IN THE EXECUTIVE ETHICS COMMISSION
OF THE STATE OF ILLINOIS
IN RE:

JOHN BALDWIN
and
EDWIN BOWEN

)
)
)

OEIG for the Agencies of the
Illinois Governor
Case #17-01266

PUBLICATION OF REDACTED VERSION OF OEIG FINAL
REPORT
Below is the redacted final summary report from an Executive Inspector General. The
General Assembly has directed the Executive Ethics Commission (Commission) to redact
information from this report that may reveal the identity of witnesses, complainants or informants
and “any other information it believes should not be made public.” 5 ILCS 430/20-52(b).
The Commission exercises this responsibility with great caution and with the goal of
balancing the sometimes-competing interests of increasing transparency and operating with
fairness to the accused and others uninvolved. To balance these interests, the Commission may
redact certain information contained in this report. Additionally, the Commission redacts certain
information that relates to allegations against a person who was found not to have committed a
violation. The redactions are made with the understanding that the subject or subjects of the
investigation have had no opportunity to rebut the report’s factual allegations or legal conclusions
before the Commission. Further, in publishing the below redacted final summary report, the
Commission makes no finding of law or fact for or against any individual or entity referenced
therein.
The Commission received this report from the Governor’s Office of Executive Inspector
General (“OEIG”) and a response from the agency in this matter. The Commission, pursuant to
5 ILCS 430/20-52, redacted the final report and mailed copies of the redacted version and
responses to the Attorney General, the Executive Inspector General for the Governor, and John
Baldwin and Edwin Bowen’s last known addresses.
The Commission reviewed all suggestions received and makes this document available
pursuant to 5 ILCS 430/20-52.

Office of the Executive Inspector General
for the Agencies of the Illinois Governor
Summary Report
I.

ALLEGATIONS AND EXECUTIVE SUMMARY

On June 26, 2017, the Office of Executive Inspector General (OEIG) received an
anonymous complaint alleging that employees at the Illinois Department of Corrections’ (IDOC)
Pinckneyville Correctional Center improperly raised funds for the Employee Benefit Fund (EBF),
including through sales of items purchased from Pinckneyville EBF Committee Chair [IDOC
Employee 3]’s friends. In addition, the complaint alleged that the Pinckneyville EBF accepts
donations from businesses and encourages employees to do business with entities that made
donations. The complaint also alleged that Pinckneyville EBF Committee members perform EBF
activities during their State work hours. 1
Early in the investigation, the OEIG learned that all IDOC Correctional Centers and
IDOC’s central administrative office have their own EBFs, and the issues raised in the complaint
may not have been unique to the Pinckneyville EBF. Therefore, the OEIG expanded the
investigation to examine the EBFs in three additional facilities, as well as IDOC’s oversight of the
EBFs statewide. Specifically, investigators reviewed documents such as EBF transaction records,
EBF Committee meeting minutes, and emails; investigators also interviewed EBF Committee
Chairs and various IDOC administrators.
The investigation revealed that although IDOC’s Administrative Directives limit the
primary source of the EBFs’ revenues to profits from vending machines and the employee
commissaries, most of the EBFs have expanded their revenue streams by generating large sums of
money from fundraising. These expansive fundraising efforts, in turn, have led to various
problematic practices, including soliciting donations from local businesses without ensuring that
they are not State vendors, improperly holding raffles, selling merchandise in a way that evades
statutory and IDOC limitations, and devoting large amounts of State time to EBF activities. In
addition, the investigation discovered that the EBFs spent much of the funds they raised on
employee entertainment, such as parties, meals, cash prizes and awards; in some cases, they spent
their funds in ways that benefit only a select few employees. The EBFs also improperly used
inmate labor for their fundraisers.
The investigation further revealed that the EBFs at each facility operate independently,
with little to no oversight, whether through audits, implementation of clear policies and
procedures, training, or otherwise. Moreover, the expansion of the EBFs’ revenue sources, and the
resultant problematic practices, have been sanctioned or encouraged by high-level IDOC
managers. The EBF system, as it stands, leaves IDOC open to fraud, waste, and abuse.
II.

1

BACKGROUND

[The Commission exercises its discretion to redact this footnote pursuant to 5 ILCS 430/20-52(b).]

1

IDOC houses inmates in 25 adult Correctional Centers statewide, in addition to operating
boot camps, work camps, and Adult Transition Centers. 2 IDOC employs approximately 11,600
staff members statewide and is responsible for overseeing nearly 44,400 adult inmates and
supervising approximately 28,000 parolees.3 IDOC’s administrative offices are located at its
central office in Springfield. The following organizational chart shows some of the relevant IDOC
administrative employees at the time of this investigation, and the relationship between the central
office and the Correctional Centers: 4
Acting Director
John Baldwin
Springfield Central Office
Chief of Staff
Edwin Bowen
Springfield Central Office

-

-

[Identifying Information
Redacted]
[IDOC Senior Staff
Employee 1]
Springfield Central Office

