Less than four months after Manuel Laboy Rivera ended his tenure as executive director of the Central Office for Recovery, Reconstruction and Resiliency, known as COR3, his new company, NovaForge Consulting Partners LLC, had already signed its first contract with the government of Puerto Rico.
But he was not the only one to leave COR3. The team at the company, registered in January 2025, includes at least seven former COR3 officials: Marlena V. Riccio Paniagua, Sebastián E. Batista Bustelo, Zulma N. Rovira Pérez, Gabriel E. Salgado Hernández, Alejandro R.J. Nieto Vincenty, Kristie M. Flores Carrubio and Katerina S. Cayere Díaz.
In his work proposals, Laboy Rivera boasts that his team has “unmatched experience in the formulation, implementation and management of federal and state initiatives.”
The former COR3 executive director now performs functions like those he carried out in the public sector, but as a private consultant: working on disaster recovery matters and advising clients on compliance with the rules and regulations required for the use of federal funds. His potential clients include municipalities, companies, public agencies and nonprofit organizations, according to NovaForge Consulting Partners LLC’s website.
“We don’t just manage programs and projects; we drive transformation,” promises Laboy Rivera’s company. From 2021 until December 2024, he led the Central Office for Recovery, Reconstruction and Resiliency. COR3 was created in 2017 as a division of the Puerto Rico Public-Private Partnerships Authority to coordinate and oversee federal funds allocated after Hurricanes Irma and María, and it has drawn complaints about its bureaucracy and the slow pace of its reimbursements and advances.
Although Manuel Laboy Rivera’s name does not appear in the Department of State’s corporate registry as holding any role in NovaForge, the company’s website identifies him as its president.
Laboy Rivera was not available for an interview requested by the Centro de Periodismo Investigativo (CPI).
No Ethics Consultation on Legislative Contract
NovaForge’s first contract was with the Legislative Assembly’s Budget Office, or OPAL, in Spanish, to handle recovery matters and provide consulting, advisory and specialized management services in fiscal policy, finance and public administration, project development and viability, and economic policy. The contract, which began in March 2025 and expires this June, is worth $144,000.
The contract also allows NovaForge to provide services to the House of Representatives and the Senate. In fact, Laboy Rivera accompanied Senate President Thomas Rivera Schatz and other senators on visits to members of Congress in Washington, D.C., in 2025 and this year. OPAL separately reimbursed NovaForge for the costs of those trips, lodging and meals.
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NovaForge has amassed nearly $1.2 million through contracts with OPAL, the Public Service Regulatory Board, the Puerto Rico Electric Power Authority through Genera LLC, the Office of the Veterans Advocate and the municipalities of Carolina, San Juan, Toa Baja, San Lorenzo and Peñuelas.
When the CPI asked whether Laboy Rivera’s hiring by OPAL could have triggered any prohibition, the Office of Government Ethics, or OEG, said: “The Office was not consulted regarding the hiring of engineer Manuel Laboy Rivera by the Legislative Assembly’s Budget Office, so we do not have the information necessary to determine whether the relevant provisions of our Organic Law should have been activated.”
The OEG also said that “no former public servant is required to consult” the agency.
But Laboy Rivera himself had doubts about whether he could pursue some government contracts. In April, June and September of last year, the former official asked the ethics office whether he could offer his services to several municipalities and agencies, according to OEG documents.
In response to his first inquiry, OEG Assistant Director Massiel Hernández Tolentino said neither Laboy Rivera nor his corporation could “provide advisory services or services of any other kind, whether through contracting or subcontracting,” to the entities he had asked about. He made the inquiry to the OEG when NovaForge was seeking contracts with the municipalities of Yabucoa, San Sebastián and Gurabo, where it had already submitted proposals to compete for program management contracts. Laboy Rivera also reported having potential service contracts with American University, LUMA Energy and Genera PR.
The OEG’s decision states that the Ethics Law prohibits a former official from being hired by an agency in which the official intervened in official actions during the previous year within the year after leaving public employment. An “official action” is defined as “rendering advisory services, conducting investigations, filing charges, auditing, adjudicating, and rule making on specific areas advising, investigating, accusing, auditing, adjudicating, formulating rules and regulations on specific parties.” It also includes “any procedure related to orders, authorizations, exemptions, resolutions, contracts, granting of permits, franchises, accreditations, privileges, and licenses.”
Hernández Tolentino said in the letter that Laboy Rivera handled “matters related to these entities’ grants” in 2024 in his roles as COR3 executive director and as the governor’s authorized representative before the Federal Emergency Management Agency (FEMA).
“You held meetings with their representatives, conducted field visits, answered their inquiries, represented them and managed their requests before FEMA,” the communication reads.
“It should be noted that, in those meetings or field visits, you discussed ongoing projects, their status, the challenges subrecipients were facing and the needs affecting their work. In that context, you made recommendations on project closeouts or the course of action to follow and evaluated alternatives for submitting inquiries to FEMA when there were disputes or questions about the interpretation and implementation of the programs under your charge,” Hernández Tolentino wrote.
The OEG official also said Laboy Rivera worked with the Puerto Rico Electric Power Authority, LUMA and Genera PR “to identify areas for improvement” and met with them weekly to work on redefining Puerto Rico’s energy plan.
Persistence Pays Off
But something changed between June and August 2025. On June 20, the OEG attorneys who had handled the inquiry granted Laboy Rivera a meeting he had requested. At the meeting, they discussed “the scope of the provisions applicable to former public servants,” and he also “submitted additional information related to the standardized grant agreements signed between COR3 and the subrecipients.”
