Interim Audit Report of the 

Audit Division on the 

1199 SEIU United Healthcare 

Workers East Federal Political 

Action Fund1 (January 1, 2019 - December 31, 2020)

Why the Audit 

Was Done

Federal law permits the 

Commission to conduct 

audits and field 

investigations of any 

political committee that is 

required to file reports 

under the Federal 

Election Campaign Act 

(the Act). The 

Commission generally 

conducts such audits 

when a committee 

appears not to have met 

the threshold 

requirements for 

substantial compliance 

with the Act. 2 The audit 

determines whether the 

committee complied with 

the limitations, 

prohibitions and 

disclosure requirements 

of the Act.

About the Committee (p. 2)

The 1199 SEIU United Healthcare Workers East Federal Political 

Action Fund is a separate segregated fund – labor organization of 

1199 SEIU United Healthcare Workers East and is headquartered 

in New York, New York. For more information, see the chart on 

the Committee Organization, p.2. 

Financial Activity (p. 2)

• Receipts

o Contributions from Individuals 

o Other Federal Receipts

Total Receipts

$ 13,153,782 

4 

$ 13,153,786 

• Disbursements

o Transfers to Affiliated/Other 

Party Committees

o Other Disbursements 

o Contributions to Federal 

Candidates/Committee and 

Other Political Committees

o Refund of Contributions to 

Individuals 

o Operating Expenditures 

Total Disbursements

$ 10,807,053 

1,623,242 

337,250 

203,833 

96,694 

$ 13,068,072

1

 On January 24, 2023, the committee filed a Statement of Organization changing its name from 1199 

Service Employees Int’l Union Federal Political Action Fund to 1199 SEIU United Healthcare Workers 

East Federal Political Action Fund. 2

 52 U.S.C. §30111(b).
Future Action

The Commission may 

initiate an enforcement 

action, at a later time, 

with respect to any of the 

matters discussed in this 

report.

Findings and Recommendations (p. 3)

• Misstatement of Financial Activity (Finding 1)

• Reporting of Apparent Independent Expenditures (Finding 2)

• Recordkeeping for Communications (Finding 3)
Interim Audit Report of the Audit 

Division on the 

1199 SEIU United Healthcare 

Workers East Federal Political 

Action Fund 

(January 1, 2019 - December 31, 2020) 
Table of Contents 

Page 

Part I. Background

 Authority for Audit 1 

 Scope of Audit 1 

 Records Obtained Through Subpoena 1 

Part II. Overview of Committee 

Committee Organization 2 

Overview of Financial Activity 2 

Part III. Summaries 

Findings and Recommendations 3 

Part IV. Findings and Recommendations

Finding 1. Misstatement of Financial Activity 5

Finding 2. Reporting of Apparent Independent Expenditures 6

Finding 3. Recordkeeping for Communications 10
1

Part I 

Background

Authority for Audit

This report is based on an audit of the 1199 SEIU Service United Healthcare Workers 

East Federal Political Action Fund (1199 SEIU), undertaken by the Audit Division of the 

Federal Election Commission (the Commission) in accordance with the Federal Election 

Campaign Act of 1971, as amended (the Act). The Audit Division conducted the audit 

pursuant to 52 U.S.C. §30111(b), which permits the Commission to conduct audits and 

field investigations of any political committee that is required to file a report under 52 

U.S.C. §30104. Prior to conducting any audit under this subsection, the Commission 

shall perform an internal review of reports filed by selected committees to determine if 

the reports filed by a particular committee meet the threshold requirements for substantial 

compliance with the Act. 52 U.S.C. §30111(b). 

Scope of Audit

Following Commission-approved procedures, the Audit staff evaluated various risk 

factors and as a result, this audit examined: 

1. the consistency between reported figures and bank records; 

2. the disclosure of individual contributors’ occupation and name of employer; 

3. the disclosure of independent expenditures; 

4. the disclosure of disbursements, debts and obligations; 

5. the completeness of records; and

6. other committee operations necessary to the review.

