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In Re: Barbara Raymond,
Respondent
STATE ETHICS COMMISSION
FINANCE BUILDING
613 NORTH STREET, ROOM 309
HARRISBURG, PA 17120-0400
File Docket:
Order No.
Date Decided:
Date Mailed:
FACSIMILE: 717-787-0806
WEBSITE: www.ethhics.pa.gov
22-0032-C
1840
9/ 10/24
9/13/24
Before: Michael A. Schwartz, Chair
Paul E. Parsells
David L. Reddecliff
Thomas E. Leipold
This is a final adjudication of the State Ethics Commissions
Procedurally, the Investigative Division of the State Ethics Commission conducted an
investigation regarding possible violations) of the Public Official and Employee Ethics Act
("Ethics Act"), 65 Pa.C.S. § 1101 ct a ., by the above -named Respondent. At the commencement
of its investigation, the Investigative Division served upon Respondent written notice of the
specific allegations. 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. ALLEGATION:
That Barbara L. Raymond, a public employee in her capacity as the Director of the Bureau
of Veterans Homes of the Pennsylvania Department of Military and Veterans Affairs, violated
Section 1103(a) of the Ethics Act when she used the authority of her public position for a private
pecuniary benefit by utilizing Commonwealth -related travel to receive reward/benefit points from
American Airlines Advantage, Hilton Honors, Intercontinental Hotels Group Rewards Club,
Marriot International/Marriot Bonvoy, and the Radisson Hotel Group/Club Carlson, which were
not used for Commonwealth -related travel.
II. FINDINGS:
1, Barbara L, Raymond ("Raymond") has been employed by the Pennsylvania Department of
Military and Veterans Affairs ("DMVA") as the Director of the Bureau of Veterans Homes
from approximately July 2, 2021, through the present,
` Commissioners Robert P. Caruso and Emilia McKee Vassallo recused themselves ftonn this matter and did not
participate in the deliberations involving this case.
Raymond, 22-0032-C
Page 2
2.
3.
a. Raymond has been employed by DMVA since approximately March 31, 2008, and
she has held various employment positions throughout her tenure with DMVA as
follows:
Quality Assurance Risk Management Coordinator
Administrative Officer 5
Veterans Extended Care Facility Commandant
Bureau of Veterans Homes Director
March 31, 2008 — July 10, 2009
July 11, 2009 — February 4, 2011
February 5, 2011 —July 1, 2021
July 2, 2021 —Present
Raymond's responsibilities as Director of the Bureau of Veterans Homes include the
administration and direction of the Veterans Homes as well as the following:
a. Serving as the principal advisor to the Deputy Adjutant General of Veterans Affairs
and the Adjutant General in matters concerning the provision of care to veterans.
b. Supervising the preparation and control of budget activities; formulating rules,
regulations, and policies; overseeing admission procedures; and evaluating
program implementation and administration.
C. Acting as a liaison with the U.S. Department of Veterans Affairs and other federal
and state agencies.
d. Serving as the principal advisor to the Adjutant General and other high level agency
decision makers.
e. Supervising the professional, technical, and clerical staff.
As Director of the Bureau of Veterans Homes, Raymond oversees the Division of Clinical
Services and the Veterans Homes for DMVA.
a. DMVA has an established chain of command regarding its operations as follows:
1. Adjutant General.
2. Executive Deputy Secretary,
3. Deputy Adjutant General of Veterans Affairs.
4. Executive Director of Long Term Care.
5. Bureau of Veterans Homes Director.
4. DMVA has six Veterans Homes throughout the Commonwealth, all of which are run by
an onsite Commandant and Adjutant Commandant.
Raymond, 22-0032-C
Page 3
a. The Veterans Homes are located as follows:
1. Pennsylvania Soldiers' and Sailors' Home located at 560 East 3rd Street,
Erie, PA 16507.
aa. Raymond's prior DMVA positions were all based at the
Pennsylvania Soldiers' and Sailors' Home.
bb. Raymond currently maintains an office at the Pennsylvania
Soldiers' and Sailors' Home, but her position is based at Fort
lndiantown Gap.
2. Delaware Valley Veterans' Home located at 2701 Southampton Road,
Philadelphia, PA 19154.
3, Gino Merli Veterans' Center located at 401 Penn Avenue, Scranton, PA
18503.
4. Hollidaysburg Veterans' Home located at PO Box 319, Rt. 220,
Hollidaysburg, PA 16648.
5. Southeastern Veterans' Center located at 1 Veterans Drive, Spring City, PA
19475.
6. Southwestern Veterans' Center located at 7060 Highland Drive, Pittsburgh,
PA 15206.
5. The Director of the Bureau of Veterans Homes position was previously one position but
due to COV1D-19, the job was split into the positions of Executive Director of Long -Term
Care and Bureau of Veterans Homes Director.
a. The Executive Director of Long -Term Care handles the business end of the Bureau
of Veterans Affairs.
1. This position is currently held by Travis Davis ("Davis").
b. The Bureau of Veterans Homes Director handles the clinical end of the Bureau of
Veterans Affairs.
i . This position is currently held by Raymond.
aa. Raymond reports to Davis in the chain of command.
