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HomeMy WebLinkAbout614-R SummersMr. 2avid Summers 9C5 Park Avenue (Lynwood) Belle Vernon, PA 15012 Re: 86- 120 -r; Dear Mr. Summers: Zirek STATE ETHICS COMMISSION 3C8 FINANCE BUILDING HARRISBURG, PENNSYLVANIA 17120 ORDER OF THE COMMISSION Order No. 614 -R Date Decided: June 10, 1988 -'ate Mailed: June 24, 1988 The Ethics Commission has reviewed the allegation(s) that you have violated the Ethics Act, Act 1978 -170. On February 18, 1988, a hearing on the matter was conducted and relevant evidence and testimony was presented. The Commission has now completed its investigation. The individual allegations, conclusions, and findings on which those conclusions are based are as follows: Z. Allegation: That you, a Washington Township Supervisor - Roadmaster, violated Section 3(a) of the Ethics Act which prohibits a public employee or public official's use of office or confidential information gained through that office to obtain financial gain by receiving prescription drugs, health insurance and a life insurance policy at the township's expense. A. Findings: 1. You have served as a Washington Township Supervisor for at least the past twenty years and, as such, you are subject to the provisions of the State Ethics Act. 2. You have also served as township roadmaster. a. Your compensation as roadmaster was set by the township auditors. b. You report to work every morning, review the work with the employees, visit main jobs, report of the progress in the various jobs on that day and plan for the following day. 3. Records of the Washington Township Auditors disclosed the following regarding compensation set for township supervisors: Mr. David Summers Page 2 a. January 4, 1979: David Summers, Roadmaster, $300 /month, plus (10) road inspections. In the event of layoff from construction, Summers will nullify the $300 /month and work at a $5.00 hourly rate, for (8) hours a day. b. January 7, 1980: Supervisors---- -$5.30 per hour while acting in the capacity of a Supervisor and a written explanation of work performed to be submitted before payment is made to the Secretary. Ruad :_aster - $350.00 Per Month. Superintendent -- $300.00 Per Month. of Police 'ec /Treas. Compensation to be 4% on all monie :, paid by him. c. a nua ry 5, 1981: Supervisors $5.80 per hour while acting in the capacity of a Supervisor and a written explanation of work performed to be submitted before payment is made to the Secretary. Roadmaster Superintendent -- $300.00 Per Month. of Police Sec /Treas. d. January 4, 1982: Supervi sors No insurance benefits set by the auditors. $350.00 per month plus road inspections as code permits. Compensation to be 4% on all expenditures paid by him. $6.30 per hour while- acting in the capacity of a Supervisor and a written explanation of work performed to be submitted before payment is made the Secretary. Roadmaster $370.00 Per month plus road inspections as code permits. Mr. David Surn rs Page 3 Superintendent -- $350.00 Per Month. of Police Sec /Treas. Compensation to be 4% on all (Ypenditures. e. January 3, 1983: Supervisors $6.30 per hour while acting in the capacity of 3 Supervisor and a written explanation of work performed to be submitted befor3 payment is made to the Secretary. Roadmaster $375.00 Per month plus road inspections as code permi ts. �Raperintendent -- $350.00 Per Month. of Police Sec/Treas. - -6 - -- Compensation to be 4% on all expenditures- -paid him. • January 2, 1984: pervi sons Rnad aster. Superintendent -- $335.00 per month. of Police :,ec /Tres. Compensation to be 4% on all expenditures p.=id by him. g. January 8, 1985: $6.30 per hour while acting in the capacit;, "n a Supervisor and a written explanation of wos' performed to be submitted before payment i Ir. le 7 1:o the Secretary. ;500.00 per month plus road inspections as permi ts. Supervisors $7070 per hour while acting in the capacity of a Supervisor and a written explanation of work performed to be submitted before payment is made to she Secretary. kcadmastesr $500.00 per month plus road inspections as code permits. P. . Daui J Su:.;ners N:e 4 Superintendent -- $335.00 per month,. or Roads !sac /Treas. Compensation to ',e 4% on all expenditures paid by him. h. _?:.nary 7, 1986: Supervi sors $7.00 per hour while acting tn the capacity of a Supervisor and a written explanation of work performed to be submitted before payment is made to the Secretary. Roads ster $500.00 per month plus road inspections a.: code permits. S i "i ntendent -- $335.00 per month ✓.