I

[Identifying Information
Redacted]
[IDOC Employee 1]
Springfield Central Office

25 Adult
Correctional
Centers

By Administrative Directive, IDOC permits its facilities to establish EBFs, which are
defined simply as funds used for the benefit of employees. 5 The Directive cites 730 ILCS 5/3-22 and 5/3-4-3 as authority for permitting its facilities to establish EBFs. 6 Those statutory
provisions do not specifically authorize the establishment of EBFs, but give IDOC the power to
administer IDOC funds7 and require:
Forty percent of the profits on sales from commissary stores shall be expended by
[IDOC] for the special benefit of committed persons . . ., for the special benefit of
2

https://www2.illinois.gov/idoc/aboutus/Pages/IDOCOverview.aspx (last visited Oct. 2, 2018). For the sake of
consistency, this report refers to these different types of entities collectively as “facilities.”
3
https://www2.illinois.gov/idoc/aboutus/Pages/IDOCOverview.aspx (last visited Oct. 2, 2018).
4
The OEIG learned that as of November 1, 2018, IDOC Chief of Staff Edwin Bowen was hired into a Personnel
Code-covered position as Supervisor of Jail and Detention Standards at IDOC. For the sake of consistency and clarity,
this report will refer to him as the Chief of Staff.
5
IDOC Admin. Directive 02.43.101(I)(B) & (II)(D) (2001).
6
IDOC Admin. Directive 02.43.101(I)(A) (2001).
7
See 730 ILCS 5/3-2-2(1)(k).

2

employees, and for the advancement or reimbursement of employee travel,
provided that amounts expended for employees shall not exceed the amount of
profits derived from sales made to employees by such commissaries, as determined
by [IDOC].8
IDOC’s central office and all of IDOC’s Correctional Centers have EBFs; two Adult
Transition Centers and a Life Skills Re-Entry Center also have them. The EBFs fund various
activities for IDOC employees, such as holiday parties and cookouts. The EBFs also make funeral
donations, fund gifts for retiring employees, purchase equipment for employee gyms, and
contribute to charities. In Fiscal Year (FY) 2017, the EBFs collectively took in nearly $1 million
systemwide.
III.

INVESTIGATION
A.

Documentation Of EBF Revenues And Expenditures

The OEIG interviewed IDOC [Identifying Information Redacted] [IDOC Employee 1]
about how EBF revenues and expenditures are documented.9 [IDOC Employee 1] began working
for IDOC as a [Identifying Information Redacted] in [Identifying Information Redacted] and has
been the [Identifying Information Redacted] at IDOC since [Identifying Information Redacted].
Her duties include overseeing IDOC’s locally held funds, including the EBFs.
[IDOC Employee 1] explained that IDOC’s central accounting database is the Fund
Accounting Commissary Trading System (FACTS). She said that transactions related to local
funds such as the EBFs, including the EBFs’ receipts, disbursements, and other information, are
recorded in FACTS.10 She said that the staff at each individual facility enter their EBFs’
transactions into FACTS, and that while certain fields in the system are required, individuals may
categorize transactions or fill in descriptions of transactions differently. [IDOC Employee 1] said
that approximately 5 to 15 staff members at each facility may have access to their own facility’s
information in FACTS, and that she ([IDOC Employee 1]) and other accountants in the central
office, as well as information technology staff, have access to all the facilities’ information in the
system. She said that data in FACTS are used to prepare various reports, including quarterly
reports of cash balances, receipts, and disbursements that are submitted to the Comptroller’s
Office.
B.

Sources Of Revenue For The EBFs Statewide

Initially, the OEIG examined the EBFs’ revenue sources. In addition to the above statutory
requirement that IDOC use a portion of the profits from commissary sales to benefit employees,
IDOC’s Administrative Directives require that the “[p]rimary sources of revenue” for the EBF
shall be:
8

See 730 ILCS 5/3-4-3(c) (emphasis added).
[IDOC Employee 1] was initially interviewed on March 26, 2018, and the OEIG subsequently had multiple followup conversations with her between March 29 and November 8, 2018.
10
IDOC’s Administrative Directives require benefit fund receipts to be posted to the appropriate Cash Receipts Journal
in FACTS; invoices are also entered into FACTS. IDOC Admin. Directive 02.43.103(II)(E) (2000).
9

3




“profits from vending machines,” and
“disbursement of profits from the Employees’ Commissary Fund.” 11

IDOC is required to deposit the profits of employee vending machine sales into the Employee
Commissary Fund.12 Not all facilities have an employee commissary; if a facility does not
maintain an Employee Commissary Fund, the vending machine profits shall be deposited directly
to the EBF.13
The OEIG obtained a spreadsheet from IDOC that identified the amount of money received
by each EBF from vending machines, employee commissaries, and other sources, from FY 2012
through FY 2017. Investigators interviewed IDOC [Identifying Information Redacted] [IDOC
Employee 2], who prepared the spreadsheet.14 [IDOC Employee 2] explained that he created the
spreadsheet by compiling several different reports, using data from FACTS. He said he identified
the vending machine revenues because they are itemized in the system, and that he identified the
commissary revenues through documentation in the system of transfers in and out of the employee
commissary; he said the revenues from other sources were any revenues that remained.
As detailed in the chart on the following page, the data presented in the spreadsheet show
that between FY 2012 and FY 2017, the EBFs’ systemwide revenues came largely from sources
other than profits from vending machines and commissary sales:

