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HomeMy WebLinkAbout1618 Stinson In Re: Denise H. Stinson, : File Docket: 12-015 Respondent : X-ref: Order No. 1618 : Date Decided: 7/9/13 : Date Mailed: 7/12/13 Before: John J. Bolger, Chair Nicholas A. Colafella, Vice Chair Raquel K. Bergen Mark R. Corrigan Roger Nick Kathryn Streeter Lewis This is a final adjudication of the State Ethics Commission. Procedurally, the Investigative Division of the State Ethics Commission conducted an investigation regarding possible violation(s) of the Public Official and Employee Ethics Act (“Ethics Act”), 65 Pa.C.S. § 1101 et seq., by the above-named Respondent. At the commencement of its investigation, the Investigative Division served upon Respondent written notice of the specific allegation(s). Upon completion of its investigation, the Investigative Division issued and served upon Respondent a Findings Report identified as an “Investigative Complaint.” A Stipulation of Findings and a Consent Agreement were subsequently submitted by the parties to the Commission for consideration. The Stipulated Findings are set forth as the Findings in this Order. The Consent Agreement has been approved. I.ALLEGATIONS: That Denise Stinson, a public official/public employee in her capacity as a Member of Yeadon Borough Council, Delaware County, violated Sections 1103(a) and 1105(b) of the State Ethics Act (Act 93 of 1998), 65 Pa.C.S. §§ 1103(a) and 1105(b), when she used the authority of her public position to obtain a private pecuniary benefit for herself and/or members of her immediate family by using her position to receive payment from the Borough for the costs of private health insurance; and when she subsequently participated in actions of Council to approve payments issued to her for private health care insurance costs; and when she failed to disclose on a Statement of Financial Interests filed for the 2011 calendar year real estate interests, creditors, direct and/or indirect sources of income, gifts, transportation, lodging and hospitality, financial interests in any legal entity for profit and business interests transferred to immediate family members. II.FINDINGS: 1. Denise Stinson has served as a Council Member for Yeadon Borough, Delaware County, from January 4, 2010, through the present. a. Stinson was elected to Council during a special election held in November 2009. Stinson, 12-015 Page 2 b. Stinson has served as President of Yeadon Borough Council from August 2012 until the present. 2. Yeadon was incorporated as a Borough in Delaware County, Pennsylvania, on March 9, 1893. a. According to the United States Census Bureau, the population of Yeadon Borough was 11,443 at the 2010 census. 3. Yeadon Borough is governed by a seven-Member Council and Mayor. a. Historically, Council will hold two (2) meetings each month. 1. Council holds workshop meetings on the first Thursday of each month. 2. Council holds legislative meetings on the third Thursday of each month. 3. Council holds special meetings as necessary. 4. Compensation to be received by Members of Borough Council is capped by the Borough Code, 53 P.S. § 45101 et seq. a. Borough Council Member compensation is determined by the Borough’s population. b. Specifically, the Borough Code reads: Members of council may receive compensation to be fixed by ordinance as follows: (1) In boroughs with a population of less than five thousand, a maximum of eighteen hundred seventy-five dollars ($ 1875) a year. (2) In boroughs with a population of five thousand or more but less than ten thousand, a maximum of two thousand five hundred dollars ($ 2500) a year. (3) In boroughs with a population of ten thousand or more but less than fifteen thousand, a maximum of three thousand two hundred fifty dollars ($ 3250) a year. (4) In boroughs with a population of fifteen thousand or more but less than twenty-five thousand, a maximum of four thousand one hundred twenty-five dollars ($ 4125) a year. (5) In boroughs with a population of twenty-five thousand or more but less than thirty-five thousand, a maximum of four thousand three hundred seventy-five dollars ($ 4375) a year. (6) In boroughs with a population of thirty-five thousand or more, a maximum of five thousand dollars ($ 5000) a year. The salaries shall be payable monthly or quarterly for the duties imposed by the provisions of this act. Stinson, 12-015 Page 3 Benefits provided to members of council under section 1202(26) shall not be considered pay, salary or compensation, but payment for all or a part of the premiums or charges for the benefits shall be in accordance with section 1202(26). Any change in salary, compensation or emoluments of the elected office shall become effective at the beginning of the next term of the member of council. 53 P.S. § 46001. 5. Council Members are compensated at a scale of $150.00 monthly ($1,800.00 annually) for their service. a. The population of Yeadon Borough is 11,443, which would make Council Members eligible to receive compensation of $3,250 per year. b. Attendance at the monthly Council meeting is not required in order for Council Members to receive compensation. c. Per the Borough Code (53 P.S. § 46001), Council Members of Yeadon Borough could be compensated a maximum of $3,250.00. 