Records Obtained Through Subpoena

Following numerous written and verbal attempts by the Audit staff to obtain the records 

required to perform the audit, on June 1, 2022, the Commission issued a Subpoena to 

Produce Documents and Order to Submit Written Answers to 1199 SEIU.3 The 

subpoena contained a request for a database of receipts, bank statements, sample 

documentation for donor payroll deductions authorizations, copies of negotiated checks, 

copies of records and media and the completed Internal Control Questionnaire provided 

by the Federal Election Commission. In response the subpoena request, 1199 SEIU 

submitted records on July 1, 2022. 

3

 See supra footnote 1. 
2 

Part II

Overview of Committee 

Committee Organization 

Overview of Financial Activity 

(Audited Amounts)

Cash on hand @ January 1, 2019 $ 1,570,822

Receipts

o Contributions from Individuals 13,153,782

o Other Federal Receipts 4

Total Receipts $ 13,153,786

Disbursements

o Transfers to Affiliated/Other Party 

Committees

10,807,053

o Other Disbursements 1,623,242

o Contributions to Federal Candidates 

/Committees and Other Political Committees 337,250

o Refund of Contributions to Individuals 203,833

o Operating Expenditures 96,694

Total Disbursements $ 13,068,072

Cash on hand @ December 31, 2020 $ 1,678,2784

4

 The 2020 ending cash on hand does not equal the beginning cash on hand plus reported receipts minus reported 

disbursements. The difference is due to voided checks that were outstanding, some as old as over 13 years. 

Important Dates

• Date of Registration September 1, 1999

• Audit Coverage January 1, 2019 - December 31, 2020

Headquarters New York, New York

Bank Information

• Bank Depositories One

• Bank Accounts One checking account

Treasurer

• Treasurer When Audit Was Conducted Helen Schaub (11/9/2021 – Present)

Timothy Foley (5/3/2017 – 11/8/2021)

• Treasurer During Period Covered by Audit Timothy Foley

Management Information

• Attended FEC Campaign Finance Seminar Yes

• Who Handled Accounting and 

Recordkeeping Tasks

Paid Staff
3

Part III

Summaries

Findings and Recommendations

Finding 1. Misstatement of Financial Activity

During audit fieldwork, a comparison of 1199 SEIU’s reported financial activity with its 

bank records revealed a misstatement of beginning and ending cash on hand balances for 

calendar years 2019 and 2020. Specifically, for 2019, 1199 SEIU overstated its 

beginning and ending cash on hand balances by $161,025. For 2020, 1199 SEIU 

overstated its beginning cash on hand balance by $161,025 and overstated its ending cash 

on hand balance by $96,649. The Audit staff recommends that 1199 SEIU amend its 

most recently filed disclosure reports to correct its cash on hand balance.

(For more detail, see p. 5.)

Finding 2. Reporting of Apparent Independent 

Expenditures

During audit fieldwork, the Audit staff reviewed expenditures, totaling $825,663, that 

1199 SEIU disclosed on Schedule B, Line 29 (Other Disbursements). These appear to be 

independent expenditures that contain express advocacy and should have been disclosed 

on Schedule E, Line 24 (Itemized Independent Expenditures). Additionally, of the 

apparent independent expenditures totaling $825,663, the Audit staff identified two 

disbursements, totaling $75,500, for which1199 SEIU may have been required to file 24-

hour reports depending on the date of public dissemination.

If 1199 SEIU believes that the apparent independent expenditures, totaling $825,663, did 

not require reporting as independent expenditures, the Audit staff recommends that 1199 

SEIU provide documentation to support its conclusion. Absent such documentation, the 

Audit staff recommends that 1199 SEIU amend its reports to disclose these 

disbursements as independent expenditures on Schedule E and submit revised procedures 

for reporting independent expenditures. Lastly, for the two disbursements totaling 

$75,500, the Audit staff recommends that 1199 SEIU provide documentation to support 

the date of public dissemination for each communication to determine whether 24-hour 

reports were required to be filed.