6. Raymond frequently travels as the Bureau of Veterans Homes Director to ensure that the
Veterans Homes are functioning properly.
Raymond, 22-0032-C
Page A
a. Raymond travels on a weekly basis to the Veterans Homes in the Commonwealth.
1. The duties of Raymond's position determine the need/frequency of travel.
2. Raymond's travel frequently includes/requires overnight accommodations.
b. Raymond maintains a Commonwealth of Pennsylvania Travel Credit Card ending
in x-4797 to pay for business travel expenses, including overnight
accommodations.
1. Travel Credit Card ending in x-4797 is in Raymond's name.
2. Raymond is eligible to be reimbursed for expenses incurred for overnight
travel while on Commonwealth business.
7. The Commonwealth maintains policies regarding travel by Commonwealth employees on
official business,
a. Policies regarding employee travel are documented within Commonwealth
Management Directive 230,10, Commonwealth Travel Policy and Manual 230.1,
Commonwealth Travel Procedures Manual.
1. Management Directive 230.10 establishes policy, responsibilities, and
procedures for the CommonweaIth's travel program.
2. Manual 230.1 is issued as a companion to and is based on the policy set
forth in Management Directive 230.10 to assist Commonwealth travelers in
making informed and cost-effective travel decisions.
S. Brian T. Lyman, Chief Accounting Officer, Office of the Budget, Office of Comptroller
Operations issued a memo dated December 13, 2019, titled Travel Policy Revisions,
relating to Section 5 of the Commonwealth Travel Procedures Manual.
a. Section 5.2 Frequent Flyer Guest Programs states that Commonwealth travelers on
official Commonwealth business may open and maintain frequent flyer/guest
accounts with airlines, hotels, car rental companies, train service and other travel
suppliers.
1. Commonwealth travelers may not select a travel supplier based on the
benefits of the frequent traveler program.
b. Policy Item 3-Travel Credits states that any credits, promotions, certificates, or
other considerations earned in a frequent traveler program must be used for official
Conunonwealth travel.
Raymond, 22-0032-C
Page 5
C. Commonwealth travelers may not use a personal credit card in place of the
Commonwealth Corporate Travel Card or Agency Airline Card in order to gain
benefits from their credit card company.
9. Hilton has a rewards program named Hilton Honors.
a. Hilton Honors has multiple tiers/levels to which members can belong, based on the
number of stays the member has per year.
1. Blue tier earns the base number of points for each hotel stay.
aa. 10 points are given per 1 dollar spent at most Hilton brand hotels.
bb. 5 points are given per 1 dollar spent at Home2 Suites and Tru by
Hilton.
2. Silver tier earns 20 percent more points on the base point amount for each
hotel stay.
aa. Members are required to stay 10 plus nights per calendar year
(January 1 to December 31) to reach and maintain the Silver tier.
3. GoId tier earns 80 percent more points on the base point amount for each
hotel stay.
aa. Members are required to stay 40 plus nights per calendar year to
reach and maintain the Gold tier.
4. Diamond tier earns 100 percent more points on the base point amount for
each hotel stay.
aa. Members are required to stay 60 plus nights per calendar year to
reach and maintain the Diamond tier.
b. Members maintain their existing tier status from January I" through March 3 1 " but
are downgraded April 1" if they do not qualify for their existing tier during the
previous calendar year.
10. Marriott has a rewards program named Marriott Bonvoy.
a. Marriott Bonvoy has several tiers to which members can belong, based on the
number of stays the member has per year.
1. Member tier earns the base number of points for each hotel stay.
aa. 10 points are given per 1 dollar spent at most Marriott brand hotels.
Raymond, 22-0032-C
Page 6
bb. 5 points are given per 1 dollar spent at Protea Hotels, Element,
Residence Inn, Towneplace Suites, and Home & Villas by Marriott
Bonvoy.
2. Silver Elite tier earns 10 percent more points on the base point amount for
each hotel stay.
aa. Members are required to stay 10 plus nights per calendar year
(January 1 to December 31) to reach and maintain the Silver Elite
tier.
3. Gold Elite tier carps 25 percent more points on the base point amount for
each hotel stay.
aa. Members are required to stay 25 plus nights per calendar year to
reach and maintain the Gold Elite tier.
4. Platinum Elite tier earns 50 percent more points on the base point amount
for each hotel stay.
aa. Members are required to stay 50 plus nights per calendar year to
reach and maintain the Platinum Elite tier.
5. Titanium Elite tier earns 75 percent more points on the base point amount
for each hotel stay.
aa. Members are required to stay 75 plus nights per calendar year to
reach and maintain the Titanium Elite tier.
6. Ambassador Elite tier earns 75 percent more points on the base point
amount for each hotel stay.
aa. Members are required to stay 100 plus nights and spend $23,000
dollars per calendar year to reach and maintain the Ambassador Elite
tier.
