Washington Association of Nurse Anesthetists PAC: Alleged violations of RCW 42.17A.235 and .240 for failure to timely & accurately report contributions and expenditures in election years 2024 & 2025 (MAY25)

The first complaint alleged 1) a discrepancy between the Respondent’s ending balance for 2024 and beginning balance for 2025; 2) failure to file reports based on the accelerated reporting schedule for 2024 and 2025 election participation; and 3) late reporting. Specifically, Mr. Edwards (the “Complainant”) alleged that 1) monthly C-4 reports for January and April of 2025 and a C-3 report for 4/30/25 were filed late; and 2) the vendor’s address was missing from an April 2025 expenditure. The second complaint alleged the Respondent failed to file a 21-day pre-Primary C-4 report for 2025. The third complaint added allegations of 1) a late C-3 report for 6/30/25; and 3) failure to file a 7-day pre-Primary C-4 report for 2025. As evidence of election participation, the Complainant provided a printout of PDC records showing that 2025 candidates Michelle Caldier and Tina Orwall reported they had received contributions from the Respondent committee.

Based on the attached findings, this case was resolved as follows:

The Respondent completed a Statement of Understanding (SOU) and paid a $600 civil penalty on November 19, 2025 in accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule), acknowledging violations of RCW 42.17A.235 and RCW 42.17A.240 for failing to timely file the 21-Day pre-Primary, 21-day pre-General, 7-day pre-General, and December C-4 reports for election year 2024. The $600 penalty assessed resolves the allegations concerning these late reports. 

In addition, pursuant to WAC 390-37-060(1)(d), the Respondent received a  formal written warning concerning their failure to timely and accurately disclose all contribution and expenditures on C-3 reports in 2024 and 2025, C-4 reports for 2025, and the remaining C-4 reports for 2024 that were not resolved under the aforementioned SOU. PDC staff expect the committee to timely and accurately file required reports of contributions and expenditures in the future The Commission will consider this formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules. 

The Respondent also made a minor or ministerial error on a required C-4 report, which did not materially harm the public interest. The committee made the necessary technical correction to amend their committee’s carryforward starting balance for 2025 to match their ending balance for 2024 within 2-14 days of being notified by PDC staff, as required for a matter resolved as a technical correction. See WAC 390-37-060.

PDC staff reminded the committee about the importance of including complete expenditure description details on C-4 reports, including vendor address, in accordance with the PDC laws, rules or guidance. 

Based on this information, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1).