11

IDOC Admin. Directive 02.43.101(II)(E)(2) (2001).
IDOC Admin. Directive 02.44.110(II)(E)(2)(b) (2004).
13
See IDOC Admin. Directive 02.85.101(I)(B) (2000) (retrieved from the OEIG library) (IDOC “may provide
appropriate facilities necessary for the operation of an Employees’ Commissary”) and IDOC Admin. Directive
02.44.110(II)(E)(2)(b) (2004).
14
[IDOC Employee 2] was interviewed on May 7 and November 8, 2018.
12

4

Sources of IDOC EBF Revenues Systemwide
Revenue
Source
Vending
Machines
and
Commissary

FY12

FY13

FY14

FY15

FY16

FY1715

$180,127
(25%)

$190,222
(27%)

$194,691
(30%)

$225,032
(26%)

$201,500
(24%)

$188,979
(20%)

Other

$530,998
(75%)

$513,939
(73%)

$457,381
(70%)

$630,753
(74%)

$647,560
(76%)

$771,008
(80%)

Total
Revenues

$711,125

$704,161

$652,072

$855,785

$849,060

$959,987

These sources of IDOC EBF revenue figures listed above are also depicted in the following bar
graph comparing the vending machine/commissary revenue amounts with the amount of all other
revenue collected:
IDOC EBF Revenues
900000
800000
700000
600000
500000
400000
300000
200000
100000
0
FY 2012

FY 2013
■

FY 2014

FY 2015

Vending Machine/Commissary Revenues

15

■

FY 2016

FY 2017

Other Revenues

[IDOC Employee 1] later advised the OEIG that the data provided regarding Menard Correctional Center’s EBF
revenues for FY 2017 reflected an accounting error where $147,000 of Inmate Benefit Fund money was accidentally
credited into the EBF and later debited back to the Inmate Benefit Fund. Accordingly, the OEIG subtracted $147,000
from the “Other” amount for FY 2017 in this chart and the graph below.
In addition, [IDOC Employee 1] later clarified that the data provided for the EBFs at the Centralia Correctional
Center and the Springfield central office may include revenues received by the “Together Encouraging the
Advancement of Morale Statewide” (TEAMS) initiative. In his August 27, 2018 interview, IDOC Chief of Staff
Edwin Bowen told investigators that he started TEAMS shortly after he became Chief of Staff in mid-2015, that
TEAMS funds were initially housed at the Springfield central office, and that they moved to Centralia in late 2015 or
early 2016. Mr. Bowen said that IDOC was in the process of “phasing out” TEAMS, and that TEAMS had not held
a fundraiser in at least one year.

5

The data in the spreadsheet reflected that in FY 2017, 25 of the 29 EBFs derived over half
of their revenues from sources other than vending machine profits and commissary sales.
Moreover, as shown in the chart below, 10 of the 29 EBFs derived over 90% of their revenues
from sources other than vending machine profits and commissary sales in FY 2017: 16
EBFs with Non-Vending/Commissary Revenues Over 90% of All Revenues
FY 2017
Facility
% of Revenues from
% of Revenues from
Total Revenues
Vending Machines or
Other Sources
Employee Commissary
Big Muddy
1%
99%
$14,231
Centralia
7%
93%
$43,857
Fox Valley17
0%
100%
$1,133
Jacksonville
5%
95%
$32,291
5%
95%
$6,883
Kewanee18
Pinckneyville
1%
99%
$44,167
Sheridan
8%
92%
$43,787
Southwestern
5%
95%
$19,396
19
3%
97%
$163,529
Springfield
Vandalia
4%
96%
$37,349

In her OEIG interviews, [IDOC Employee 1] told investigators that she understands the
IDOC Administrative Directive’s requirement regarding the EBFs’ “[p]rimary sources of revenue”
to mean that the majority of the EBFs’ funds should come from vending machine and commissary
profits. However, [IDOC Employee 1] said she believed the EBFs’ fundraising efforts, such as
sales of raffle tickets and other items, provided greater revenue than vending machine and
commissary profits, and that vending machine and commissary profits were not the primary
sources of revenue at any facility. According to [IDOC Employee 1], the operation of vending
machines and the employee commissary do not require the use of IDOC staff resources because
the vending machines are serviced by vendors and the employee commissaries are run by inmates.
Investigators also interviewed [IDOC Employee 1]’s supervisor, [IDOC Senior Staff
Employee 1], who has been IDOC’s [Identifying Information Redacted] since [Identifying
Information Redacted].20 [IDOC Senior Staff Employee 1] said that the EBFs have become more
prevalent because IDOC’s current administration is pushing to improve employee morale. He said
he believes the EBFs raise money through the employee commissary, vending machines, and sales
of raffle tickets and other items such as t-shirts.
C.

