Former Baltimore City Health Commissioner Dr. Ihuoma Emenuga, who is the subject of a criminal investigation, may have also violated city ethics laws when she was working for Chase Brexton while also a city employee.

Chase Brexton, a nonprofit health care group focused on providing services to poor and underserved populations, holds city contracts with the health department to help with health literacy and finding primary care for people with HIV. The nonprofit is also a subcontractor for the city’s needle exchange program, records show. Since 2022, the city has paid Chase Brexton upwards of $1.4 million, with the Board of Estimates approving a contract with the health provider last week.

While some City Hall personnel, like councilmembers, work outside jobs, city code makes clear that employees are prohibited from working for or receiving payment from organizations that have contracts with their agency, as Chase Brexton does with the health department. Even organizations that are in negotiations for a city contract are off limits.

Mayor Brandon Scott fired Emenuga on Monday evening, less than seven months into her tenure, after learning she was under criminal investigation, according to multiple people familiar with the matter but who were not authorized to speak publicly.

Baltimore Inspector General Isabel Mercedes Cumming’s office was investigating Emenuga and whether she was committing time theft. Cumming forwarded her findings to the Maryland State Prosecutor’s Office, which has opened its own investigation, the sources said. The inspector general’s office and the state prosecutor do not confirm or deny the existence, or absence, of investigations.

At least part of the criminal probe into Emenuga is focused on determining whether she was doing work for Chase Brexton during city hours, which could amount to time theft. Officials with the health care provider have refused to answer questions about Emenuga’s work there this past year, including whether it was paid.

Scott’s office did not immediately return requests for comment on the criminal investigation or the possible violations of the city ethics code.

Emenuga has not returned phone calls seeking comment; no one came to the door when a reporter visited her home Thursday.

It’s not uncommon for city health commissioners to maintain involvement in an outside practice to keep their medical licenses. Dr. Leana Wen, a former city health commissioner, recounts in her memoir, “Lifelines: A Doctor’s Journey in the Fight for Public Health,” that she volunteered once a month at a local health center for underinsured patients.

Although it’s not clear whether Emenuga was making money from her work at Chase Brexton, it may not matter when it comes to city ethics law. A city ethics board opinion from 2021 clarifies that even volunteer work counts as employment — a liberal interpretation of the term that the board argued is important to guard against any perception that an organization has benefited from a staffer’s “inside connections” at their agency.

Before becoming health commissioner, Emenuga had significant ties to Chase Brexton. She was the medical director at its Woodlawn clinic from 2018 to 2022, for which she was paid more than $200,000 annually, tax records show. Chase Brexton’s website now lists her as a “staff physician” at that clinic.

Baltimore’s ethics board would investigate whether Emenuga violated city law if it received a complaint accusing her of doing so, according to its website. The complaint and investigative process is confidential.

Although violations of city ethics laws do not carry criminal consequences, city officials are required to fill out financial disclosure forms, filed to the ethics board, under penalty of perjury. Those forms require people to disclose outside employment, sources of income and ties to or previous employment with city contractors.

Emenuga’s financial disclosure, filed in May, covers the 2023 calendar year and mentions only her ownership stake in Vie Health, a consultancy that doesn’t do business with the city. Before joining the health department in January, Emenuga worked as a medical director for Family Health Centers of Baltimore, which holds city contracts, records show. Also in 2023, she worked for Park West Health System, which also holds city contracts. Emenuga did not list her employment at either on her ethics form.

There is history of city employees being prosecuted for failure to disclose outside income. In 2021, a woman pleaded guilty to perjury for failing to disclose on her ethics forms over $15,000 of outside income she earned from 2014 to 2017 while working in then-City Council President Bernard “Jack” Young’s office.

The Maryland state prosecutor brought that case.

“Government officials are required to file truthful and accurate financial disclosure forms to ensure transparency and identify any potential conflicts of interest,” Charlton T. Howard III, the state prosecutor, said at the time. “Our office will continue to hold accountable any public official who abuses the public trust.”

Banner reporter Meredith Cohn contributed to this article.