6. In addition to compensation allowed for by law, Members of Borough Council are eligible to participate in Borough-funded insurance programs. a. The pertinent portion of the Borough Code regarding Council Members’ participation in Borough-funded insurance plans is found at 53 P.S. § 46202(26), which reads: (26) OTHER INSURANCE. (i) Workers’ compensation insurance. To appropriate an amount as may be necessary to secure insurance or compensation in accordance with Article VI of the act of June 2, 1915 (P.L. 736, No. 338), known as the “Workers’ Compensation Act,” for: (A) volunteer fire fighters of companies duly recognized by the borough, by motion or resolution, killed or injured while going to, returning from, or attending fires, or while performing their duties as special fire police; and (B) other borough employes as “employe” is defined in section 601 of the “Workers’ Compensation Act.” (ii) Life and health insurance. To make contracts of insurance with any insurance company, association or exchange, authorized to transact business in the Commonwealth, insuring borough employes, or any class or classes of employes, or mayor and council, or their dependents, under a policy or policies of insurance covering life, health, hospitalization, medical and surgical service or accident insurance. (iii) Pension contracts. To contract with an insurance company, granting annuities or pensions, for the pensioning of borough employes, or any class, or classes of employes, and to agree to pay part or all of the Stinson, 12-015 Page 4 premiums or charges for carrying the contracts, and to appropriate moneys from the borough treasury for such purposes. (iv) Liability insurance. To make contracts with any insurance company, association or exchange, authorized to transact business in this Commonwealth, insuring any public liability of the borough, and to appropriate moneys from the borough treasury for such purpose. (v) Nothing in this clause shall affect any contract, right or coverage of insurance vested or existing on the effective date of this clause. Contract, as used in this clause, includes an annuity contract, provided that the option to renew continues to provide the same rights to the annuitant that existed on the effective date of this clause. 53 P.S. § 46202(26) (emphasis added). 7. Yeadon Borough provides health insurance coverage for its employees through a policy managed by Independence Blue Cross. a. Participants in the Borough’s insurance plan pay no insurance premium. b. The Borough policy consists of two (2) groups: the Police policy group, and all other Borough employees. 1. The Borough’s Employee (non-police) group consists of no less than fourteen (14) members. 8. Upon amendment of the Borough Code in 2001, which amongst other provisions, allowed the participation of Council Members in a Borough-funded health insurance program, Yeadon Borough permitted elected officials to receive/participate in the same insurance benefit program that was otherwise provided to Borough employees. a. During calendar year 2010, only one Member of Council participated in the Borough’s health insurance plan. 9. In or around 2008, Council reviewed the Borough’s health insurance costs, and noted that the cost for Council Members’ health insurance was projected to exceed $64,000.00 for fiscal year 2009. a. Yeadon Borough Council adopted a budget for fiscal year 2008 at the end of calendar year 2007, that included a total of $22,762 for Borough-provided health insurance benefits. 1. Actual costs for health insurance benefits for the year 2007 were $29,521.84. b. The costs exceeded budgeted funds due to some Council Members participating in a family coverage plan. 10. As part of a cost-savings attempt, in 2008 Council directed Interim Borough Manager Paul Janssen to prepare a Resolution for Borough adaptation which limited/capped the costs of benefits provided to Yeadon Borough Council Members. a. All matters involving a financial expenditure with Yeadon Borough are first presented and reviewed by the Manager and Finance Director. Stinson, 12-015 Page 5 11. All Members of Council present at a meeting are to participate in voting on motions presented. a. The Mayor votes only in the case of a tie. 12. Council’s voting procedures on matters involving financial expenditures or accounts payable occur in roll call fashion. a. Votes on all other matters occur via a group “YES/NO” manner. b. All objections and/or abstentions are noted within the minutes. 13. On December 18, 2008, Yeadon Borough Council President Vivian Ford requested Council to consider a Resolution which would limit Council health insurance costs to less than $5,000.00. a. Meeting minutes for December 18, 2008, reflect the following: President Ford asked Council to receive and consider a resolution to restrict the compensation Borough Council members can receive as part of Borough paid health benefits to $5,000 Upon Motion of Vice President Byrne and Seconded by councilor McDonald the adoption of a resolution to restrict the compensation Borough Council members can receive as part of Borough paid health benefits to $5,000 was accepted unanimously by a vote of 6 to 0. b. Actual language of the approved Resolution No. 2008-12 reads, in pertinent part: NOW, THEREFORE, BE IT RESOLVED that the Yeadon Borough Council, Delaware County, Pennsylvania, hereby restricts the costs which Councilors and the Mayor may incur utilizing benefits as an elected official to $5,000 per TH RESOLVED AND ENACTED THIS 18 DAY OF official per year, and DECEMBER 2008. 