Additional Issues Identified With Revenue Sources At Selected EBFs

16

A chart showing the FY 2017 amounts and percentage breakdowns for all EBFs is attached in Appendix A.
Fox Valley is an Adult Transition Center.
18
Kewanee is a Life Skills Re-Entry Center.
19
“Springfield” refers to the EBF at IDOC’s central office, which is not a prison. IDOC employees sometimes call
this the “Concordia” EBF because the office is located on Concordia Court, in Springfield. For the sake of consistency,
this report will refer to it as the Springfield EBF.
20
[IDOC Senior Staff Employee 1] was interviewed on February 14, 2018.
17

6

Given that most of the EBFs largely obtain their revenues from sources other than
commissary and vending machine profits, investigators further examined a selection of EBFs and
identified additional problems with the EBF practices taking place at those facilities. Specifically,
the OEIG examined the revenue sources at the Pinckneyville, Sheridan, and Dixon Correctional
Centers’ EBFs; and the Springfield central office’s EBF. As shown in the chart below, the numbers
of employees that potentially benefit from these EBFs’ revenues range from about 300 employees
at the Springfield central office to about 644 employees at Dixon Correctional Center.
Facility
Pinckneyville
Sheridan
Dixon
Springfield

Number of Employees
418
379
644
300

Number of Inmates
1,98721
1,73222
2,20023
0

Investigators obtained FACTS records for the selected EBFs from January 2016 through
July 2017, as well as some EBF Committee meeting minutes and emails of some EBF Committee
Chairs. Investigators also interviewed the following Chairs of the Pinckneyville, Sheridan, Dixon
and Springfield EBFs:
[IDOC Employee 3] Pinckneyville Correctional Center EBF Chair 24
[IDOC Employee 4] Sheridan Correctional Center EBF Chair 25
[IDOC Employee 5] Dixon Correctional Center EBF Chair 26
[IDOC Employee 6] Springfield Central Office EBF Chair 27
The records and interviews revealed that the EBFs received revenues from a variety of fundraising
activities, including donations, raffle ticket sales, and sales of merchandise and food.
1. Revenues from Donations and Sponsorships

21

https://www2.illinois.gov/idoc/facilities/Pages/pinckneyvillecorrectionalcenter.aspx (last visited Oct. 2, 2018).
https://www2.illinois.gov/idoc/facilities/Pages/sheridancorrectionalcenter.aspx (last visited Oct. 2, 2018).
23
https://www2.illinois.gov/idoc/facilities/Pages/dixoncorrectionalcenter.aspx (last visited Oct. 2, 2018).
24
[IDOC Employee 3] was interviewed on July 14, 2017 and June 29, 2018. She said she is a [Identifying Information
Redacted] at Pinckneyville Correctional Center, and that she was the Pinckneyville EBF Committee Chair from before
[Identifying Information Redacted] to [Identifying Information Redacted]. She explained that she stepped down from
the EBF Committee Chair position because [Identifying Information Redacted].
25
[IDOC Employee 4] was interviewed on July 27, 2018. She said she is the Sheridan [Identifying Information
Redacted], and that she has been the Sheridan EBF Committee Chair for [Identifying Information Redacted].
26
[IDOC Employee 5] was interviewed on August 7, 2018. She said she is a [Identifying Information Redacted], and
that she has been the Dixon EBF Committee Chair for [Identifying Information Redacted].
27
[IDOC Employee 6] was interviewed on July 13, 2018. He said he has been [Identifying Information Redacted] in
the Springfield central office for [Identifying Information Redacted], and that he has been the Springfield EBF
Committee Chair for [Identifying Information Redacted].
22

7

Because soliciting State or IDOC vendors for donations could create a conflict of interest, 28
the OEIG attempted to determine the extent to which the EBFs solicit donations from local
businesses, and what steps IDOC takes to ensure that State vendors are not solicited. In response
to an OEIG request for donor and donation information for the EBFs, IDOC did not produce any
lists or other records maintained by the EBFs of donors to the EBFs or the donations the EBFs
received. Instead, IDOC searched FACTS for keywords such as “donation,” “donor,” “gift,”
“contribution,” and “Employee Benefit Fund.” Based on that search, IDOC identified only a
limited number of donations, which may or may not have been donations to the EBF from a
potential vendor or business.29
When asked if there is any way to track donations to the EBFs, [IDOC Employee 1] said it
depends on how the entries are coded in the system. As noted above, [IDOC Employee 1] said
that each facility may enter information into FACTS differently. She explained that many facilities
will indicate in FACTS that a transaction was a donation but fail to attach any specific detail to it,
and other facilities will put nothing at all. [IDOC Employee 1] said that IDOC does not have an
accurate donor list, and that without one, the EBFs have to be trusted to ensure that there are no
conflicts of interest with the donations they accept. Similarly, [IDOC Senior Staff Employee 1]
said that under the current system, it would be impossible to compile a list of donors to the EBFs.
Pinckneyville EBF
The OEIG reviewed the FACTS records of the Pinckneyville EBF’s transactions and
determined that it received a total of approximately $2,300 in March and April 2017 for
transactions variously described as “5K Sponsors,” “5K Sponsors & Entries,” “5K
Sponsors/Entries,” and “5K Sponsors/Registrants.”30 Only one of these entries identified the
sponsors.
The OEIG also reviewed emails sent to and from Pinckneyville EBF Committee Chair
[IDOC Employee 3]’s State email account in the first half of 2017, and identified various
communications relating to the Pinckneyville EBF’s efforts to solicit donations in the community.
For example, the emails reflected that [IDOC Employee 3] wrote to a City of Pinckneyville
employee on April 28, 2017: “Attached is the required insurance policy for our 5K in June. . . The
City of DuQuoin has requested to sponsor us, so I wanted to be sure and include Pinckneyville, if
they so wish. I’ve attached a sponsorship form for review . . . .” 31
In addition, in at least one email, Pinckneyville EBF staff reminded a potential sponsor of
IDOC’s significant role in the local community and noted that Pinckneyville Correctional Center