(For more detail, see p. 6.)

Finding 3. Recordkeeping for Communications

During audit fieldwork, the Audit staff reviewed disbursements for communications to 

verify the accuracy of the information and proper classification of transactions disclosed 

on 1199 SEIU’s reports. The Audit staff identified 17 transactions on 1199 SEIU’s 

24/48-Hour Reports of Independent Expenditures, totaling $1,025,299, with purposes 

including, “digital ads,” “digital ads set up,” “projected digital ad buy” and “projected 

staff compensation for phone banking.” Documentation provided by 1199 SEIU was 
4

insufficient to verify proper reporting. The Audit staff recommends that 1199 SEIU 

provide the necessary information from which the reported disbursements, totaling 

$1,025,299, may be verified or explained. Such records may include worksheets 

demonstrating how 1199 SEIU allocated the expenditure on behalf of each clearly 

identified candidate for Federal office, copies of invoices and identification of the 

associated communication, and, if the communication has been provided, information 

associating each communication with an invoice(s).

(For more detail, see p. 10.)
5

Part IV

Findings and Recommendations

Finding 1. Misstatement of Financial Activity 

Summary 

During audit fieldwork, a comparison of 1199 SEIU’s reported financial activity with its 

bank records revealed a misstatement of beginning and ending cash on hand balances for 

calendar years 2019 and 2020. Specifically, for 2019, 1199 SEIU overstated its 

beginning and ending cash on hand balances by $161,025. For 2020, 1199 SEIU 

overstated its beginning cash on hand balance by $161,025 and overstated its ending cash 

on hand balance by $96,649. The Audit staff recommends that 1199 SEIU amend its 

most recently filed disclosure reports to correct its cash on hand balance. 

Legal Standard 

Contents of Reports. Each report must disclose:

• The amount of cash on hand at the beginning and end of the reporting period; 

• The total amount of receipts for the reporting period and for the calendar year;

• The total amount of disbursements for the reporting period and for the calendar year; 

and

• Certain transactions that require itemization on Schedule A (Itemized Receipts) or 

Schedule B (Itemized Disbursements). 52 U.S.C. §30104(b)(1), (2), (3), (4), and (5). 

Facts and Analysis 

A. Facts

During audit fieldwork, the Audit staff reconciled 1199 SEIU’s most recent reported 

financial activity, filed prior to the audit notification, with its bank records for calendar 

years 2019 and 2020. The reconciliation determined that 1199 SEIU’s 2019 beginning 

and ending cash on hand balances were overstated by $161,025. In 2020, 1199 SEIU 

overstated beginning and ending cash on hand balances by $161,025 and $96,649, 

respectively. The cash on hand discrepancies for 2019 and 2020 resulted primarily from 

prior period adjustments as well as minor misstatements for disbursements during 

calendar year 2020.

B. Interim Audit Report & Audit Division Recommendation

The Audit staff discussed the misstatements for 2019 and 2020 with 1199 SEIU 

representatives during the exit conference and provided schedules detailing the 

misstatements. During the exit conference, 1199 SEIU representatives inquired if the 

Audit staff was able to determine the cause of the discrepancies. The Audit staff 

explained that the misstatements stemmed from discrepancies that occurred prior to the 

audit period. In response to the exit conference, 1199 SEIU acknowledged the 

discrepancies between the beginning and ending cash on hand balances on its reports and 

the corresponding amounts on 1199 SEIU’s bank records for 2019 and 2020. 

Additionally, 1199 SEIU explained that these discrepancies have persisted for the past 10 
6

years and it has no reason to believe that the discrepancies were due to wrongdoing. 