14. Resolution No. 2008-12 does not authorize elected officials of Yeadon Borough to be reimbursed for their private insurance or insurance provided through an employer or other entity. 15. Yeadon Borough never enacted or established any type of policy that authorized elected officials to be reimbursed for their private insurance or insurance provided through an employer or other entity in lieu of enrolling/participating in a Borough- funded health insurance program. 16. Following the 2009 special election, and prior to Stinson taking office, Council Member Delores Jones-Butler approached Stinson and informed her that as a newly-elected Council Member, she was entitled to receive compensation as delineated in the Borough Code, including the option of participating in the Borough’s health insurance program. 17. Following Stinson’s installment as a Council Member for Yeadon Borough, Jones – Butler again informed Stinson that as an elected official of Yeadon Borough, she (Stinson) had the option of receiving insurance benefits at Borough expense. Stinson, 12-015 Page 6 a. Jones-Butler informed Stinson that she (Stinson) could either participate in the Borough-funded health insurance plan or be reimbursed by the Borough for health insurance expenses, up to $5,000.00 annually. b. Stinson opted not to participate in the Borough-provided health insurance benefit plan offered to employees/elected officials. 1. Stinson was not an employee of Yeadon Borough. c. Stinson did not seek immediate reimbursement for costs associated with her employer-provided health insurance, because she believed that she was not incurring any reimbursable expenses. 18. In a non-governmental capacity, Stinson has been employed as a Unit Facilitator for Mercy Fitzgerald Hospital for at least the past 33 years. a. As an employee of Mercy Fitzgerald Hospital, Stinson received as part of her compensation a salary and benefits. b. Stinson’s insurance benefits were provided to her as an employee of Mercy Fitzgerald Hospital by way of payroll deductions. 1. Stinson’s biweekly pay reflected deductions for health insurance benefits. 19. The costs of Stinson’s insurance benefits, as deducted from her pay with Mercy Fitzgerald Hospital, totaled approximately $312.37 per month (deducted biweekly), and as of December 2009, totaled as follows: a. Low PPO EE: $100.00; Dental-Concordia Prem-EE: $27.00; Supplemental Life: $3.82; Voluntary Benefits: $12.92; for a total deduction of $143.74 (biweekly). b. These deductions are in addition to health insurance benefit costs paid by Stinson’s employer. 20. On August 19, 2010, Janssen was removed as the Interim Borough Manager by a majority vote of the Yeadon Borough Council. a. Stinson voted in favor of Janssen’s removal. b. The position of Borough Manager remained vacant from August 2010 until approximately April 2011. 21. Following Janssen’s removal from office, on or around December 31, 2010, Stinson provided a copy of her pay statement and employer-provided benefit information to Yeadon Borough Finance Director Tyrone Jordan. a. Stinson provided the information to Jordan in order to secure reimbursement from Yeadon Borough for the costs associated with Stinson’s employer- provided health insurance. b. Reimbursements could not be made by the Borough without the pay statements being provided by Stinson. Stinson, 12-015 Page 7 22. Stinson previously declined to receive Borough-provided health insurance and was informed by Janssen that non-out of pocket expenses for health care costs/insurance were not eligible for reimbursement from the Borough. a. It was only after Janssen was terminated that Stinson sought reimbursement. b. Stinson waited until Janssen was terminated before she sought reimbursement for employer-provided health care costs, since Janssen previously informed her that her expenses were ineligible for reimbursement from the Borough. c. Stinson sought reimbursement after being advised by Borough Council Member Sandra Thomas that she was getting reimbursement for insurance benefits. 23. Either Yeadon Borough Finance Clerk Sheila Briner or Finance Director Tyrone Jordan initiated reimbursement payments to Stinson following receipt of Stinson’s pay statements. a. Stinson provided payroll information that enabled her to receive retroactive reimbursements. 24. Payments for health insurance reimbursements were placed on accounts payable lists for Council approval at regular legislative meetings of Council. a. Council receives the accounts payable lists prior to monthly meetings in meeting packets. b. The accounts payable lists represent expenditures not yet paid by the Borough. 25. On March 18, 2011, Stinson received two (2) retroactive reimbursement payments from Yeadon Borough, as reimbursement for her (Stinson’s) employer-provided health insurance costs. a. The first March 18, 2011, reimbursement payment totaled $3,748.42, and represented payment in the amount of $312.37 for twelve (12) months ($3,748.42 ÷ 12 ≈ $312.37) and represented payment for the year 2010. b. The second March 18, 2011, reimbursement payment totaled $937.11, and represented payment in the amount of $312.37 for three (3) months ($937.11 ÷ 3 = $312.37) and represented payment for January, February and March 2011. c. Stinson began receiving regular monthly payments in the amount of $312.37 beginning in April 2011. 