28

Depending on the circumstances, EBF solicitations also could violate the gift ban prohibition in the State Officials
and Employees Ethics Act. See 5 ILCS 430/1-5 & 10-10 (prohibiting State employees from “intentionally solicit[ing]
or accept[ing] any gift from any prohibited source,” including people or entities that do business or seek to do business
with the employee’s State agency).
29
Due to the type of keyword search conducted, the search results could include donations from the EBFs, as well as
donations to the EBFs.
30
Other entries describe transactions merely as “5K,” but do not indicate whether these revenues were from
sponsorships, race registration fees, or something else.
31
It does not appear that the City of Pinckneyville sponsored the race.

8

employees were encouraged to support sponsors. As Pinckneyville EBF member [IDOC
Employee 7] wrote a representative of [IDOC Sponsor 1] on March 27, 2017:
I am sending this out seeking participants and/or sponsors for our upcoming 5K
run/walk on June 17th, 2017 . . . With over 470 employees, we believe we are the
largest employer in Perry County32 . . . We would appreciate your consideration in
becoming a sponsor and/or participant in our event this year. We highly encourage
our staff here at our facilities to support the businesses, organizations and
individuals who also support them.
According to the emails, [IDOC Sponsor 1] subsequently agreed to donate $300 to sponsor the
Pinckneyville EBF’s 5K race.
The records also reflect that [IDOC Employee 3] encouraged Pinckneyville employees to
support the EBF’s sponsors in return. For example, in a June 16, 2017 email sent to Pinckneyville
and DuQuoin Work Camp employees prior to the 2017 5K race, [IDOC Employee 3] wrote:
[W]e encourage everyone to stop and read through the list of sponsors that have
been gracious enough to support our EBF. These are local businesses that
recognize the dedication that is put forward into all of our jobs. EBF is prepared to
step in to help employees during their time of crisis, but to do so, we must have
fundraisers, such as these. It’s these businesses, that help cover race costs and
necessities, that allow us to raise funds to put towards our EBF. Any gratitude that
we can show to them in return is appreciated.
The documents reflect that 22 businesses and governmental entities sponsored the
Pinckneyville EBF’s 2017 5K race.33 Investigators reviewed information available on the Illinois
Comptroller’s website and determined that three of these sponsors were State vendors at the time
the donations were made, although none were IDOC vendors.
In her interviews, [IDOC Employee 3] said that in 2016, she called every business listed in
the Pinckneyville Yellow Pages to solicit donations for the Pinckneyville EBF’s 5K race, and that
in 2017 she contacted the businesses that had donated the previous year. [IDOC Employee 3] said
she made the calls during her work hours. She said that in 2017, Pinckneyville Correctional Center
Personnel employee [IDOC Employee 7] also contacted businesses for donations, including in
DuQuoin, Illinois. [IDOC Employee 3] said the donations were used for the 5K race’s expenses,
and that the Pinckneyville EBF kept the remaining funds. [IDOC Employee 3] said the EBF did
not keep a record of what businesses were solicited, but that she did keep a record of the donations
received.

32

The U.S. Census Bureau estimated the 2017 population of Perry County to be 21,285 and estimated the population
of Pinckneyville to be 5,392. https://www.census.gov/quickfacts/fact/table/perrycountyillinois/PST045217 &
https://factfinder.census.gov/faces/nav/jsf/pages/community_facts.xhtml (last visited Oct. 2, 2018).
33
The EBF Committee’s June 29, 2017 meeting minutes estimated that profits from the 5K race “appear to be 3x that
of last year, due to the increase in business sponsorships.”