11. Edward Raymond ("E. Raymond") is Raymond's spouse.
12. E. Raymond is a member of the Hilton Honors rewards program and the Marriott Bonvoy
rewards program.
a. E. Raymond became a member of the Hilton Honors rewards program on July 11,
2013.
I . E. Raymond receives bonus points for staying at his "benefit preferences."
Raymond, 22-0032-C
Page 7
2. As of March 30, 2023, E. Raymond's Hilton Honors account had earned at
least 920,373 points and redeemed at least 346,000 points.
aa. E. Raymond became a Hilton Honors Diamond tier member on or
about February 5, 2020, and maintained that status through at least
March 30, 2023.
b. E. Raymond became a member of the Marriott Bonvoy rewards program on January
14, 2013.
1. As of March 7, 2023, E. Raymond's Marriott Bonvoy account had earned
at least 488,305 points and redeemed at least 386,500 points.
13. Raymond has memberships with Hilton Honors and Marriott Bonvoy.
a. Raymond became a member of the hotel rewards programs at different times.
1. Raymond enrolled in the Hilton Honors program on August 29, 2022.
aa. Raymond's Hilton Honors number ends in 1018.
bb. Raymond is a Silver tier member.
cc. As of March 30, 2023, Raymond's Hilton Honors account had
earned at least 18,390 points.
2. Raymond enrolled in the Marriott Bonvoy program on August 28, 2022.
aa. Raymond's MaiTiott Bonvoy number ends in -9879.
bb. Raymond is a Gold Elite tier member.
CC. As of March 2023, Raymond's Marriott Bonvoy account had
earned at least 86,809 points.
14. E. Raymond is employed by a private manufacturing company.
15. E. Raymond frequently travels for his employment.
a. E. Raymond is based at his company's Pennsylvania location.
b. E. Raymond traveled to his employer's other various locations throughout the
United States.
16. His employer uses a system for its employee travel which enables travelers to upload their
own hotel and food receipts.
Raymond, 22-0032-C
Page 8
a. Reimbursement for travel expenses requires the employee to submit the request to
his/her respective supervisor to approve the request, which is then submitted to the
finance department.
17. His employer's travel policy allows employees to belong to rewards programs and gain
points while traveling.
a. Employees are permitted to use the reward points they earn during related travel
for personal use.
18. E. Raymond accumulated Hilton Honors points and Marriott Bonvoy points on his personal
Hilton and Marriott rewards accounts through his work travel.
a. E. Raymond's travel significantly declined in 2020 due to the COVID-19
pandemic.
19. Raymond frequently travels in her capacity as the Bureau of Veterans Homes Director.
a. Raymond travels weekly to Veterans Homes in the Commonwealth to ensure the
Veterans Homes are functioning properly.
b. Raymond's travel with the Commonwealth significantly increased in 2020 due to
the COVID-19 pandemic.
20. The Commonwealth uses the Concur system for its employee travel, which enables
travelers or their travel delegates to upload their travel -related expenses for reimbursement.
a. Travel delegates have the ability to access and change the profile of the individual
to which they are assigned.
I. This includes the ability to add rewards numbers for various programs.
21. DMVA travel requests submitted through Concur go through different processes
depending on the destination and the purpose of the travel.
a. Regular Weekly Travel.
1. The traveler or the travel delegate books a hotel room through Concur.
2. The traveler returns with subsistence receipts and a hotel folio and either
the traveler or the travel delegate uploads the documents into Concur.
3. The traveler is reimbursed based on the data that is uploaded into Concur.
b. In -State Trainings.
1. The traveler completes an Out of Service Training ("OST") memo.
Raymond, 22-0032-C
Page 9
aa. The OST is approved by the traveler's superior and ultimately the
Adjutant General,
bb. The OST estimates travel amounts and any conference registration
fees.
C. Out -of -State Conferences.
1. Travelers complete a Commonwealth Out of State Travel Application
("COSTA") through the COSTA system and attach their OST memo.
2. The COSTA is approved in a continually upward process by the following:
aa. Traveler.
bb. Supervisor.
cc. Manager.
dd. Travel Coordinator.
cc. Deputy Secretary for Administration or equivalent.
ff. Travel Coordinator.
gg. Governor's Office.
i. If the trip is estimated to be over $5,000 the COSTA is
automatically sent to the Governor's Office.
22. In Raymond's previous position as Commandant and in her current position as Bureau of
Veterans Homes Director she was/is assigned a travel delegate to book her travel.
a. Raymond's Concur profile identified three individuals as Raymond's travel
delegates.
I. Alyssa Cooley ("Cooley") - Raymond's administrative assistant.
2. Pamela Jenkins - Raymond's former administrative assistant.
3. Joshua Pulling - Accounting Assistant,
23. On September 16, 2021, Stacey Jo Withers ("Withers"), Assistant Director of Travel
Operations, Bureau of Commonwealth Payroll Operations, Travel Operations Division,
emailed Raymond regarding Raymond's stay at the Sheraton Station Square from August
24, 2021, through August 27, 2021.