26. Stinson received payments from Yeadon Borough for the reimbursement of her insurance benefits provided to her as an employee of Mercy Fitzgerald Hospital. a. Payments made to Stinson on March 18, 2011, were for insurance reimbursements for the entire year of 2010 and for the first three (3) months of 2011. b. Stinson abstained from voting on all motions to approve reimbursements for her insurance benefits other than the last payment made on May 20, 2011, which was approved at the legislative meeting on June 16, 2011. Stinson, 12-015 Page 8 27. Stinson continued to receive “reimbursement” payments on a monthly basis, as a result of Borough Council actions approving the accounts payable lists at the monthly meetings. a. Beginning on April 21, 2011, Yeadon Borough Council initiated the practice of approving separate motions regarding the voting to approve reimbursement of employer-provided insurance benefits, in order to allow the affected Council Member to abstain from voting. 1. Stinson abstained from voting to approve Borough payments issued to herself during/after the April 21, 2011, Yeadon Borough Council meeting. 28. Concerns were raised by citizens of Yeadon Borough regarding the appropriateness of Council Members being reimbursed for employer-provided health insurance …. [Redacted due to confidentiality requirements of the Ethics Act.] 29. [Redacted due to confidentiality requirements of the Ethics Act.] 30. Following the questions being raised regarding Yeadon Borough providing employer health costs reimbursement to its Council Members, Council enacted Resolution No. 2011-09, on July 21, 2011, restricting the value of the reimbursement, which read in part: NOW THEREFORE BE IT RESOLVED , effective for the Calendar year of 2011 and going forward, the Yeadon Borough Council shall restrict the value of the health insurance, accident insurance, and life insurance benefits per official per year to an amount not to exceed the single rate (no children) premium of the health insurance ST RESOLVED THIS 21 DAY OF plan provided to non-union Borough employees. JULY 2011 a. Resolution No. 2011-09 regarding health care costs for Council Members and the Mayor was approved at the regular legislative meeting on July 21, 2011, by a 6-0 vote in which Stinson participated in approving the resolution. 31. Following the enactment of Resolution No. 2011-09, Stinson opted not to be included as part of the Yeadon Borough insurance plan available to officials and employees of the Borough. a. Stinson discontinued collecting the $312.37 monthly “reimbursement” from the Borough following the enactment of Resolution No. 2011-09 on July 21, 2011. 32. [Redacted due to confidentiality requirements of the Ethics Act.] 33. Stinson realized a private pecuniary benefit in her capacity as a Yeadon Borough Council Member, as a result of being reimbursed by Yeadon Borough for insurance benefits that were provided to Stinson through her employer, Mercy Fitzgerald Hospital. a. Stinson opted not to participate in the health insurance plan offered by the Borough. b. Stinson provided an Annual Benefits Enrollment Statement, issued to her by her employer Mercy Fitzgerald Hospital, to Finance Director Tyrone Jordan Stinson, 12-015 Page 9 with the intent of being reimbursed by Yeadon Borough for her employer- provided health insurance costs. The following findings relate to the allegation that Stinson failed to disclose on her Statement of Financial Interests filed for the 2011 calendar year real estate interests, creditors, direct/indirect sources of income, gifts, transportation, lodging and hospitality, financial interests in any legal entity for profit, and business interests transferred to immediate family members. 34. Pursuant to the Statement of Financial Interests filing requirements for public officials and public employees of Section 1104 of the State Ethics Act, Stinson was required to file an accurate and complete Statement of Financial Interests by May st 1 annually, in her capacity as a Yeadon Borough Council Member. 35. Stinson did not complete any of sections eight (8) through thirteen (13) of her Statement of Financial Interests for the 2011 calendar year, and failed to list income in excess of $1,300.00 from her employment with Mercy Fitzgerald Hospital and from Yeadon Borough. III.DISCUSSION: As a Council Member for Yeadon Borough (“Borough”), Delaware County, from January 4, 2010, through the present, Respondent Denise H. Stinson, also referred to hereinafter as “Respondent,” “Respondent Stinson,” and “Stinson,” has been a public official subject to the provisions of the Public Official and Employee Ethics Act (“Ethics Act”), 65 Pa.C.S. § 1101 et seq. The allegations are that Stinson violated Sections 1103(a) and 1105(b) of the Ethics Act when she used the authority of her public position to obtain a private pecuniary benefit for herself and/or members of her immediate