The state Department of Human Resources said yesterday that Annapolis lobbyist Bruce C. Bereano met with its officials on behalf of the winning bidder on a disputed $42 million contract even though he is not registered to represent the organization.

Elyn Garrett-Jones, a spokesman for the Department of Human Resources, said that Bereano conducted two meetings in April with department procurement officials concerning details of the lucrative foster care contract that had been awarded to the nonprofit Adoptions Together.

Garrett-Jones said yesterday that two department employees recall that, at one of the meetings, Bereano introduced himself as a representative of Adoptions Together. In fact, Bereano was registered with Social Work Associates, a for-profit company whose owner was apparently playing a role in the effort to land the contract.

"Never was there a mention of Social Work Associates," Garrett-Jones said. "He kept referring to Adoptions Together as his client," according to her employees.

According to state ethics law, it is illegal for a lobbyist to knowingly conceal from officials the identity of the entity he is representing.

The executive director of Adoptions Together has denied Bereano was involved in its procurement effort.

The Sun reported Wednesday that Bereano had signed an agreement with Social Work Associates and its parent, Mercer Ventures Inc., guaranteeing him a cut of any government business he could drum up for the firm. Contingency fee arrangements are prohibited by the state ethics law.

Bereano did not return calls from The Sun for the fourth straight day. However, he told the Washington Post on Thursday that the agreement did not constitute an illegal contingency fee.

The lobbyist also disavowed his earlier disclosure that he earned more than $139,000 in lobbying fees over the past six months from Social Work Associates. He filed an amended disclosure with the State Ethics Commission late Thursday, saying he earned only $17,579 from the company. He told the Post he might have made a mathematical error.

The contract Bereano was discussing with state officials concerns some of the most vulnerable children in the state - 500 Baltimore residents in foster care and in need of adoption. The department is seeking a private contractor to run its program for three years, at about $14 million a year.

The use of an outside organization for this purpose is part of a growing trend toward privatization of social services - a lucrative business for nonprofit groups and for-profit companies.

The department chose Adoptions Together as the winning bidder this year, replacing Foster America. The contract was on the Board of Public Works agenda in April, but was put on hold after Foster America challenged the award at the Board of Contract Appeals.

Foster America charged that the contract award was tainted by the intervention of lobbyists and lawmakers.

Robert A. Hahn, general counsel of the State Ethics Commission, would not comment on whether Bereano's contacts with the department might violate state ethics law.

Bereano could also face questions from the commission, which has the power to fine him or shut down his lobbying practice, about the Social Works Associates agreement.

Former Del. Donald B. Robertson, who led a state task force that studied Maryland's lobbyist ethics laws, said he was skeptical about the lobbyist's denial that the agreement included a contingency fee. After being read Bereano's letter of agreement to company owner Michael D. Traina, Robertson said that "based on my limited understanding of the facts, it would certainly seem to be a contingency arrangement."

Bereano also could face questions from the Ethics Commission about his original financial disclosure.

The commission generally allows officials and lobbyists to amend their disclosures to correct inadvertent mistakes. However, there has also been at least one case in which the panel has determined that a filer's original disclosures were intentionally deceptive and refused to be swayed by a later amendment.

In Bereano's case, Robertson said, "I don't believe the amendment eliminates all questions."

Bereano's claim of $139,000 from Social Work Associates had helped push his earnings past $800,000 for the six-month period that ended April 30 - near the head of the list of top-earning lobbyists.

"Many lobbyists feel an incentive to be high on that list," Robertson said.

Sen. Barbara A. Hoffman, chairwoman of the Budget and Taxation Committee, said that when large out-of-state companies have a legislative issue in Maryland they frequently say, "Get me the top lobbyist." Often, she said, that translates to the highest-earning lobbyist.

Robertson said he would need to know more before he could say whether Bereano's contacts with the Human Resources Department pose a problem. "It would depend on the interaction between Bruce and the department," he said.

Earlier in the week, Janice Goldwater, executive director of Adoptions Together, denied that Bereano and Traina, formerly a top executive of Foster America, had played a role in the nonprofit's pursuit of the contract.

However, a deposition obtained by The Sun shows that Adoptions Together Associate Director Dawn Musgrave acknowledged in January that Traina had taken part in five to 15 meetings last summer and fall at which the group's bid proposal was prepared. The deposition was taken as part of a lawsuit against Traina by Foster America, his former employer.

Goldwater did not return calls yesterday seeking to clarify the role of Bereano and Traina. In the earlier interview, Goldwater said Social Work Associates had contacted Adoptions Together in an effort to win business. She also said the group was considering hiring Bereano as its lobbyist but had not done so.

Traina did not return calls.