Rayrnond, 22-0032-C
Page 10
a. Withers informed Raymond that her (Raymond's) reimbursement request for
overnight expenses associated with her Sheraton Station Square stay was being
returned for not presenting the Commonwealth employee name on the hotel folio.
1. E. Raymond's name appeared on the hotel folio.
b. Withers instructed Raymond to obtain a new hotel folio with her (Raymond's)
name as the guest.
C. Withers attached the Commonwealth Travel Procedures Manual 230.1 Section 5.2
Frequent Flyer Guest Programs to her email which identified Commonwealth
policies relating to travel rewards programs.
d. Withers informed Raymond that any fixture reservations without the proper name
on the hotel folio would not be processed for reimbursement.
24. Raymond received an email on January 31, 2022, from James Austin ("Austin"), Division
Chief Travel Accounting & Auditing, Bureau of Commonwealth Payroll Operations,
Travel Operations Division, Pennsylvania Office of Budget Comptroller Operations stating
that hotel folios from her (Raymond's) October 5 to 6, 2021, travel report were being
returned for correction.
a. Austin informed Raymond that the Commonwealth travel policy allows a
Commonwealth traveler to earn rewards on a hotel program, but the rewards
number must be in the Commonwealth traveler's name.
b. Austin provided Raymond with the opportunity to correct the hotel folios,
instructed Raymond to contact the hotel and have E. Raymond's reward number
removed, and advised Raymond to provide a new hotel folio without E. Raymond's
reward number attached.
25. Copied on the emails to Raymond were Raymond's travel delegate and administrative
assistant Cooley, Withers, Davis, Elizabeth Mione (Administrative Officer at DMVA), and
Patricia Derry ("Derry") (Deputy for Administration at DMVA).
a. Cooley returned Austin's January 31, 2022, email on February 2, 2022, informing
him that the hotel was unable to remove the honors number as Raymond had
already checked out.
26. On February 4, 2022, Austin sent an email to Raymond which included the Commonwealth
Travel Procedures Manual 230.1, Section 5.2 Frequent Flyer Guest Programs.
a. Austin informed Raymond that any future travel reports submitted for
reimbursement with hotel reward points not in Raymond's name would be denied
reimbursement for the hotel expenses.
Raymond, 22-0032-C
Page I
b. Cooley, Withers, Davis, and Derry were copied on the email.
27. An audit of Raymond's travel documents was subsequently completed by Withers and her
staff in the Travel Audit Department because of Raymond's contravention of the
Commonwealth travel policy and having been previously informed of the policy.
a. An audit was completed on Raymond after she violated the Commonwealth policy.
28. On August 26, 2022, Austin emailed Raymond following the audit completed on
Raymond's travel reimbursements, again attaching the Commonwealth Travel Procedures
Manual 230.1, Section 5.2 Frequent Flyer Guest Programs.
a. Austin informed Raymond that the department would be sending reports back to
Raymond for correction requiring the removal of the hotel rewards and Raymond's
resubmission of the applicable expense reports.
29. On August 29, 2022, Gloria Winkleman ("Winkleman"), Section Supervisor of the Travel
Accounting Section, sent four emails to Raymond.
Winkleman referenced Austin's February 4, 2022, email that informed Raymond
that any future expense reports which included hotel reward points not in
Raymond's name would be denied payment.
b. All four of the emails included the Commonwealth Travel Procedures Manual
230.1 Section 5.2 Frequent Flyer Guest Programs, as attachments.
c. The emails were either copied (3) or forwarded (1) to Withers and Austin.
30. Raymond was denied reimbursement of hotel expenses incurred for Commonwealth -
related business travel as follows:
Trip #
Cheek In
Check Out
Hotel
Charge
269943
5/11/2022
5/12/2022
Hampton Inn Limerick
$133.56
269943
5/12/2022
5/13/2022
Sheraton Station Square
$161.44
269963
6/6/2022
6/8/2022
Four Points by Sheraton
$230.00
283171
7/11/2022
7/13/2022
Sheraton Station Square
$322.88
283171
7/13/2022
7/14/2022
Hampton Inn Limerick
$138.60
293171
7/14/2022
7/15/2022
Sheraton Station Square
M I A
289062
7/24/2022
7/26/2022
Hampton Inn Limerick
$267.12
289062
7/27/2022
7/28/2022
Sheraton Station Square
$161.44
Total Not Reimbursed
$1,576.48
Ra, ice, 22-0032-C
Page 12
a. All travel expenses identified were paid for via Raymond's Commonwealth Travel
Card (x-4797).
b. Raymond opened her own membership accounts with Hilton Honors and Marriott
Bonvoy in August 2022 as a result of the reimbursement denial.
31. Raymond and E. Raymond had earned a total of approximately 574,373 points on E.
Raymond's Hilton Honors account as of August 29, 2022.
a. The accrual of the 574,373 points included multiple points earned by Raymond as
a result of traveling for the Commonwealth in her official capacity.
32. Of the approximate 574,373 Hilton Honors points earned as of August 29, 2022,
approximately 379,122 were earned by Raymond from January 9, 2017, through November
29, 2021, while traveling on official Commonwealth business.
a. Raymond's travel began to increase in 2020 due to the COVID-19 pandemic.
b. Raymond utilized her Commonwealth credit card to issue payment for her noted
Commonwealth lodging expenses.