9

[IDOC Employee 3] said that none of the sponsors should have been vendors of the
Pinckneyville Correctional Center, IDOC, or the State. [IDOC Employee 3] said that because she
works in [Identifying Information Redacted] she sees paperwork regarding vendors and said she
has vetoed certain suggested sponsorships because she knew they were IDOC vendors. However,
[IDOC Employee 3] said there was no process in place to ensure that the sponsors were not State
vendors.
Investigators asked [IDOC Employee 3] what she meant by her statement in her June 16,
2017 email to Pinckneyville Correctional Center and DuQuoin Work Camp employees that “Any
gratitude that we can show to [the sponsors of the 5K race] in return is appreciated.” [IDOC
Employee 3] said she meant that if the employees saw a sponsor they “might want to thank them,”
but that she was not suggesting that employees should support the businesses.
Other EBFs
Although Springfield EBF Committee Chair [IDOC Employee 6] and Dixon EBF
Committee Chair [IDOC Employee 5] told investigators that they had never solicited donations
from businesses for the Springfield and Dixon EBFs, Sheridan EBF Committee Chair [IDOC
Employee 4] said that in the past, she solicited donations or sponsorships from local businesses for
the Sheridan EBF’s golf outing. Specifically, [IDOC Employee 4] said she contacted businesses
from which the EBF had ordered food in the past, including [IDOC Sponsor 2], [IDOC Sponsor
3], and the [IDOC Sponsor 4]; [IDOC Employee 4] recalled that [IDOC Sponsor 2] made a
donation, but the other two businesses declined to do so. [IDOC Employee 4] said she did not
think the businesses that were solicited were State vendors, but she acknowledged that no one
checked.34 [IDOC Employee 4] estimated that the last time the EBF received a donation or
sponsorship for a golf outing was in 2015.
2. Revenues from Raffle Ticket Sales
The OEIG also examined whether the EBFs improperly raised funds through raffles. The
Raffle and Poker Runs Act limits the types of entities that may receive raffle licenses to:
bona fide religious, charitable, labor, business, fraternal, educational or veterans’
organizations that operate without profit to their members . . . , or to a non-profit
fundraising organization . . . organized for the sole purpose of providing financial
assistance to an identified individual or group of individuals suffering extreme
financial hardship as the result of an illness, disability, accident or disaster, as well
as law enforcement agencies and statewide associations that represent law
enforcement officials . . . . 35

34

Although [IDOC Employee 4] said the EBF had previously done business with these vendors, according to the
OEIG’s review of the Illinois Comptroller’s website, none of these businesses has had a State contract.
35
See 230 ILCS 15/2. In this context, “law enforcement agency” is defined as “an agency of this State or unit of local
government which is vested by law or ordinance with the duty to maintain public order and to enforce criminal laws
or ordinances.” 230 ILCS 15/9.

10

Although the EBFs are IDOC funds, and as such would not appear to qualify to receive a
raffle license under this statute, the investigation revealed that about 21 EBFs obtained raffle
licenses from municipal or county government offices. The OEIG obtained some of the EBFs’
raffle license applications, which reflected that the EBFs certified or otherwise represented on their
applications that they were non-profit organizations; some also checked boxes on the applications
identifying themselves as the types of entities listed in the Raffle and Poker Runs Act, such as
labor or fraternal organizations. All four of the EBF Committee Chairs interviewed in the
investigation stated that their EBFs had held raffles, although [IDOC Employee 6] said the
Springfield EBF had not held one for three or four years. However, the Committee Chairs stated
that the EBFs recently had been directed to stop holding raffles.
[IDOC Employee 4] said that until recently, the Sheridan EBF’s primary source of revenue
was raffles. She said that the Sheridan EBF held four raffles a year, in addition to raffles held at
monthly cookouts, and that the items the EBF raffled off included televisions, iPads and other
electronics, FitBits, lottery tickets, corn hole bean bag sets, patio furniture, and gift cards for guns
and other items. One raffle referenced in the Sheridan EBF transactions records and meeting
minutes was a 2017 “Badge of Cash” raffle, similar to a Queen of Hearts raffle, in which weekly
drawings were held until a winner was drawn. 36 According to [IDOC Employee 4], the Badge of
Cash raffle raised $30,000, which was split equally between the winner and the Sheridan EBF.
3. Revenues from Merchandise Sales
As shown above, it is clear that most of the EBFs’ revenues statewide do not come from
sales made in the employee commissaries. Instead, the investigation revealed that a great deal of
the EBFs’ revenues come from sales of merchandise made outside the commissaries. For example,
the FACTS records and meeting minutes obtained in the investigation showed that the
Pinckneyville, Springfield, Sheridan, and Dixon EBFs raised funds by selling merchandise such
as t-shirts and other clothing, tumblers, keychains, coins, bags, and food. This practice avoids two
types of limits imposed on commissary sales: sales markups at the employee commissaries are
statutorily limited to 10%,37 and IDOC’s Administrative Directives require facilities to accrue only
40% of the net profits from the employees’ commissaries to the EBF. 38 When the EBFs sold
merchandise outside the commissaries, they did not adhere to either of these limits; rather, they
imposed higher markups and retained 100% of the profits.
Pinckneyville EBF
36

The Chicago Tribune described the way this type of raffle works. Each card from a deck is placed in a numbered
envelope. Participants buy raffle tickets and give each ticket a number they guess corresponds with the envelope
containing the Queen of Hearts. One raffle ticket is drawn each week, and if the ticket has the number of the envelope
containing the Queen of Hearts, the ticket holder wins the jackpot. If not, the game continues, with the pot growing
until the ticket with the Queen of Hearts’ envelope number is drawn. Robert McCoppin, “Queen of Hearts raffles
with
big
jackpots
spreading
to
Chicago
bars,”
Chicago
Tribune,
June
25,
2018,
http://www.chicagotribune.com/news/local/breaking/ct-met-queen-of-hearts-raffles-chicago-20180621-story.html
(last visited Oct. 2, 2018).
37
See 730 ILCS 5/3-7-2a.
38
IDOC Admin. Directive 02.44.110(II)(E)(1)(a) (2004). The remainder is distributed to IDOC’s “523 – Salary
Reimbursement Fund.” [IDOC Employee 1] explained that the 523 fund is used for staff salaries and various other
purposes.