� - ads SF /Treas. Compensation to be 4% on all ex. - :nditures- -paid by him. i. January 6, 1987: 'Supervisors $7.00 per hour while acting in the capacity of a Supervisor and a written explanation of work performed to be submitted before payment is made to the Secretary. oAmaster $500.00 per month plus road inspections as code permits. Superintendent -- $335.00 per month. of Roads Sec /Treas. Compensation to be $14,750.00 annually. Sec /Treas. Bond is $125,000.00 and the Assistant Treasurers bond is $12,000.00. 4. Supervisor Ernest Reppert, who also serves township tecretary /treasurer, advised that each year a letter was prepared by the supervisors with compensation requests and sent to the auditors. The auditors would sign the letter indicating their approval and return the letter to the supervi sors. Mr. David Suiwnrs Page 5 Reppert btat!:1 that i surarice coverage was never part of these 1 et;t s approved by the auditor. b, Your compensation as roadmasrcer ryas included in these letters. o.. You participated in the preparation of this letter. Recorc;s of the Provident Indemnity Life Insurance disclosed the follcwvir.; :—larding payments made on your behalf by the township for life insurar._,_ '5,000), basic medical and major medical benefits, prescription plat: acid accidental dealth and dismemberment ($6,000). a. Yc a were insured from October, 1976 through September, 1982; under Group Plan Number EG- 0592 - 0272 -1. Your spouse was ilso included in t ii s coverage. Your insured number was ',0006, b. 1976: $ 229.05 1977: $ 970.52 (3 months) October to December d. 1978: $ 986.18 e. 1979: $ 991.92 f. 1980: $1,543.82 g. 1961: $1.602.72 h. 198L: $1,950.12 (9 months) January to September 1 . 1976 to 1982 Total - $8,274.33 6. R .)t :ords of the Columbia Life Insurance Company disclosed the following information regarding payments made on your behalf by the township for various forms of insurance coverage: a. You are insured by the following policy number and coverage;.. AKME0931 (Paid prescription plus dental) AKSM4629 (Medical coverage) IKSM4629 (Plan F. life insurance only} b, The effective date of these coverages was listed as March 25, 1982,, Coverage included your spouse and dependents. Mr. David Lun;..iers C c. pr4_mium Payments were made as foll•ms: Year 1982 1983 1984 19E5 1986 1987 T o May) rol i cy Number AKME093I AKSM4629 $ 652.54 $ 286.16 $2,090.05 $ 53.30 $ 318.61 $ 636.01 • $ 354.96 $1,182.78 $ 354.96 $1,324.80 $ 147.90 $ 552.00 Lt SM4629 $ 108.85 $1,410.75 $ 186.80 $ 231.30 $ 276.00 $ 115.00 Total e. June 14, 1984 - Revised Certificate of Insurance. Total $ 1,047.55 $ 3,554.10 $ 1,141.22 $ 1,769.04 $ 1,955.76 $ 814.90 $10,282.57 d. ClaiLs were paid for you and your family from 1982 to 1984 totalling $586.93. These payments were mainly for prescription. Columbia Life insurance records also disclosed the following: a. August 14, 1982 - Print -out listing employee, dependents co‘mrage costs: Summers, Spouse B Plan, Health - $662.6 Prescription $142.20, Dental $576.34, ! •; fe $129.60. Total annual premium $2,809,20. b. September 7, 1982 - Memo to Agent Warren Arleth from Rosemary Huber, Group Department advising to have you complete form 1060a for increase in medical coverages. c. March 26, 1984 - Memo from David Leich, Life Department Manager, to Warren Arleth advising to have you complete PG -5 application. (for up grade of life insurance). d. June 8, 1984 - Columbia Invoice reflecting balance due of $323.80 to upgrade coverages fr you to policy number LKSM4629. (life insurance) David Summers :vge . g. July 25, 1984 Leti :er from David Leich to . Reppert, Tc',nship Secretary /Treasurer advi 11g t; ,t ',1'4,03 was needed for your P.C.S. prescription pE emiums. As soon as that amount was ra=.eived ~oars would be sent to you to submit Faso Au t 3, 1984 - Memo from JoAnn Lindner, Group Department t Washington County Re: David Summers, AKME:e 1 enclosing revised certificate and noting tila'. P.C.S. paid prescription had been added bat' tr his policy. Enclosed were P.C.S. Drug Cla Forms for you to complete. W111iaTa J. O'Keefe, Special Investigator for the State Ethics Commission, •" -s 7j11ows: a. That ':e interviewed Ernest Reppert who said that to his knowledge, the auditors had not approved insurance for supervisors. b. Mr. Winn was also interviewed who stated that since he ,'ecei ved .surance as an auditor, he took it for granted that auditors had approved the insurance. c, In your interview, you stated that to your knowledge, the auditors .