C. Raymond submitted for and received reimbursement from the Commonwealth for
her travel -related expenses.
33. Raymond earned approximately 18,390 points on her Hilton Honors account (Acct. No. -
1018) from August 29, 2022, until February 28, 2023, while traveling in her capacity as a
Commonwealth employee as detailed below:
Arrival
Date
Departure
Date
Brand
Code
Prop
Code
Honors
Number
Guest
9/11/2022
9/12/2022
HA
PHLLI
1637311018
Barb Raymond
9/26/2022
9/29/2022
HH
MDTIIH
1637311018
Barb Raymond
10/12/2022
10/13/2022
HA
PHLLI
1637311018
Barb Raymond
12/19/2022
12/20/2022
HA
PHLLI
1637311018
Barb Raymond
1/9/2023
1/11/2023
HA
PFILLI
1637311018
Barb Raymond
2/26/2023
2/28/2023
HA
PHLLI
1637311018
Barb Raymond
Raymond utilized her Commonwealth credit card to issue payment for the noted
lodging expenses.
Raymond, 22-0032-C
Page 13
b. Raymond submitted for and received reimbursement from the Commonwealth for
the travel -related expenses.
34. Hilton Honors points can be used to redeem free hotel room stays.
Individual Hilton brand hotels may require different point amounts for a free night
based on the category of hotel, location, and seasonal rates.
b. Room redemptions provide the guest with a standard room for lodging.
35. Raymond utilized a total of 346,000 Hilton Honors points to stay a total of six nights of
redeemed hotel room stays under E. Raymond's Hilton Honors account number as detailed
below:
a. The Raymonds used 26,000 Hilton Honors points to pay room fees for a one night
stay at the Homewood Suites by Hilton in Orlando, Florida from May 8, 2021, to
May 9, 2021.
1. A standard room rate at the Homewood Suites by Hilton was approximately
$99.00 in May of 2021.
b. The Raymonds used 320,000 Hilton Honors points to pay room fees for a five -night
stay at the Marco Island Beach Resort in Marco Island, Florida from November 24,
2021, to November 29, 2021.
A standard room rate at the Marco Island Beach Resort was approximately
$329.00 in 2021.
Raymond in her Commonwealth travel had accrued in excess of 26,000 points as
of September 26, 2019, and in excess of 320,000 points by June 16, 2021.
1. The point totals each were accrued prior to the respective redemptions.
36. Raymond saved approximately $1,744.00 on hotel room fees by utilizing Hilton Honors
points as detailed below:
Hotel
Year
Standard
Rate
Days
Redeemed
Total
Marco Island Beach Resort - Hilton
2021
$329.00
5
$1,645.00
Homewood Suites Orlando - Hilton
2021
$99.00
1
$99.00
Total
$1,744.00
Raytnond, 22-0032-C
Page 14
37. Raymond and E. Raymond had earned approximately 484,965 points on E. Raymond's
Marriott Bonvoy account number x-7962 tip until August 28, 2022.
a. The accrual of the 484,965 points included multiple points earned by Raymond as
a result of traveling for the Commonwealth in her official capacity.
38. Of the approximate 484,965 Marriott Bonvoy points earned as of August 28, 2022,
approximately 242,271 were earned by Raymond from February 2020 through August
2022 while traveling on official Commonwealth business.
a. Raymond's travel started to increase in 2020 due to the COVID-19 pandemic.
39. Raymond opened her own Marriott Bonvoy account on August 28, 2022.
40. Raymond earned approximately 86,809 points on her Marriott Bonvoy account (x-1018)
from August 28, 2022, until March 10, 2023, while traveling in her capacity as a
Commonwealth employee.
a. Raymond utilized her Commonwealth credit card to issue payment for the noted
lodging expenses.
b. Raymond submitted for and received reimbursement from the Commonwealth for
the travel -related expenses.
41. Marriott Bonvoy points can be used to redeem free hotel stays.
a. Marriott Bonvoy brand hotels may require different point amounts for a free night
based on the category of hotel, location, and seasonal rates.
b. Room redemptions provide the guest with a standard room for lodging.
42. Raymond utilized a total of 149,000 Marriott Bonvoy points to stay a total ofthree nights
of redeemed hotel room stays with Marriott under E. Raymond's Marriott Bonvoy account
number as detailed below:
Redemption
Points
Date
Hotel Information
Used
Certificate N
Guest
Hotel
Standard Rate
Redemption/ Marriott
11/23/2021
Hotel
60,000
14470231
E. Raymond
JW Marriott Marco Island
6/16/2022
Free Suite Award
59,000
1609505
E. Raymond
Hilton Head Resort & Spa
Standard Rate
Redemption/ Marriott
11/18/2022
Hotel
30,000
68032754
E. Raymond
Residence Inn Orlando
Total:
149,000
Rand, 22-0032-C
Page 15
a. The Raymonds used 60,000 Marriott Bonvoy points to pay the room fee for a one-
night stay at the JW Marriott Marco Island Beach Resort in Marco Island, Florida
from November 23, 2021, to November 24, 2021.