11

For example, Pinckneyville EBF Committee Chair [IDOC Employee 3] sent mass emails
to IDOC employees systemwide on November 14, 2016 and June 9, 2017, soliciting orders for
“RED” t-shirts to raise money for the Pinckneyville EBF.39 The t-shirts used “RED” as an acronym
for “Remember Everyone Deployed.” FACTS transactions records show that the Pinckneyville
EBF grossed about $19,200 in sales of RED t-shirts between December 2016 and June 2017, and
incurred about $12,025 in expenses. 40 Minutes of monthly EBF Committee meetings held in 2016
and 2017 commented variously that “RED shirt sales [are] through the roof,” “[t]he response has
been overwhelming,” and “[p]rofits are phenomenal.” [IDOC Employee 3]’s emails indicate that
she processed and fulfilled the RED shirt orders.
In her OEIG interviews, [IDOC Employee 3] confirmed that the Pinckneyville EBF sold
items to raise money for the EBF, including shirts, coins, plants, and food. [IDOC Employee 3]
said that the EBF sold about 1,500 “RED” t-shirts statewide, and that the sales were a “huge
fundraiser for the EBF.” [IDOC Employee 3] said there was no set markup on the RED t-shirts;
she said the EBF charged $12 for a short-sleeve shirt, and $16 for a long-sleeve shirt, and that she
believed the EBF paid between $6 and $8 for each shirt. [IDOC Employee 3] said that all the
proceeds for the RED t-shirt sales went to the Pinckneyville EBF. She said that the EBF has never
sold items through the employee commissary.
Investigators also found that the Pinckneyville EBF’s method of selecting its vendors was
problematic. [IDOC Employee 3] said the Pinckneyville EBF did not use any formal process when
deciding where to purchase the items it sold, and that those decisions were normally made based
on “word of mouth.” When asked how the vendor for the RED shirts ([IDOC Sponsor 5]) was
selected, [IDOC Employee 3] said she made cold calls and [IDOC Sponsor 5] gave decent prices.
[IDOC Employee 3] added that she knows [IDOC Sponsor 5]’s owner, because they are from the
same home town.
Other EBFs
Springfield EBF Committee Chair [IDOC Employee 6] told investigators that the
Springfield EBF’s primary source of revenue is the EBF’s store, which sells IDOC apparel and
other merchandise to employees and the cadets who train at the Springfield campus. [IDOC
Employee 6] said that it was discussed with a prior IDOC Chief Financial Officer whether the EBF
store could be considered to be a commissary, but that it was understood that the store would not
be considered a commissary and would not be limited to a commissary’s 10% markup. He
explained that commissaries are understood to be in facilities that house inmates, and the
Springfield central office does not house inmates. [IDOC Employee 6] said that all the profits
from the EBF store go to the Springfield EBF. 41

39

The IDOC records reflected sales of other types of t-shirts by the Pinckneyville EBF as well.
Because the OEIG requested records through July 2017, these amounts do not include any sales made later.
41
When asked why the Springfield EBF had the highest amount of revenue of all the EBFs, [IDOC Employee 6] noted
that most other facilities do not sell IDOC apparel and merchandise. [IDOC Employee 6] added that the Springfield
EBF’s expenditures for the items it sells in the store were also high.
40

12

[IDOC Employee 6] and the Sheridan and Dixon EBF Committee Chairs maintained in
their interviews that they follow applicable procurement rules and never purchased the items the
EBFs sold from anyone with whom they had a personal or social relationship,
D.