�d ro; approved the insurance. 9. Selma S. Russell, Auditor, provided the following testimony: s.. In January, 1986, she began as an auditor to do the 1985 books. b. When Ernest Reppert told her that she had insurance, she asked if it was legal and he (Reppert) said yes. c. SLe called the State Ethics Commission and was advised that neither auditors nor supervisors could get insurance benefits. J. Th t trhen she received prior rulings from the State Ethics Commission on insurance benefits, she gave a copy of those rulings to her fellow au'l tor, Robert L. Campbell. e. I;n a public meeting, when someone questioned benefits for the auditors, she stated that she replied that benefits for both auditor:, and supervisors were not legal. f. That Mr. Campbell wanted to set up a meeting with the supervisors regarding benefits but the supervisors did not get back to him. ..I D-..yrdei Summers 3 g. As auditor, she acted upon and approved the comp,tnsati on for th:: supervisors in 1.986 and 1987 as well as approving the books. h. he stated that she did not approve insurance benefit i F,r the 1986 year, she didn't even raise th -, :11a tter of insurance benefits because it was in the hands of the State Ethics Commission j. =pie did not file any exceptions in the auditors report that insurance was improper. 10, R . aert L. Campbell, Auditor, gave the following testimony: That he was appointed an auditor in 1986. b. although he wanted to be an auditor for the insurance, he did not use _he coverage because he found it was illegal. c-. That he took no action to allow or disallow insurance for the supervisors because it was in the hands of the State Ethics Commi ssion. d. He tried to set up a meeting with the superviscrs as to the legality of insurance but they decided not to meet with him. e.. ;larch of 1986, he took the State Ethics Commission prior ru i ngs ,.� insurance to your house, gave and discussed the documents wi `h you. A.; to the letter from the supervisors regarding compensation, there was no mention of insurance benefits. y. There were no exceptions by the new auditors the first time they did the books because they did not know about insurance benefits. h. That there was no written objection or exception and no approvals or denials by the auditors in the 1986 and 1987 auditors' report. i. he did not approve health care benefits for the supervisors. 11. You, r.. vid Summers, Supervisor and Roadrraster, provided the f.HHlowing: a. The following information was provided to a State Ethics Commission i nvestigator: (1) You have served as a township supervisor for (25) years. Mr. David Summer Page -) (2) You also seive ac township roadmaster and receive a monthly salary. You are on call 24 hours a day, but you nave never worked full -time hours, such as (35) or (40) hours each week. Neither of the other supervisors fill out a time sheet to reflect hours or days worked. (7) Your duties generally entail ping to the township building in the morning and advising the road crew of the days activities, Supervisor Winn also help out. You and Winn come back and check later in the day. You come in when its snowing on an as needed basis. ('; The supervisors have had insurance coverages with Provident Indemnity Insurance and later with Columbia Insurance Company. You have been a memislr of either plan since at least 1979. (5) You curren.ly receive life insurance and interim insurance for hospitalization that is not paid by Medicare. Prior to reachirg age 65, you had full hospitalization. (6) To the best of your knowledge, the auditors have never approved the insurance for supervisors but they never disapproved it either until the present. b, The fo ' ;owing testimony was given by you at the hearing: (1) That you