I. A standard room at the JW Marriott Marco Island Beach Resort was
approximately $329.00 in November of 2021.
b. The Raymonds used 59,000 Marriott Bonvoy points to pay the room fee for a one-
night stay at the Marriott Hilton Head Resort & Spa located at Hilton Head Island,
South Carolina from June 16, 2022, to June 17, 2022,
1. A standard room at the Marriott Hilton Head Resort & Spa was
approximately $310.00 in June of 2022.
C. The Raymonds used 30,000 Marriott Bonvoy points to pay the room fee for a one-
night stay at the Residence Inn Orlando by Marriott located in Orlando, Florida
from November 18, 2022, to November 19, 2022.
1. A standard room at the Residence Inn Orlando by Marriott was
approximately $99.00 in November of 2022.
d. Raymond in her Commonwealth travel had accrued in excess of 60,000 points as
of August 27, 2021; in excess of 59,000 points by January 13, 2022; and in excess
of 30,000 points by March 10, 2022.
1. The point totals each were accrued prior to the respective redemptions.
43. Raymond saved approximately $775.42 on hotel room fees by utilizing her Marriott
Bonvoy points as detailed below:
Hotel
Year
Standard
Rate
Days
Redeemed
Total
JW Marriott Marco Island
2021
$329.00
1
$329.00
Hilton Head Resort & Spa - Marriott
2022
$310.00
1
$310.00
Residence Inn Orlando - Marriott
2022
$136.42
1
$136.42
Total
$775.42
44. After the redemption of Hilton Honors reward points for personal travel and Marriott
Bonvoy points for personal travel Raymond has an approximate remaining balance of
51,512 Hilton Honors points and 180,080 Marriott Bonvoy points respectively as shown
below:
Raymond, 22-0032-C
Page 16
Description
Hilton
Marriott
E. Raymond's accounts
33,122
93,271
Raymond's accounts
18,390
86,809
Total
51,512
180,080
45. Raymond realized a financial gain of approximately $2,519.42 to effect free lodging
between 2021 and 2022 by using Hilton Honors points and Marriott Bonvoy points, which
were accrued during her Commonwealth travel, for personal travel stays.
Hotel
Year
Standard
Rate
Days
Redeemed
Total
Marco Island Beach Resort - Hilton
2021
$329.00
5
$1,645.00
Homewood Suites Orlando - Hilton
2021
$99.00
1
$99.00
JW Marriott Marco Island
2021
$329.00
1
$329.00
Hilton Head Resort & Spa - Marriott
2022
$310.00
1
$310.00
Residence Inn Orlando - Marriott
2022
$136.42
1
$136.42
$1,203.42
$2,519.42
111. DISCUSSION:
As the Director of the Bureau of Veterans Homes of the Pennsylvania Department of
Military and Veterans Affairs ("DMVA") from approximately July 2, 2021, through the present,
Respondent Barbara L. Raymond ("Raymond") has been a public employee subject to the
provisions of the Public Official and Employee Ethics Act ("Ethics Act"), 65 Pa. C.S. § 1101 et
sec..
The allegation is that Raymond violated Section 1103(a) of the Ethics Act when she used
the authority of her public position for a private pecuniary benefit by utilizing Commonwealth -
related travel to receive reward/benefit points from American Airlines Advantage, Hilton Honors,
Intercontinental Hotels Group Rewards Club, Marriot International/Marriot Bonvoy, and the
Radisson Hotel Group/Club Carlson, which were not used for Commonwealth -related travel.
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).
Ra. Inond, 22-0032-C
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The following terms relevant to Section 1103(a) are 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 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 innnediate family or a business with which he or a
member of his immediate family is associated.
65 Pa.C.S. § 1102.
Subject to the statutory exclusions to the Ethics Act's definition of the term "conflict" or
"conflict of interest," 65 Pa.C.S. § 1102, pursuant to Section 1103(a) of the Ethics Act, a public
official/public employee is prohibited 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.
In Stefanko, Opinion 90-015, this Commission determined that:
[A]ny frequent flyer credits or award certificates received by or due the individual
in connection with official travel, paid for by the government agency by which he
is employed, are due to that agency and must be used for official travel only; the
utilization for his own personal travel is prohibited since such activity would be a
private pecuniary benefit obtained through the use of authority of office.
Id. at 5.
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.
Raymond has been employed with DMVA since approximately March 31, 2005, and she
has served as the Director of the Bureau of Veterans Homes since approximately July 2, 2021.
Raymond is responsible for overseeing the administration of six DMVA Veterans Homes located
throughout the Commonwealth, and she travels to them frequently to ensure that they are
fiinctioning properly. Raymond maintains a Commonwealth of Pennsylvania Corporate Travel
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Credit Card in her name to pay for her Commonwealth business travel expenses, and she is eligible
to be reimbursed for expenses incurred for her overnight travel.
