THE FORMER CHIEF OPERATING OFFICER of MassHealth, the state’s Medicaid program, agreed on Wednesday to pay a $25,000 civil penalty to the State Ethics Commission to settle charges that he negotiated a job with a major consulting firm at the same time the firm was being solicited to work on a project funded by the agency.

According to the disposition agreement, Philip Poley, who was MassHealth’s COO from 2007 until 2010, made overtures to the Accenture consulting firm in 2009 at the same time he was inviting the company to participate in the development of a Medicaid analysis unit at UMass Medical School in Worcester.

Starting in 2009, Poley began discussing the project with Accenture officials, and, in November 2010, a $420,000 consulting contract was finalized. Over the same time period, Poley showed interest in a “confidential conversation… to explore career alternatives” with the firm. On June 29, 2010, he filed a disclosure with his superior at the executive office of Health and Human Services and the State Ethics Commission in reference to his job discussions with Accenture and halted work on the UMass/Accenture contract.

Poley officially vacated his position at MassHealth, where records indicate he was paid $110,000 a year, in August 2010. He joined Accenture in September at a base annual salary of $185,000, with the potential for performance-based bonuses.

According to the Ethics Commission, Poley’s actions violated several conflict of interest laws, including his failure to file a timely disclosure. Additionally, he continued to provide guidance to former colleagues at MassHealth about the development of a Medicaid analysis unit while working at Accenture, another violation of the code.

Attempts to reach Poley at Accenture on Wednesday were unsuccessful.

As a public employee, Poley was prohibited from using his position to leverage a private sector opportunity, according to State Ethics Commission Executive Director Karen Nober. “Contacts with potential employers must be disclosed before public employees may take any action involving those entities, and in certain circumstances, they must abstain entirely from matters affecting a potential employer,” she said in a statement.