Lastly, 1199 SEIU stated it would file a Form 99, “...that corrects these misstatements 

and explains a one-time adjustment of the cash balance on a subsequent periodic report in 

order to reconcile that report, and so future reports as well, with the cash balance.” 

As of this report, 1199 SEIU has not yet filed the Form 99 or made the adjustment to its 

current cash on hand balance. As such, the Audit staff recommends that, within 30 

calendar days of service of this report, 1199 SEIU amend its most recently filed 

disclosure report to correct the cash on hand balance. The Audit staff further 

recommends 1199 SEIU file a Form 995 (Miscellaneous Electronic Submission) with an 

explanation that the cash on hand change resulted from a prior period adjustment. 

Further, 1199 SEIU should reconcile the ending cash on hand balance on its most recent 

report to correct any subsequent discrepancies that may affect the adjustment 

recommended by the Audit staff. 

Finding 2. Reporting of Apparent Independent 

Expenditures

Summary 

During audit fieldwork, the Audit staff reviewed expenditures, totaling $825,663, that 

1199 SEIU disclosed on Schedule B, Line 29 (Other Disbursements). These appear to be 

independent expenditures that contain express advocacy and should have been disclosed 

on Schedule E, Line 24 (Itemized Independent Expenditures). Additionally, of the 

apparent independent expenditures totaling $825,663, the Audit staff identified two 

disbursements, totaling $75,500, for which1199 SEIU may have been required to file 24-

hour reports depending on the date of public dissemination. 

If 1199 SEIU believes that the apparent independent expenditures, totaling $825,663, did 

not require reporting as independent expenditures, the Audit staff recommends that 1199 

SEIU provide documentation to support its conclusion. Absent such documentation, the 

Audit staff recommends that 1199 SEIU amend its reports to disclose these 

disbursements as independent expenditures on Schedule E and submit revised procedures 

for reporting independent expenditures. Lastly, for the two disbursements, totaling 

$75,500, the Audit staff recommends that 1199 SEIU provide documentation to support 

the date of public dissemination for each communication to determine whether 24-hour 

reports were required to be filed. 

Legal Standard 

A. Definition of Independent Expenditures. An independent expenditure is an 

expenditure made for a communication expressly advocating the election or defeat of 

a clearly identified candidate that is not made in cooperation, consultation, or concert 

with, or at the request or suggestion of, a candidate, a candidate’s authorized 

committee, or their agents, or a political party or its agents. 

5 If 1199 SEIU chooses to file a Form 99 instead of amending its disclosure reports, the form must contain 

all pertinent information that is required on each schedule. 
7

A clearly identified candidate is one whose name, nickname, photograph or drawing 

appears, or whose identity is apparent through unambiguous reference, such as “your 

Congressman,” or through an unambiguous reference to his or her status as a 

candidate, such as “the Democratic presidential nominee” or “Republican candidate 

for Senate in this state.”

Expressly advocating means any communication that:

• Uses phrases such as “vote for the President” or “re-elect your Congressman” or 

communications of campaign slogan(s) or individual word(s), which in context can 

have no other reasonable meaning than to urge election or defeat of one or more 

clearly identified candidates; or

• When taken as a whole and with limited references to external events, such as 

proximity to the election, could be interpreted by a reasonable person only as 

advocating the election or defeat of one or more clearly identified candidates. 11 

CFR §§100.16(a), 100.17 and 100.22.

B. Disclosure Requirements – General Guidelines. An independent expenditure shall

be reported on Schedule E if, when added to other independent expenditures made to

the same payee during the same calendar year, it exceeds $200. Independent

expenditures made (i.e., publicly disseminated) prior to payment should be disclosed

as memo entries on Schedule E and as a debt on Schedule D. Independent

expenditures of $200 or less need not be itemized, though the committee must report

the total of those expenditures on Line (b) on Schedule E. 11 CFR 

§§104.3(b)(3)(vii)(C), 104.4(a) and 104.11.