were a roadmaster for 25 years and received the insurance. (2) That the auditors got insurance and they did not question the coverr4ge as to the supervisors. (3) There was no mention of insurance but you believe that the auditors would have approved it if they were asked to. (4) Many township roadmasters receive these benefits. (5) You admit that you know payments were made for insurance on your behalf. (6) You stated that you did not ask the auditors for approval but approved the payment yourself as supervisor. (7) In terms of restitution, you stated that you only receive social security of $575 per month plus a pension of $475 per month but your home is paid for. David Summer Vincent G. Winn, Supervisor and Road ` 'uper: ntendent, p uvi ded the of1')w;ng. (a, The following information was provided to a State : thi cs Commission investigator. He served as a township auditor for over twenty years. ;, He was elected supervisor in 1986 and subsequently resigned as (auditor. He also is the appointed road superintendent. (3) The auditors did not know it was their job to approve or disapprove insurance coverage for the supervisors. (4) While serving as auditor he was permitted to participate in the prescription and life insurance plans. After burg elected supervisor he was able to obtain the hospitalizatio: coverage. (5) He and you get the road crews goi check -up on them during the day. with the crews when snow plowing have enough men for the trucks. ng in the rrirni ng and periodically You have, on occasSiooc, gone out needs to bps done, but they usually The following testimony was given by Mr. Winn: (1) That he received insurance both as auditor and Supervisor and didn't question it when he was in either position. (2, The auditors never questioned insurance coverage. (3) When he was an auditor, he approved what the ''apervi sons requested and did think health care had to be approved. (4) He did not respond to the auditors because he didn't have to. (5) He stated that he did not tell the auditors they were entitled but merely that the auditors got coverage in the past. 13. Ernest Reppert, Supervisor and Secretary, provided the following: (a) The following information was provided to a State Ethics Commission i rvestigator: (1) Hn has had the insurance since taking office in 1984. Mr. David Summers Page 1.1 (2) In past years, all ci= the auditors, the schoo7 crossing guard and part -time custocian, received life and prescription insurance. The auditors had to know the supervisors wei P getting the insurance. The auditors never did anything previous years. (3) When the auditors questioned the insurance in early 1986, 'le contacted the solicitor who advised to continue the practice as is, and that the whole issue is still up in the air. (4) He even put Robert Campbell on as an auditor so that Campbell could receive the coverage. Campbell was ill and had no 1 rsurance. 15) Y xu and Winn serve as roadmaster and road superintendent. These are 24 hour on call positions. (6) His position is full -time. He is on call 24 hours a day and that he works 50 hours a week. b) The following testimony was given Mr. Reppert: (1) T`e auditors did not question insurance coverage and they, the ruditors, had the benefits. (2) He did not receive written notice that the coverge was improper. (3) y'rior to 1988, he never submitted insurance coverage for auditor approval. (4) He did not meet with the auditors because he felt they were nitpicking and besides, the books were closed. i4. William Trenk, former Auditor, gave the following testimony. a. He served as auditor between 1962 and 1973 and from 1975 through 1979. b. He was aware of insurance coverage for auditors and supervisors but was not aware that auditor approval was needed. c. The supervisors told him that they were entitled to i nsuraace )enefits. d. He did not authorize insurance payments. Mr. D ?vid Su;lame s Page '? 