family by using her position to receive payment from the Borough for the costs of private health insurance; and when she subsequently participated in actions of Borough Council to approve payments issued to her for private health care insurance costs; and when she failed to disclose on a Statement of Financial Interests (“SFI”) filed for the 2011 calendar year real estate interests, creditors, direct and/or indirect sources of income, gifts, transportation, lodging and hospitality, financial interests in any legal entity for profit, and business interests transferred to immediate family members. Pursuant to Section 1103(a) of the Ethics Act, a public official/public employee is prohibited from engaging in conduct that constitutes a conflict of interest: § 1103. Restricted activities (a)Conflict of interest.— No public official or public employee shall engage in conduct that constitutes a conflict of interest. 65 Pa.C.S. § 1103(a). The term "conflict of interest" is defined in the Ethics Act as follows: § 1102. Definitions "Conflict" or "conflict of interest." Use by a public official or public employee of the authority of his office or employment or any confidential information received through Stinson, 12-015 Page 10 his holding public office or employment for the private pecuniary benefit of himself, a member of his immediate family or a business with which he or a member of his immediate family is associated. The term does not include an action having a de minimis economic impact or which affects to the same degree a class consisting of the general public or a subclass consisting of an industry, occupation or other group which includes the public official or public employee, a member of his immediate family or a business with which he or a member of his immediate family is associated. 65 Pa.C.S. § 1102. Section 1103(a) of the Ethics Act prohibits a public official/public employee from using the authority of public office/employment or confidential information received by holding such a public position for the private pecuniary benefit of the public official/public employee himself, any member of his immediate family, or a business with which he or a member of his immediate family is associated. Section 1105(b) of the Ethics Act and its subsections detail the financial disclosure that a person required to file the SFI form must provide. Section 1105(b)(3) of the Ethics Act requires the filer to disclose on the SFI any direct or indirect interest in any real estate which was sold or leased to or purchased or leased from the Commonwealth, any of its agencies or political subdivisions, or which was the subject of any condemnation proceedings by the Commonwealth or any of its agencies or political subdivisions. Subject to certain statutory exceptions, Section 1105(b)(4) of the Ethics Act requires the filer to disclose on the SFI the name and address of each creditor to whom is owed in excess of $6,500 and the interest rate thereon. Subject to certain statutory exceptions not applicable to this matter, Section 1105(b)(5) of the Ethics Act requires the filer to disclose on the SFI the name and address of any direct or indirect source of income totaling in the aggregate $1,300 or more. Subject to certain statutory exceptions, Section 1105(b)(6) of the Ethics Act requires the filer to disclose on the SFI the name and address of the source and the amount of any gift or gifts valued in the aggregate at $250 or more and the circumstances of each gift. Subject to certain statutory exceptions, Section 1105(b)(7) of the Ethics Act requires the filer to disclose on the SFI the name and address of the source and the amount of any payment for or reimbursement of actual expenses for transportation and lodging or hospitality received in connection with public office or employment where such actual expenses exceed $650 in an aggregate amount per year. Section 1105(b)(9) of the Ethics Act requires the filer to disclose on the SFI any financial interest in any legal entity engaged in business for profit. S ection 1105(b)(10) of the Ethics Act requires the filer to disclose on the SFI any financial interest in a business with which he is or has been associated in the preceding calendar year which has been transferred to a member of his immediate family. The term “financial interest” is defined in the Ethics Act as “[a]ny financial interest in a legal entity engaged in business for profit which comprises more than 5% of the equity of the business or more than 5% of the assets of the economic interest in indebtedness.” 65 Pa.C.S. § 1102. Stinson, 12-015 Page 11 As noted above, the parties have submitted a Consent Agreement and Stipulation of Findings. The parties’ Stipulated Findings are set forth above as the Findings of this Commission. We shall now summarize the relevant facts as contained therein. The Borough is governed by a seven-Member Council and a Mayor. Stinson was elected to Borough Council during a special election held in November 2009, and she has served as a Member of Borough Council from January 4, 2010, through the present. Stinson has served as President of Borough Council from August 2012 until the present. Borough Council Members are compensated $1,800.00 annually for their service and are not required to be in attendance at monthly meetings in order to receive such compensation. With respect to insurance coverage for members of a borough council, the Borough Code authorizes a borough to “make contracts of insurance with any insurance company, association or exchange, authorized to transact business in the Commonwealth, insuring borough employes, or any class or classes of employes, or mayor and council, or their dependents, under a policy or policies of insurance covering life, health, hospitalization, medical and surgical service or accident insurance.” 