C. 24-Hour Independent Expenditure Reports. Any independent expenditures 

aggregating $1,000 or more, with respect to any given election, and made after the 

20th day but more than 24 hours before the day of an election must be reported and 

the report must be received by the Commission within 24 hours after the expenditure 

is made. A 24-hour report is required for each additional $1,000 that aggregates. The 

24-hour report must be filed on a Schedule E. The date that a communication is 

publicly disseminated serves as the date that the Committee must use to determine 

whether the total amount of independent expenditures has, in the aggregate, reached 

or exceeded the threshold reporting amount of $1,000. 11 CFR §§104.4(f) and 

104.5(g)(2).

D. 48-Hour Independent Expenditure Reports. Any independent expenditure 

aggregating $10,000 or more for an election in any calendar year, up to and including 

the 20th day before an election, must disclose this activity within 48 hours each time 

that the expenditures aggregate $10,000 or more. The reports must be filed with the 

Commission within 48 hours after the expenditure is made. The date that a 

communication is publicly disseminated serves as the date that the Committee must 

use to determine whether the total amount of independent expenditures has, in the 

aggregate, reached or exceeded the threshold reporting amount of $10,000. 11 CFR 

§§104.4(f) and 104.5(g)(1). 
8

E. Allocation of Expenses Between Candidates. Expenditures made on behalf of more 

than one clearly identified federal candidate shall be attributed to each such candidate 

according to the benefit expected to be derived. In the case of a publication or 

broadcast communication, the attribution shall be determined by the proportion of 

space or time devoted to all candidates. This method shall be used to allocate 

payments involving both clearly identified federal candidates and one or more clearly 

identified non-federal candidates. 11 CFR §106.1(a).

Facts and Analysis

A. Reporting of Apparent Independent Expenditures 

1. Facts

During audit fieldwork, the Audit staff reviewed disbursements to ensure proper 

reporting. The Audit staff noted that 1199 SEIU did not disclose these apparent 

independent expenditures on Schedule E, rather the disbursements, totaling 

$825,663, were disclosed on Schedule B, Line 29 and appear to be media related. 

These expenditures were for 126 digital ads, one mailer, one text script and one 

phone script which contain express advocacy. A breakdown analysis for these 

expenditures is as follows:

Apparent Independent Expenditures Reported as Other Disbursements 

(Associated Digital Ads, Mailer, Phone and Text Scripts Invoices Provided 

under 11 CFR §100.22(a))

The purposes on the invoices provided to the Audit staff for these expenditures 

were: paid media campaigns, service fees for campaigns, call hub dialers and text 

tools, and card print for card stock. The digital ads provided to the Audit staff 

contained phrases such as, “Vote Biden-Harris Nov.3,” “Vote Early for BidenHarris Oct.12-30,” “Vote Early for Biden-Harris Oct. 15-31,” “Vote Early for 

Biden-Harris Oct.13 – 30,” “Vote Siegel Nov 3,” and “Vote Ortiz Jones Nov 3.” 

All of these communications contained language expressly advocating the 

election or defeat of a clearly identified candidate, as defined under 11 CFR 

§100.22(a).

2. Interim Audit Report & Audit Division Recommendation

The Audit staff discussed this matter with 1199 SEIU representatives during the 

exit conference and provided a schedule detailing these expenditures. During the 

exit conference, 1199 SEIU representatives requested that the Audit staff explain 

the finding, including how the finding total was derived. The Audit staff 

explained the schedule and the various amounts identified. In response to the exit 

conference, 1199 SEIU stated that, “as the result of an administrative error the 

Committee appears to have disclosed its independent expenditures on line 29.” In 

addition, 1199 SEIU stated that with the exception of two payments to its phone 

6

 There were 12 distinct digital ads, which referenced various early voting periods and the November 3rd

general election date.
9

bank vendor, all expenditures were disclosed on its 24/48-hour reports. 1199 

SEIU further stated that, as recommended by the Audit staff, it will amend its 

reports to disclose all applicable expenditures on Schedule E.