Five days later, the former COR3 executive director again asked the OEG whether he could offer his services, this time to the municipalities of Aguadilla, San Lorenzo, San Juan, Fajardo and Caguas. He included Carolina in the inquiry, even though NovaForge had already had a contract with that municipality since May 2025. Laboy Rivera also told the OEG that his services would extend to American University, the Adventist University of the Antilles, the Roman Catholic and Apostolic Church, the Archdiocese of San Juan de Puerto Rico and the dioceses of Arecibo, Fajardo-Humacao, Caguas and Ponce.
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This time, the OEG assistant director found no impediment to the former COR3 official providing professional services to those municipalities and entities. Her determination, she said, was based on the fact that in 2024 Laboy Rivera did not award any grant contract to those entities. After evaluating the additional information, the OEG concluded that Laboy Rivera’s actions in 2024 involving the municipalities were excluded from the prohibitions in the Ethics Law.
The law states that, during the year after leaving public employment, a former public servant cannot be hired by an agency, private individual or business over which the person took official action in the year before leaving the job. However, the law excludes intergovernmental contracts. Agreements between COR3 and municipalities are considered intergovernmental.
Regarding the private entities, the OEG found that Laboy Rivera’s interventions were “procedural steps,” such as signing letters extending deadlines, that were part of the procedures established by FEMA for COR3. That area, too, was excluded from the Ethics Law.
“In addition, during the June 20 meeting, engineer Laboy stated that he had not been selected in the bids from the municipalities included in the first inquiry, so it was not appropriate to reconsider that determination,” the OEG told the CPI.
In his third inquiry, in September 2025, Laboy Rivera also prevailed. Sara González Clemente, the OEG’s acting assistant director, concluded there were no obstacles to NovaForge providing services, this time to PREPA, the Puerto Rico Industrial Development Company, the Mental Health and Anti-Addiction Services Administration, the Department of Agriculture, the Department of Education and the Department of Economic Development and Commerce. The same applied to American Military, Academia María Reina, Hospital Menonita, Med Centro and the Museo de Ponce.
González Clemente based the decision on the fact that the contracts were intergovernmental and that Laboy Rivera’s interventions were “procedural steps.”
According to the OEG, Laboy Rivera could begin signing contracts with municipalities and other entities in January 2026 because his duties as COR3 executive director ended Dec. 31, 2024.
Until December 2026, Laboy Rivera cannot advise or represent, directly or indirectly, a private individual, business or public entity before COR3 and the Public-Private Partnerships Authority, according to the OEG. Nor can he do so before the Puerto Rico Institute of Statistics or the Puerto Rico Convention Center District Authority — which oversees the Convention Center, the Coliseo de Puerto Rico and the Antiguo Casino — because he served on their respective boards of directors.
Revolving Doors and Business Advantage?
Sylvia López Palau, a business ethics professor at the University of Puerto Rico’s Río Piedras campus, told the CPI that in this case it is necessary to consider “whether he had access to privileged information that allows him to do more business than other people, because then it is unfair competition, and that is unjust.”
She said that if the company obtained contracts in 2025 through bidding processes, both Laboy Rivera and the former COR3 employees may have information that gives them an advantage over other competitors.
“And that is not fair, because there must be transparency,” added the professor in the School of Business Administration.
López Palau said the situation is “without a doubt” an example of a revolving door.
Transparency International defines “revolving doors” as “the movement of individuals back and forth between public office and private companies, in order to exploit their period of service to the benefit of their current employer.”
No, Then Yes
Of the rest of the NovaForge team members who were COR3 employees, only Gabriel Salgado Hernández and Sebastián Batista Bustelo consulted the OEG, in November and December of last year.
The ethics office barred Salgado Hernández, a director at NovaForge, from offering services to PREPA, Genera PR and LUMA Energy, “personally or through the company NovaForge, on all matters he evaluated, processed, advised on, deliberated, recommended and determined related to grants to them.” As COR3’s Energy Associate Director, he worked closely with those entities because he coordinated and supervised energy infrastructure recovery efforts, González Clemente explained in a written response to Salgado Hernández last November.
The OEG found no impediment to the NovaForge director providing services to PRIDCO and other agencies, to private entities and to the municipalities of Naranjito and Guayama, among others. Salgado Hernández worked at COR3 from October 2021 to February 2025, where he also held the positions of project manager and energy sector lead.
At first, the OEG barred Batista Bustelo, a senior manager at NovaForge, from offering services to several municipalities, government agencies and nonprofit entities.
In a request for reconsideration, the former official told the OEG that his signature on grant agreements and amendments with those entities while he worked at COR3 “constituted a strictly procedural and ministerial step, without discretion, substantive evaluation, investigation, recommendation or individualized determination on his part.” Batista Bustelo worked as chief of staff at COR3 from June 2023 to February 2025.
After that request, the OEG changed its position. It notified Batista Bustelo that he could offer services to those same entities “on matters that are different, new or unrelated to his prior interventions as a COR3 public servant.”
Both former officials are barred, directly or indirectly, from advising or representing municipalities, public agencies and nonprofit entities, any NovaForge client or any other person or entity before COR3 and the Public-Private Partnerships Authority until two years after the date they ended their government employment. Salgado Hernández may do so after Feb. 28, 2027, while Batista Bustelo may do so after Feb. 7, 2027.
This translation was generated with the assistance of AI and reviewed by our editorial team to ensure accuracy and clarity.