53 P.S. § 46202(26)(ii). After the Borough Code was amended in 2001 to allow the participation of borough council members in a borough-funded health insurance program, the Borough permitted elected officials to receive/participate in the same insurance benefit program provided to Borough employees. The Borough provides health insurance coverage for its employees through a policy managed by Independence Blue Cross. Participants in the Borough’s insurance plan pay no insurance premium. In or around 2008, Borough Council reviewed the Borough’s health insurance costs and noted that the cost for Council Members’ health insurance was projected to exceed $64,000.00 for fiscal year 2009. As part of a cost-savings attempt, Borough Council directed Interim Borough Manager Paul Janssen (“Janssen”) to prepare a Resolution which limited/capped the costs of benefits provided to Borough Council Members. On December 18, 2008, Borough Council adopted Resolution No. 2008-12, which restricted the cost of Borough-paid health benefits for Borough Council Members and the Mayor to $5,000 per elected official per year. Resolution No. 2008-12 does not authorize elected officials of the Borough to be reimbursed for their private insurance or insurance provided through an employer or other entity, and the Borough never enacted or established any type of policy that authorized elected officials to be reimbursed for their private insurance or insurance provided through an employer or other entity in lieu of enrolling/participating in a Borough-funded health insurance program. Stinson has been employed as a Unit Facilitator for Mercy Fitzgerald Hospital (“Hospital”) for at least the past 33 years. As a Hospital employee, Stinson received as part of her compensation insurance benefits that were provided to her by way of payroll deductions. As of December 2009, the costs of Stinson’s insurance benefits as deducted from her Hospital pay totaled approximately $312.37 per month. After the special election in November 2009 and prior to Stinson taking office, Borough Council Member Delores Jones-Butler (“Jones-Butler”) informed Stinson that as a newly-elected Council Member, she was entitled to receive compensation as delineated in the Borough Code and had the option to participate in the Borough’s health insurance program. Following Stinson’s installment as a Council Member, Jones–Butler informed Stinson that she could either participate in the Borough-funded health insurance plan or be reimbursed by the Borough up to $5,000.00 annually for health insurance expenses. Stinson opted not to participate in the Borough-funded health insurance plan, and she did not seek immediate reimbursement for costs associated with her employer- Stinson, 12-015 Page 12 provided health insurance because she believed that she was not incurring any reimbursable expenses. Stinson had been informed by Janssen that non-out of pocket expenses for health care costs/insurance were not eligible for reimbursement from the Borough. On August 19, 2010, Janssen was removed as the Interim Borough Manager by a majority vote of the Borough Council. Stinson voted in favor of Janssen’s removal. The position of Borough Manager remained vacant until approximately April 2011. Following Janssen’s removal from office, on or around December 31, 2010, Stinson provided a copy of her pay statement and employer-provided benefit information to Borough Finance Director Tyrone Jordan (“Jordan”) in order to secure reimbursement from the Borough for the costs associated with Stinson’s employer-provided health insurance. Reimbursement could not be made by the Borough without Stinson’s pay statements. Stinson sought reimbursement after being advised by Borough Council Member Sandra Thomas that she was getting reimbursement for insurance benefits. Either Jordan or Borough Finance Clerk Sheila Briner initiated reimbursement payments to Stinson following receipt of Stinson’s pay statements. Payments for health insurance reimbursements were placed on accounts payable lists for Borough Council approval at regular legislative meetings of Council. The accounts payable lists represent expenditures not yet paid by the Borough. On March 18, 2011, Stinson received two retroactive reimbursement payments from the Borough, as reimbursement in the amount of $312.37 per month for her employer- provided health insurance costs. The first reimbursement payment totaled $3,748.42 and represented payment for the year 2010. The second reimbursement payment totaled $937.11 and represented payment for January, February and March 2011. Stinson began receiving regular monthly payments in the amount of $312.37 beginning in April 2011. Concerns were raised by Borough citizens