15. Mr,. John Kasuda, a former auditor in Washington Township for thl period between 1979 and 1984, was interviewed by State Ethics Commission Investigator William J. O'Keefe in the presence of Attorney Joseph Rygiel, counsel for tie respondents. Mr. Kasuda stated: that he imagined that the supervisors were getting insurance benefits; that when he was an auditor, he got prescription insurance and lastly that he did not recall ever being asked to approve the insurance for supervisors but he would have given such approval if he were asked by the supervisors for it. 15. Solicitor Joseph Rygiel, is of the view that once the auditors appr ^ve Vie salaries for the supervisors, the supervisors became employees and could be afforded the insurance coverage equal to all other employees in the township as well as for the auditors. 17. House Bill No. 1577 of the 1987 Session was passed by the General Asp `mbly of the Commonwealth of .Pennsylvania and signed into law by the Go'ernor on March 10, 1988. The foregoing Act provides, in part, amnesty to non- employee supervisors who received various township paid pension plans or group life, health, hospitalization, medical service and accident insurance plans, as well as to employee supervisors who received such pension benefits without auditor approval, but the amnesty covers the period only betweec; Jaruary 1, 1959 and March 31, 1985. B. Discussion: As a township supervisor, you are a public official es that ', Ym is defined in the State Ethics Act. 65 P.S. §402; Sowers, 80 -0K, As ,uch, you are subject to the provisions of the Ethics Act and the restrictions 'herein are applicable to you. Generally, the State Ethics Act provides as follows: Section 3. Restricted activities. (a) No public official or public employee shall use his public office or any confidential information received through his holding public office to obtain financial gain other than compensation provided by law for himself, a member of his immediate family, or a business with which he s associated. 65 P.S. 403(a). Within the above provision of law, this Commission has previously determined that a township supervisor may not receive at the township's expense, health, hospitalization, medical and life insurance benefits when such supervisor acts only in the capacity of a supervisor. Krane, 84 -001; Cowie, 84 -010. Additionally, even if such a supervisor is employed by the cownship as a superintendent, secretary /treasurer, roadmaster or laborer in accordance with the Second Class Township Code, such benefits are considered compensation and must, therefore, be fixed as such by the township board of auditors. See Synoski v. Hazle Township, 93 Pa. Comm. 168, 500 A.2d 1282, Mr. David Summers P„ge 1' (19); In re: Appeal of tf f:uditcrs Repi,r t: o^ ',uncy Creek Th—mnshik., Pa. Commw. Ct. , 520 A.2d 12A , 1987) Hunt, No., 348 -R, The forepoing drirc:iple was recently reaffirmed by Pennsyl »»ania Commonwealth Court. is Yuc %bet v. State Ethics Commission, Pa. Commw. , A.2d (1987`: filed at 834 C.D. 1986 on September 18, 1987. In the cited case, the Court h' id inter alia that a township supervisor violated Section 3(a) of the Ethic:~ At ^' en ha received a salary for the position of secretary /treasurer which Lad lot teen set by the auditors. The Court, in affirming the Order 'f tf,e Eth , ..s Commission, which required a restitution of the financial gair, aotfd on age 5 of its Opinion: Section 7 of the Ethics Act instructs the Commission to investigate situations where there is a reasonable belief that financial conflict may exist, and if conflict is found, to require the offender to remove himself from the conflict without gain. Any 'ienefits received other than as provided for above, would constiti:i,e :'inancial gain obtained in violation of the State Ethics Act. See, - C'±tcheon v. State Ethics Commission, 77 Pa. Commw. 529, 466 A.2d 28', 7. S3': Conrad v. Exeter Township, 27 D & C 3d 253, (1983). These principles , t 7.-.w are now well settled and constitute the law under which this situation must reviewed. See In Re: Report of Audit of South Union Township, 47 P ?. Comm, :., 407 A.2d 906, (1979). n the instant situation, while you were an appointed secretary / treasurer :nd, therefore, eligible to receive the in question benefits, there would have c 1e the requisite approval by the township board of auditors for this to by , -,Lasidered part of your authorized compensation. See McCutcheon v. Stag thics Commission, supra. The facts in this case establish that the auditors did not give the required approval. The testimony of Auditors Selma Russell, Robert L. Campbell