the ef- fective date of such bill. Senate Bill,294 authorizes the.use of state funds as pr@um contributions on group life ,insurancekherein the employing agency is the policyholder. Moneys appropriated to the Comptroller of Public Accounts for the fiscal year ending August 31, 1968, for "current and recurring operating ex- pense? .is available for the payment of insurance premiums,'as authorized by Senate Bill 294. - 642 -~ . Honorable Robert S. Calvert, page 6 (~-138) ,GEHERAL.OF TEXAS, Prepared by Ray McGregor Assistant Attorney General" .: APPROVED: OPINION COMMITTEE Hawthorne Phillips, Chairman : Kerns Taylor, Co-Chairman Sam Kelley ‘. John Banks Roger Tyler Malcolm Quick John Reeves c - 643 -