regarding the appropriateness of Council Members being reimbursed for employer-provided health insurance, and on July 21, 2011, Stinson participated in a 6-0 Borough Council vote to approve Resolution No. 2011-09, which restricted the yearly value of insurance benefits for Borough officials. Following the enactment of Resolution No. 2011-09, Stinson opted not to be included as part of the Borough insurance plan available to Borough officials and employees, and she discontinued collecting the $312.37 monthly reimbursement payment from the Borough. Stinson abstained from voting on all motions to approve reimbursements for her insurance benefits other than the last payment made to her on May 20, 2011, which was approved at the Borough Council legislative meeting on June 16, 2011. The parties have stipulated that Stinson realized a private pecuniary benefit in her capacity as a Borough Council Member as a result of being reimbursed by the Borough for insurance benefits that were provided to her through her employer. As for Stinson’s SFI for calendar year 2011, the parties have stipulated that Stinson did not complete any of sections eight (8) through thirteen (13) of said SFI and that she failed to list income in excess of $1,300.00 from the Borough and from her employment with the Hospital. Having highlighted the Stipulated Findings and issues before us, we shall now apply the Ethics Act to determine the proper disposition of this case. The parties’ Consent Agreement sets forth a proposed resolution of the allegations as follows: Stinson, 12-015 Page 13 3. The Investigative Division will recommend the following in relation to the above allegations: a. That a violation of Section 1103(a) of the Public Official and Employee Ethics Act, 65 Pa.C.S. § 1103(a) occurred in relation to Stinson’s receipt of payment from the Borough for the costs of private health insurance; and when she subsequently participated in actions of Council to approve payments issued to her for private health care insurance costs. b. That a violation of Section 1105(b) [of the Ethics Act] occurred when Stinson failed to disclose on her 2011 calendar year Statement of Financial Interests, her real estate interests, creditors, direct and/or indirect sources of income, gifts, transportation, lodging and hospitality, financial interests in any legal entity for profit and business interests transferred to immediate family members. 4. Stinson agrees to make payment in the amount of $1,556.16 in settlement of this matter payable to the Yeadon Borough and forwarded to the Pennsylvania State Ethics Commission within thirty (30) days of the issuance of the final adjudication in this matter. 5. Stinson agrees to file a complete and accurate Statement of Financial Interests with Yeadon Borough through the Pennsylvania State Ethics Commission, for the 2011 calendar year within thirty (30) days of the issuance of the final adjudication in this matter. 6. Stinson agrees to not accept any reimbursement, compensation or other payment from Yeadon Borough representing a full or partial reimbursement of the amount paid in settlement of this matter. 7. The Investigative Division will recommend that the State Ethics Commission take no further action in this matter; and make no specific recommendations to any law enforcement or other authority to take action in this matter. Such, however, does not prohibit the Commission from initiating appropriate enforcement actions in the event of Respondent’s failure to comply with this agreement or the Commission’s order or cooperating with any other authority who may so choose to review this matter further. Consent Agreement, at 1-2. In considering the Consent Agreement of the parties, we accept the recommendation of the parties for a finding that a violation of Section 1103(a) of Ethics Act occurred in relation to Stinson’s receipt of payment from the Borough for the costs of private health insurance; and when she subsequently participated in actions of Council to approve payments issued to her for private health care insurance costs. Stinson, 12-015 Page 14 But for being a Borough Council Member, Stinson would not have been in a position to provide a copy of her pay statement and employer-provided benefit information to Borough Finance Director Jordan in order to secure reimbursement from the Borough for the costs associated with Stinson’s employer-provided health insurance. Stinson used the authority of her public position as a Borough Council Member when she voted on the motion to approve reimbursement for her insurance benefits at the Borough Council legislative meeting on June 16, 2011. As detailed in Fact Findings 25 and 33, Stinson realized a private pecuniary benefit as a result of receiving two retroactive reimbursement payments and regular monthly payments from the Borough for her employer-provided health insurance costs. Based upon the Stipulated Findings and the Consent Agreement, we hold that a violation of Section 1103(a) of the Ethics Act occurred in relation to Stinson’s receipt of payment from the Borough for the costs of private health insurance; and when she subsequently participated in actions of Council to approve payments issued to her for private health care insurance costs. As for the allegations