and former Auditor William Trenk establish that there was no auditor approval for these benefits. This is also corroborated by the statement of John Kasuda. Not only do the facts establish that the auditors never approved insurance coverage for supervisors, they also indicate that you had knowledge both of this Commission's decisions on insurance coverage which you ignored. Lastly, you and the other supervisors failed to attend a meeting called by tac,: auditors regarding health insurance coverage. You raise the legal issue that if the auditors did not make an exception i their audit or if they did not disapprove the insurance benefit, then they :u -t be considered as having approved the benefits. The foregoing argument ! been addressed and rejected by the courts. See Hendricks v. East Rockhill Township, 1 D & C 3rd 763 (1977): Mr-. David Su..:iv rs ?age .4 The [ fac:r, that the auditors never affirmatively bjected to the purpose of the pension plan is not tantamount to the affirmative action of the auditors in fixing the compensation for the supervisors and roadmasters additionally to the compensation already fixed at $5 and later $6 per hour. Therefore, we can onij c °include that the supervisors exceeded their authori':y 1.f :::opting and purchasing a pension and annuity plan for Heir own benefit as additional compensation for their 'rvices as either supervisors or as s pervi sor- roadmasters. See Commonwealth v. Hanzlick, aupra. Id. at. 771, 771. Similarly, Commonwealth Court in McCutcheon, supra specifically noted tat h:: auditors must take affirmative action in order for working 7 to receive such benefits: The undoubted power of the supervisors under Section 702 tk. enter into insurance contracts for the township " Insuring its employees ... or any clas3 or classes `;.2reof," is not sufficient to legitimatize supervisors' acions in purchasing these policies for- themselves. in he absence of affirmative action by the township auditors under Section 515. Id. at 538. Since b:,th the testimony of the three auditors and supervisors in this c:se reflect that there was no affirmative approval of insurance benefits by t e auditors for the supervisors, the requisite "affi r :.;alive action" was 'iac<ing and hence, you, as a supervitor were not entitled to the, : benefits. 'ditionally, you argue that the Pennsylvania Insurance Code expressly "U',:huilzes coverage for elected officials as a class for whom health care insurance may be provided. This precise argument was made and rejectrd by the tour' in Exeter Townshia, supra. Further, it has been settled by the courts that insurance benefits are a form of compensation. See Edinger v. Upper Makefield Township, 25 D & C 3rd 512 (1983). Finally, a specific statutory exclusion of health care premiums under the IRC has no relevance in determining whether such benefits are financial gain under the Ethics Act. Further, Commonwealth Court has determined in McCutcheon, supra that such benefits are compensation. It also should be noted that even if these benefits had been received in good faith, such would not be controlling. Good faith receipt of suc;i benefits, even when based upon a solicitor's advice, will not alleviate the ir. D ;kvi d 15 necessity of a publ all - lei reimbursing his governmental body for the ;aipt of a + inancial gain for wh he was not entitled. See Alle hen - oufity ■v. C:rier., 179 Pa. 639, 36 A. 353, (1397); McCutcheon v. State Ethic ' ,mdission, supra; Kestler Appeal 66 Pa. Commw. 1, 444 A.2d 761, (1982). As result, this Commission believes that you must reimburse the - township for t %is financial gain. The State Ethics Act provides as follows: ction 9. Penalties. (a) Any person who violates the provisions of Section 0(a) end E:b1 is guilty of a felony and shall be fined not more than $10,000 or imprisoned for not more than five rears, or be both fined and imprisoned. 65 P.S. 409(a). (c) Any person who obtains financial gain from violating any provision of this act, in addition to any other penalty provided by law, shall pay into the State Treasury a sum of money equal to three times the financial gain resulting from such violation. 