As of the date of this report, 1199 SEIU has not amended its reports to disclose 

the disbursements on Schedule E.

The Audit staff recommends that, within 30 calendar days of service of this 

report, 1199 SEIU provide documentation that apparent independent 

expenditures, totaling $825,663, did not require reporting as independent 

expenditures. Absent such documentation, the Audit staff recommends 1199 

SEIU amend its reports to disclose these disbursements as independent 

expenditures on Schedule E.

B. Failure to File 24-Hour Reports for Apparent Independent Expenditures

1. Facts

In addition to not reporting the apparent independent expenditures during the 

audit period, 1199 SEIU did not file two 24-hour reports, totaling $75,500.7 The 

two disbursements were reported on Schedule B, Line 29, for phone bank scripts 

that contained express advocacy.

2. Interim Audit Report & Audit Division Recommendation

The Audit staff discussed this matter with 1199 SEIU representatives during the 

exit conference and provided the relevant schedules. During the exit conference, 

a representative questioned whether 1199 SEIU filed 48-hour reports for the two 

apparent independent expenditures, totaling $75,500, and the Audit staff 

confirmed that such reports were not filed. In response to the exit conference, 

1199 SEIU stated, with the exception of two payments to its phone bank vendor, 

all expenditures were disclosed on its 24/48-hour reports.

The Audit staff reviewed all 24/48-hour reports filed by 1199 SEIU and maintains 

that 24-hour reports were not filed for the two apparent independent expenditures,

totaling $75,500. Absent documentation that the apparent independent 

expenditures, totaling $75,500, did not require reporting as independent 

expenditures, the Audit staff recommends that, within 30 calendar days of service 

of this report, 1199 SEIU provide documentation to support the date of public 

dissemination for the phone bank scripts to determine whether 24-hour reports

were required to be filed.

7

 The date the expenditure is publicly distributed serves as the date that the independent expenditure is 

made for the purposes of the additional 24/48-hour filing requirements. In the absence of a known date 

for public dissemination, the Audit staff used the invoice date to determine if a 24/48-hour report was 

required.
10

Finding 3. Recordkeeping for Communications 

Summary 

During audit fieldwork, the Audit staff reviewed disbursements for communications to 

verify the accuracy of the information and proper classification of transactions disclosed 

on 1199 SEIU’s reports. The Audit staff identified 17 transactions on 1199 SEIU’s 

24/48-Hour Reports of Independent Expenditures, totaling $1,025,299, with purposes 

including, “digital ads,” “digital ads set up,” “projected digital ad buy” and “projected 

staff compensation for phone banking.” Documentation provided by 1199 SEIU was 

insufficient to verify proper reporting. The Audit staff recommends that 1199 SEIU 

provide the necessary information from which the reported disbursements, totaling 

$1,025,299, may be verified or explained. Such records may include worksheets 

demonstrating how 1199 SEIU allocated the expenditure on behalf of each clearly 

identified candidate for Federal office, copies of invoices and identification of the 

associated communication, and, if the communication has been provided, information 

associating each communication with an invoice(s). 

Legal Standard 

A. Formal Requirements Regarding Reports and Statements. Each political 

committee shall maintain records with respect to the matters required to be reported 

which shall provide in sufficient detail the necessary information and data from which 

the filed reports may be verified, explained, clarified, and checked for accuracy and 

completeness. 11 CFR §104.14(b)(1).

B. Preserving Documents. Committees must preserve these records for 3 years after a 

report is filed. 52 U.S.C §30102(d). 

Facts and Analysis 

A. Facts

During audit fieldwork, the Audit staff reviewed disbursements for communications to 

verify the accuracy of the information and proper classification of transactions disclosed 

on the reports. 1199 SEIU disclosed 17 transactions, totaling $1,025,299, for which 

documentation was insufficient to make a determination pertaining to whether these 

disbursements were correctly reported. 

