To help ensure that the Health Care System has the information it needs to comply with state regulations regarding public disclosure of the disposition of event tickets, the Health Care System should develop and implement a policy and written procedures for tracking its distribution of event tickets. The procedures should ensure that the Health Care System follows state requirements for making pertinent public disclosures.
The Health Care System amended its community funding policy to specify that it will distribute any tickets and passes it receives in accordance with state regulations. It also developed a gift, ticket, and honoraria policy to ensure, among other things, that the distribution of tickets or passes by the Health Care System is in furtherance of a public purpose, such as promoting health, and that it complete and submit to the Fair Political Practices Commission required documentation for the distribution of each ticket or pass.
Included in the Health Care System's community funding policy is a policy regarding the disposition of event tickets. The policy specifies that when the Health Care System receives tickets or other benefits in response to providing community funding, the benefits shall be provided to the Salinas Valley Memorial Hospital Foundation (foundation). The policy also indicates that the foundation is responsible for maintaining all records related to the distribution of all tickets and benefits. However, it does not appear that the Health Care System's policy regarding ticket disposition is adequate to ensure it complies with applicable state reporting requirements because, among other things, the policy does not ensure that the Health Care System's provision of tickets to the foundation will be publicly disclosed. (See 2013-406, p. 86)
Agency responses received after June 2013 are posted verbatim.