65 P.S. 409(c). In addition to the above, the State Ethics Act provides that the Commission may forward the results of any investigation to the appropria':e prosecuting authority unless the alleged offender removes himself from the conflict of interest by divesting himself of any financial gain receive , in violation of the State Ethics Act. 65 P.S. §407 9(iii). See also McCutcheon v. Stat, Eth :s Commission, supra, the Commission may order restitution of financial gains received in violation of the law. The last matter which must be addressed by this Commission concerns House Bill 1577 of 1987 which was signed into law on March 30, 1988 as At 1.7. 1938. Although Section C of Act 41 addresses the questions of amnesty i lsuran�.e benefits that were received by non - employee supervi sors and here does not address the question of insurnce benefits that were received y employee supervisors who did not get auditor approval, it is noted that Section 2 of the Act provides for a blanket amnesty to "elected officials, except township supervisors who are provided for in Section 515, [Section C] and appointed township officials who are not employees of the township." Since working employee supervisors are elected officials and since this catego, 3 of supervisors was not provided for in Section 515, Section 2 is then applicable which provides: j'Ip Da- id d Si .2 i s Je °.6 Any such insurance coverage contract entt eoc: into by township between January 1, 1969, and March 31, 1 ?86, thu ": includes or provides coverage for elected officials, ex °ept A s provided in section 515, or appointed townsh of who are not employes of the township, sham not void or unlawful solely because such inclusion of such os als was subsequently found to be without l ^W u :thorny, No penalty, assessment, surcharge, for: eiture disciplinary action of any kind nay occur as a ' esult of pai':icipation by such officials." `ftrefors, under the above provision of law, the i ns ur Ince benefit:; between Ja nau ry 1, 1959 and March 31, 1985 would not violate . 3; ) of the Ethics Act but the receipt of said insurance befits fter 1ar•rh :,1, 1985 would transgress Section 3(a‘. In this case, you eceivir a f .`nancial gain of $4,097.44 for the period of April 1, 19V forwa r The foregoing amount must be returned to your governmental body, Wa :hi ngtnn Township. C. CInclusion a. Order: 1. As a Township Supervisor in Washington Township, you are a "public fficial" and, as such, are subject to the provisions of t6,e Ethics +ct ". You did not violate Section 3(a) of the Ethics Act when you received various insurance benefits for the period up to March 31, 1985 since House Bill 1577 of 1988, which was signed into law on March 10, 1988, provides amnesty as to the receipt of those benefits. 3 . 'lot.: violated Section 3(a) of the Ethics Act when you received a J a i n through public office consisting of prescription drugs, health insurance and a life insurance policy at the township's expense, which gain is not compensation provided for by law in that such benefits had not been fixed and approved by the township auditors as part of your lawful and authorized compensation for the period April 1, 1985 forward. 4. The financial gain which you received and which was not part of the compensation provided for by law amounts to $4,097.44. 5. You are hereby ordered to remit to the State Ethics Commission, within thirty (30) days of the date of this order, the amount of $4,097.44, made payable to Washington Township as restitution for the financial gain that you received. 6. Failure to comply with the provisions of this order will result in a referral of this matter to the appropriate law enforcement authority for further civil or criminal proceedings. Mr. David `;:ammev..; P• ge 11 Our i r s in this case will rerr i n coLf idential in accord. nce wit; >ecr.ion 8(a) of the E , ics i.ct, 65 f .S. 408(a). However, this Order final a c' ail' be made available '.s a public document 5 bu si 1,ess da "s 3 iter service ( fin 1 a:; mailing). illy person who violates the confidentiality of a Commission p; ;r;eedi n is .uilty of a misdemeanor and shall be fined not more than $1,000 nr i!anr-i sole i for rot more than one year or both, see 65 P.S 409(e). (h�. ,. onf identia:'ty provision does not restrict respondents consultation with ega1 c■'Jnera By the Commission, Joseph W. Marshall, I1I Chai