Commonwealth Management Directive 230.10, Commonwealth Travel Policy, establishes
policy and procedures for the Conrrnonwealth's employee travel program. The Commonwealth
Travel Procedures Manual (Manual 230.1) is issued to assist Commonwealth employees in making
informed and cost-effective travel decisions. Per the Commonwealth Travel Policy and the
Commonwealth Travel Procedures Manual, employees who travel on Commonwealth business
may open and maintain frequent flyer/guest accounts with airlines, hotels, and other suppliers of
travel services. However, any credits, promotions, certificates, or other considerations earned in
a frequent traveler program must be used for official Commonwealth travel.
Hilton has a rewards program, Hilton Honors, that allows its members to carp points for
staying at Hilton hotels. Marriott also has a rewards program, Marriott Bonvoy, that allows its
members to carp points for staying at Marriott hotels. A member earns points based on the number
of hotel stays per year, and points may be redeemed for free hotel stays.
Raymond's spouse, Edward Raymond ("E. Raymond"), travels frequently in the course of
his employment with a company. E. Raymond is allowed to tarn points through rewards programs
while traveling on business and to use those points for personal travel. E. Raymond has
accumulated points in both Hilton Honors and Marriott Bonvoy for his work travel since 2013.
On September 16, 2021, Stacey Jo Withers ("Withers"), Assistant Director of Travel
Operations, Bureau of Commonwealth Payroll Operations, Travel Operations Division, informed
Raymond by email that Raymond's request for reimbursement for overnight expenses associated
with her hotel stay from August 24, 2021, through August 27, 2021, was being returned for
presenting E. Raymond's name instead of her name on the hotel folio. Withers instructed
Raymond to obtain a new hotel folio with Raymond's name as the guest, and she attached to her
email the Commonwealth's policies relating to travel rewards programs.
On January 31, 2022, Raymond received an email from James Austin ("Austin"), Division
Chief, Travel Accounting and Auditing, Bureau of Commonwealth Payroll Operations, Travel
Operations Division, stating that hotel folios from Raymond's October 5 to 6, 2021, travel report
were being returned for correction. Austin informed Raymond that the Commonwealth travel
policy allows a Commonwealth traveler to earn rewards on a hotel program, but the rewards
number must be in the Commonwealth traveler's name. Austin instructed Raymond to contact the
hotel to have E. Raymond's reward number removed from her hotel folio and to provide a new
hotel folio without E. Raymond's reward number attached. On February 4, 2022, Austin informed
Raymond by email that any future travel reports submitted for reimbursement with hotel reward
points not in Raymond's name would be denied reimbursement for the hotel expenses.
Raymond was subsequently denied reimbursement for $1,576.48 in hotel expenses that
were charged to her Commonwealth Corporate Travel Credit Card for her stays at hotels on eight
occasions between May 11, 2022, and July 27, 2022. As a result of the reimbursement denial,
Raymond opened her own membership accounts with Marriott Bonvoy and Hilton Honors on
August 28, 2022, and August 29, 2022, respectively.
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Raymond earned approximately 379,122 points on E. Raymond's Hilton Honors account
as a result of traveling for the Commonwealth between January 9, 2017, and November 29, 2021.
The Raymonds used 346,000 points under E. Raymond's Hilton Honors account to redeem a free
one-night stay at the Homewood Sautes by Hilton in Orlando, Florida in May 2021 and a free five -
night stay at the Marco Island Beach Resort in Marco Island, Florida in November 2021. Based
upon the hotels' standard room rates, Raymond saved approximately $1,744.00 by using the Hilton
Honors points for the free hotel stays.
Raymond earned approximately 242,271 points on E. Raymond's Marriott Bonvoy account
as a result of traveling for the Commonwealth between February 2020 and August 27, 2022. The
Raymonds used 149,000 points under E. Raymond's Marriott Bonvoy account to redeem free one-
night stays at the JW Marriott Marco Island Beach Resort in Florida in November 2021, the
Marriott Hilton Head Resort & Spa in South Carolina in June 2022, and the Residence Inn Orlando
by Marriott in Florida in November 2022. Based upon the hotels' standard room rates, Raymond
saved approximately $775.42 by utilizing the Marriott Bonvoy points for the free hotel stays.
The parties have stipulated that Raymond realized a financial gain of approximately
$2,519.42 by using Hilton Honors points and Marriott Bonvoy points, which were accrued during
her Commonwealth travel, for personal free lodging in 2021 and 2022.
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:
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 when Raymond utilized
Commonwealth -related travel to receive
reward/benefit points from Hilton Honors and
Marriot Bonvoy, which were not used for
Commonwealth -related travel.
4. Raymond agrees to make payment in the amount of $1,000.00 in
settlement of this matter payable to the Commonwealth of
Pennsylvania and forwarded to the Pennsylvania State Ethics
Commission, within thirty (30) days of the issuance of the final
adjudication in this matter,
5. Raymond agrees to not accept any reimbursement, compensation or
other payment from the Bureau of Veterans Homes, Department of
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Page 20
Military and Veterans Affairs, representing a full or partial
reimbursement of the amount paid in settlement of this matter.