regarding Stinson’s SFI for the 2011 calendar year, we hold that Stinson violated Section 1105(b) of the Ethics Act, 65 Pa.C.S. § 1105(b), when she failed to disclose on her 2011 calendar year SFI her real estate interests, creditors, direct and/or indirect sources of income, gifts, transportation, lodging and hospitality, financial interests in any legal entity for profit and business interests transferred to immediate family members. As part of the Consent Agreement, Stinson has agreed to make payment in the amount of $1,556.16 payable to Yeadon Borough and forwarded to this Commission within thirty (30) days of the issuance of the final adjudication in this matter. Stinson has agreed to not accept any reimbursement, compensation or other payment from the Borough representing a full or partial reimbursement of the amount paid in settlement of this matter. Stinson has further agreed to file a complete and accurate SFI for the 2011 calendar year with the Borough, through this Commission, within thirty (30) days of the issuance of the final adjudication in this matter. We determine that the Consent Agreement submitted by the parties sets forth a proper disposition for this case, based upon our review as reflected in the above analysis and the totality of the facts and circumstances. Accordingly, per the Consent Agreement of the parties, Stinson is directed to make payment in the amount of $1,556.16 payable to Yeadon Borough and forwarded to this th Commission by no later than the thirtieth (30) day after the mailing date of this adjudication and Order. Per the Consent Agreement of the parties, Stinson is directed to not accept any reimbursement, compensation or other payment from the Borough representing a full or partial reimbursement of the amount paid in settlement of this matter. Stinson is directed to file a complete and accurate SFI for the 2011 calendar year th with the Borough, through this Commission, by no later than the thirtieth (30) day after the mailing date of this adjudication and Order. Compliance with the foregoing will result in the closing of this case with no further action by this Commission. Noncompliance will result in the institution of an order enforcement action. Stinson, 12-015 Page 15 IV.CONCLUSIONS OF LAW: 1. As a Council Member for Yeadon Borough (“Borough”), Delaware County, from January 4, 2010, through the present, Respondent Denise H. Stinson (“Stinson”) has been a public official subject to the provisions of the Public Official and Employee Ethics Act (“Ethics Act”), 65 Pa.C.S. § 1101 et seq. 2. Stinson violated Section 1103(a) of the Ethics Act, 65 Pa.C.S. § 1103(a), in relation to her receipt of payment from the Borough for the costs of private health insurance; and when she subsequently participated in actions of Council to approve payments issued to her for private health care insurance costs. 3. Stinson violated Section 1105(b) of the Ethics Act, 65 Pa.C.S. § 1105(b), when she failed to disclose on her 2011 calendar year Statement of Financial Interests her real estate interests, creditors, direct and/or indirect sources of income, gifts, transportation, lodging and hospitality, financial interests in any legal entity for profit and business interests transferred to immediate family members. In Re: Denise H. Stinson, : File Docket: 12-015 Respondent : Date Decided: 7/9/13 : Date Mailed: 7/12/13 ORDER NO. 1618 1. As a Council Member for Yeadon Borough (“Borough”), Delaware County, Denise H. Stinson (“Stinson”) violated Section 1103(a) of the Public Official and Employee Ethics Act (“Ethics Act”), 65 Pa.C.S. § 1103(a), in relation to her receipt of payment from the Borough for the costs of private health insurance; and when she subsequently participated in actions of Council to approve payments issued to her for private health care insurance costs. 2. Stinson violated Section 1105(b) of the Ethics Act, 65 Pa.C.S. § 1105(b), when she failed to disclose on her 2011 calendar year Statement of Financial Interests (“SFI”) her real estate interests, creditors, direct and/or indirect sources of income, gifts, transportation, lodging and hospitality, financial interests in any legal entity for profit and business interests transferred to immediate family members. 3. Per the Consent Agreement of the parties, Stinson is directed to make payment in the amount of $1,556.16 payable to Yeadon Borough and forwarded to the th Pennsylvania State Ethics Commission by no later than the thirtieth (30) day after the mailing date of this Order. 4. Per the Consent Agreement of the parties, Stinson is directed to not accept any reimbursement, compensation or other payment from the Borough representing a full or partial reimbursement of the amount paid in settlement of this matter. 5. Stinson is directed to file a complete and accurate SFI for the 2011 calendar year with the Borough, through the Pennsylvania State Ethics Commission, by no later th than the thirtieth (30) day after the mailing date of this Order. 6. Compliance with paragraphs 3, 4, and 5 of this Order will result in the closing of this case with no further action by this Commission. a. Non-compliance will result in the institution of an order enforcement action. BY THE COMMISSION, ___________________________ John J. Bolger, Chair