The Audit staff’s analysis resulted in the following: 

Disbursements – Insufficient Documentation ($1,025,299) 

1199 SEIU reported 17 transactions, totaling $1,025,299, on 24/48 Hour Reports of 

Independent Expenditures with purposes including, “digital ads,” “projected digital ad 

buy,” and “digital ads setup.” The 17 transactions include one 48-hour report that 1199 

SEIU disclosed with an amount of $0 and a purpose of, “projected staff compensation for 

phone banking” and the vendor as 1199 SEIU United Healthcare Workers East. Without 

sufficient documentation, the Audit staff is unable to verify the reporting of these 

transactions as filed on the 24/48-Hour Reports of Independent Expenditures. The Audit 
11

staff requested copies of the communications, invoices and supporting documentation for 

the 17 transactions, totaling $1,025,299. As of the date of this report, 1199 SEIU has not 

provided documentation that would allow the Audit staff to verify whether the 

transactions were reported correctly.

B. Interim Audit Report & Audit Division Recommendation

The Audit staff discussed this matter with 1199 SEIU representatives during the exit 

conference and provided a schedule of the transactions for which further records were 

necessary to verify the accuracy of 1199 SEIU’s reporting. During the exit conference, 

1199 SEIU representatives inquired about the documentation provided for the identified 

amounts, totaling $1,025,299. The Audit staff explained that 1199 SEIU did not provide 

any documentation to show which ads were run and the costs associated with the ads. 

An 1199 SEIU representative also inquired about the identified discrepancy between the 

amount reported for one media vendor and the actual amount that cleared the bank. The 

Audit staff explained that 1199 SEIU over reported the 24/48-hour reports to one vendor 

by $176,7208

.

In response to the exit conference, 1199 SEIU stated that, during the 2020 election cycle, 

it filed 24/48-hour reports “disclosing over $2.5 million in projected and actual 

expenditures to [its digital media vendor] for setup placement of digital advertising.” 

1199 SEIU stated that this amount is consistent with the digital media vendor’s invoices 

and the payments made to this vendor. 1199 SEIU also stated its digital media vendor 

tracked the projected and ultimate cost for the 24/48-hour reports and that it relied on the 

digital media vendor “...to maintain updated, detailed breakdowns of its ad spending.” 

1199 SEIU stated that it has inquired with the digital media vendor for additional 

documentation supporting the reported allocation of costs for the digital ads, and the 

digital media vendor has none. If its media vendor does produce documentation for the 

ads, 1199 SEIU stated that it will forward the documentation to the Audit Division.

In response to 1199 SEIU’s assertion that it filed 24/48-hour reports disclosing over 

$2,500,000 in “projected and actual expenditures” to its digital media vendor, the Audit 

staff reviewed the 24/48-hour reports filed by 1199 SEIU for the 2020 election cycle and 

maintains that 1199 SEIU filed 24/48-hour reports, totaling $1,777,962, for the 2020 

election cycle. 1199 SEIU did not provide the Audit staff with documentation that 

supported its assertion that $2,500,000 in 24/48-hour reports were filed for the 2020 

election cycle.

The Audit staff recommends that, within 30 calendar days of service of this report, 1199 

SEIU provide, in sufficient detail, documentation that allows for verification of proper 

reporting for the communication disbursements, totaling $1,025,299. This 

documentation should include copies of invoices, scripts, documentation from the digital 

media vendor, associated communications, as well as information associating each 

communication with an invoice(s) and documentation. In addition, 1199 SEIU should 

8 1199 SEIU reported $1,691,721 in transactions on its 24/48-hour reports to its digital media vendor; 

however, only $1,515,000 cleared its bank account, which is an overreported difference of $176,721.
12

provide documentation to support the 48-hour report from 1199 SEIU United Healthcare 

Workers East filed on November 3, 2020, totaling $0.