6. Raymond agrees to use travel rewards program points accrued
during Commonwealth travel only for future Commonwealth travel,
in accordance with Commonwealth policies.
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 Raymond'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.
a. Raymond has been advised that as a matter of course, all
orders from the Commission are provided to the Attorney
General, albeit without any specific recommendations
pursuant to Paragraph 7 above.
b. Raymond has been advised that all orders become public
records and may be acted upon by law enforcement as they
deem appropriate.
C. The non -referral language contained in this paragraph is
considered an essential part of the negotiated Consent
Agreement.
Consent Agreement, at 1-2.
We accept the recommendation of the parties for a finding of a violation of Section 1103(a)
of the Ethics Act. It is clear that the elements of a use of authority of office for a private pecuniary
benefit have been established.
Per the travel policy established by the Commonwealth, any credits or other considerations
that a Commonwealth employee earns in a rewards program as a result of traveling on
Commonwealth business must be used for official Commonwealth travel. Raymond used the
authority of her public position when she earned points in her spouse's Hilton Honors and Marriott
Bonvoy rewards programs due to her hotel stays while traveling on Commonwealth business.
Raymond's use of the authority of her public position resulted in a private pecuniary benefit in that
the points she earned were redeemed for personal free hotel stays worth approximately $2,519,42
instead of being redeemed for official Commonwealth travel.
Based upon the Stipulated Findings and Consent Agreement, we hold that a violation of
Section 1103(a) of the Ethics Act, 65 Pa.C.S. § 1103(a), occurred when Raymond utilized
Raymond, pond, 22-0032-C
Page 21
Commonwealth -related travel to receive reward/benefit points from the Hilton Honors and Marriot
Bonvoy rewards programs which were not used for Commonwealth -related travel.
As part of the Consent Agreement, Raymond has agreed to make payment in the amount
of $1,000.00 payable to the Commonwealth of Pennsylvania and forwarded to this Commission
within thirty (30) days of the issuance of the final adjudication in this matter. Raymond has agreed
to not accept any reimbursement, compensation or other payment from the Bureau of Veterans
Homes, DMVA, representing a frill or partial reimbursement of the amount paid in settlement of
this matter. Raymond has finrther agreed to use travel rewards program points accrued during
Commonwealth travel only for fiiture Commonwealth travel in accordance with Commonwealth
policies.
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, Raymond is directed to make
payment in the amount of $1,000.00 payable to the Commonwealth of Pennsylvania and forwarded
to this Commission by no later than the thirtieth (30"') day after the mailing date of this adjudication
and Order,
Raymond is directed to not accept any reimbursement, compensation or other payment
from the Bureau of Veterans Homes, DMVA, representing a full or partial reimbursement of the
amount paid in settlement of this matter.
Raymond is directed to fiilfill her agreement to use travel rewards program points accrued
during Commonwealth travel only for future Commonwealth travel in accordance with
Commonwealth policies.
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.
IV. CONCLUSIONS OF LAW:
1. As the Director of the Bureau of Veterans Homes of the Pennsylvania Department of
Military and Veterans Affairs from approximately July 2, 2021, through the present,
Respondent Barbara L. Raymond ("Raymond") has been a public employee subject to the
provisions of the Public Official and Employee Ethics Act ("Ethics Act"), 65 Pa.C.S. §
1101 et sec .
2. A violation of Section 1103(a) of the Ethics Act, 65 Pa.C.S. § 1103(a), occurred when
Raymond utilized Commonwealth -related travel to receive reward/benefit points from the
Hilton Honors and Marriot Bonvoy rewards programs which were not used for
Commonwealth -related travel.
In Re: Barbara Raymond, File Docket: 22-0032-C
Respondent Date Decided: 9/10/24
Date Mailed: 9/13/24
ORDER NO. 1840
1. A violation of Section I I03(a) of the Public Official and Employee Ethics Act, 65 Pa.C.S.
§ 1103(a), occurred when Barbara L. Raymond ("Raymond"), as the Director of the Bureau
of Veterans Homes of the Pennsylvania Department of Military and Veterans Affairs,
utilized Commonwealth -related travel to receive reward/benefit points from the Hilton
Honors and Marriot Bonvoy rewards programs which were not used for Commonwealth -
related travel.
2. Per the Consent Agreement of the parties, Raymond is directed to make payment in the
amount of $1,000.00 payable to the Commonwealth of Pennsylvania and forwarded to the
Pennsylvania State Ethics Commission by no later than the thirtieth (301h) day after the
mailing date of this Order.
3. Raymond is directed to not accept any reimbursement, compensation or other payment
from the Bureau of Veterans Homes, Pennsylvania Department of Military and Veterans
Affairs, representing a full or partial reimbursement of the amount paid in settlement of
this matter.
4. Raymond is directed to fulfill her agreement to use travel rewards program points accrued
during Commonwealth travel only for future Commonwealth travel in accordance with
Commonwealth policies.
5. Compliance with paragraphs 2, 3, and 4 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,
Michael A. Schwartz, Chair