SEIU 775 Quality Care Committee Sponsored by SEIU PEAF: Alleged Violations of RCW 42.17A.260 & .305 for failing to accurately describe expenditures in C-6 Reports of Independent Expenditures and Electioneering Communications (EY '23; AUG '23)

Case

#141192

Respondent

SEIU 775 Quality Health Care PAC Sponsored by SEIU PEAF

Complainant

Glen Morgan

Description

• Allegation: Violations of RCW 42.17A.260 & .305 for failing to accurately describe expenditures in C-6 Reports of Independent Expenditures and Electioneering Communications

The PDC dismissed this matter in accordance with RCW 42.17A.755(1) and will not be conducting a more formal investigation into these allegations or taking further enforcement action in this matter.

• The complaint identified ten C-6 reports filed by SEIU 775 Quality Care Committee in July 2023 in support of candidates. Three of the C-6 reports concerned Independent Expenditure mailings for which the Committee paid Moxie Media to prepare and mail. The three C-6 reports that reported Independent Expenditure mailings were filed on July 12, July 19, and July 26, 2023. The description of the expenditure for each report was “IE Mailing.”
• The remaining seven C-6 reports identified in the complaint concerned Independent Expenditures for which the committee reported the vendor as SEIU 775 and provided a description of the Independent Expenditure as “In-Kind Staff Phone/Text,” which was provided by SEIU 775, the entity that controls the Committee.
• On August 31, 2023, SEIU 775 Quality Care Committee amended the three C-6 reports that concerned Independent Expenditure mailings for which the Committee paid Moxie Media to prepare and mail. The amended reports included additional expenditure detail describing the work performed by Moxie Media for the Committee and included the names of sub-vendors and the number of pieces mailed. For example, C-6 report 11969, filed on July 12, 2023 was amended by C-6 report 12012 on August 31, 2023. The total cost for the original and amended C-6 reports was $7,311.16, in support of Brittany Williams. The amended C-6 included the following descriptions and amounts for its payment to Moxie Media, which total $7,311.16:
• IE Mailing Consulting Fee $2,701.39
• Claro Creative Graphics $700.00
• Cap City Press (6,000 pieces)
• Cap City Press Mail Services $349.28
• Expenditures $200 or less $93.75
• USPS – Postage $1,886,86
• SEIU 775 Quality Care Committee did not amend the remaining seven C-6 reports identified in the complaint, stating they did not do so because the expenditures listed in these reports involved internal staff time for phone calls and texts in support of City of Burien candidates for which the Committee did not use a sub-vendor for robocalls or mass texting.

The PDC has not issued guidance concerning what is required to satisfy the reporting requirements in RCW 42.17A.260 and RCW 42.17A.305 to provide “a detailed description of expenditures.” Although specific standards are not explicitly required by statute or rule, staff appreciates the value of a detailed description of expenditures and is thankful for the Committee’s willingness to voluntarily provide a more detailed description of their expenditures to vendors. The Committee provided a general description of internal services when outside vendors were not used and the PDC has not issued guidance suggesting that additional detail be provided.

PDC staff will consider providing additional guidance concerning the meaning of “a detailed description of expenditures” and for describing the use of internal staff to conduct campaign activities when reporting independent expenditures and electioneering communications.

Disposition

Case Closed with No Evidence of Violations

Date Opened

August 17, 2023

Areas of Law

RCW 42.17A.260, RCW 42.17A.305

Documents

• 141192 SEIU 775 Quality Care Committee Sponsored by SEIU PEAF Complaint.pdf
• 141192 Combined Case Closure Letters.pdf
• 141192 Response to Complaint.pdf