State Time And Resources Spent On EBF Activities

In light of the significant amount of fundraising the EBFs do, investigators examined the
extent to which IDOC employees are spending State time and resources on EBF fundraising
activities and events.
[IDOC Employee 1] said that EBF events used to be held during employees’ lunch time,
but that since 2014 and 2015 employees have been spending an increasing amount of State time
on EBF events. She said that she has received emails indicating that State work could not be done
because an employee was at an EBF event or out purchasing items for the EBF.
[IDOC Senior Staff Employee 1] also said that he thought the work spent on EBF matters
is “substantial.” [IDOC Senior Staff Employee 1] said that on one occasion, an employee
complained to him that staff members spent half a day on a cookout, rather than taking care of the
responsibilities the rest of the team needed to accomplish. He added that business office employees
may have to collect money for the EBFs, create journal entries, determine how to do the taxes, and
set up the events, and that it was “not uncommon” for them to say that the EBFs were “consuming”
their time.
Investigators asked IDOC to produce timesheets for various EBF Committee members, as
well as records relating to overtime approved for EBF activities. However, the timesheets did not
reflect how much State time the employees spent doing EBF activities. According to IDOC, it
approved a total of 35.38 hours of overtime for EBF activities between January and June 2017, at
five facilities, for a total of $1,291.
Pinckneyville EBF
Investigators also examined [IDOC Employee 3]’s emails to assess whether she spent a
significant amount of State time and resources handling Pinckneyville EBF matters. As noted
above, [IDOC Employee 3] sent and received emails regarding the Pinckneyville EBF’s June 17,
2017 5K race. In addition, following her June 9, 2017 mass email to IDOC employees soliciting
RED t-shirt orders, [IDOC Employee 3] sent and received emails in which she took orders,
processed payments, and arranged for deliveries of the shirts. In light of these two significant
Pinckneyville EBF activities that occurred in June 2017, investigators counted the emails [IDOC
Employee 3] sent and received that appeared to reference any EBF work during the month prior
to the June 17, 2017 5K race, whether related to the race, RED t-shirt sales, or other EBF matters.
Based on that review, investigators counted approximately 594 EBF-related emails that [IDOC
Employee 3] sent and received during that month.
In her interviews, [IDOC Employee 3] said that when she was the Pinckneyville EBF
Committee Chair, the time she spent working on EBF matters depended on the event. [IDOC
Employee 3] said that at most, she would spend 10 to 20 hours in a week on EBF activities. [IDOC

13

Employee 3] acknowledged that she spent “a lot” of time working on the RED shirt sales during
her work hours, including taking orders for the shirts, communicating with the supplier, taking
payments, and arranging for deliveries. [IDOC Employee 3] said that all the employees in her
office helped sort the shirts when they arrived. [IDOC Employee 3] said that Pinckneyville EBF
Committee members also helped serve food, make sales, and set up for the 5K race, although she
stated that the employees who set up the 5K race did so on their own time. She said that the
Pinckneyville EBF holds cookouts for employees during State hours, which take a few hours.
Sheridan EBF
Sheridan EBF Committee Chair [IDOC Employee 4] said she does the majority of her work
on the Sheridan EBF during her State work hours. She said the amount of time she spends on EBF
matters varies, but that she generally spent about two hours in a week in which a Sheridan EBF
event is taking place. [IDOC Employee 4] estimated that she spent a week’s worth of time
preparing for employee recognition, including voting on gifts, purchasing gifts, creating a list of
employees to be recognized, and placing orders. In addition, [IDOC Employee 4] said that when
the Sheridan EBF was selling t-shirts several years ago, she spent the equivalent of an entire work
day putting orders together and sorting shirts. [IDOC Employee 4] said the Sheridan EBF used to
hold monthly cookouts from April through October, which took up to two hours to plan; she said
Sheridan EBF Committee members grilled the food for the cookouts, which were held for three
and one-half hours during the first shift and for two hours during the second shift. 42
Dixon EBF
Dixon EBF Committee Chair [IDOC Employee 5] said that many of the Dixon EBF events
are scheduled on her days off, but that when Dixon EBF events such as cookouts are held on days
when she is working, she spends five or six hours in a week working on the events. She said that
Employee Appreciation Week, which takes place each year in May, is the Dixon EBF event that
takes the most time to prepare for. She estimated that ten employees are involved in preparing for
that event, and that each employee spends about 40 hours from January to May, which is mostly
working time, on the preparations.
Springfield EBF
Springfield EBF Committee Chair [IDOC Employee 6] said that he spends one to two
hours working on Springfield EBF matters in a week in which there is an EBF event, and about 10
to 15 minutes working on Springfield EBF matters in a week in which there is no EBF event; he
added that the Springfield EBF does not host many EBF events. He said the Springfield EBF held
four or five cookouts for cadets in 2017, which took place from 11:30 a.m. to 1:00 p.m., with the
Springfield EBF Committee members grilling the food. [IDOC Employee 6] said that there are
more Springfield EBF meetings during the time leading up to the Christmas party, but that
employees use benefit time to set up for the party.

42

[IDOC Employee 4] said she did not know when the cookouts were held for the third shift. She said that as of the
date of her interview, the EBF had only held one cookout in 2018.

14

[IDOC Employee 6] said the Springfield EBF store generally is only open by appointment,
and that if an employee wants to buy an item he or she will call a Springfield EBF Committee
member, who opens the store, makes the sale, and then returns to work. [IDOC Employee 6] said
that he is called to make a sale in the store once or twice for five or ten minutes in a two-week
period. He said that during cadet graduations, the store is open before work hours, and Springfield
EBF Committee members take shifts of up to 30 minutes to make sales. [IDOC Employee 6] said
that another Springfield EBF Committee member handles ordering items for the EBF, and he did
not know how much time she spends doing that task.
E.

EBF Expenditures

In addition to examining the sources of the EBFs’ revenues, the OEIG also examined how
the EBFs spend their funds. IDOC’s Administrative Directives permit facilities to spend EBF
funds for six purposes:
(1) expenditures for which each employee will have a similar opportunity to benefit from
the expenditure;
(2) equipment or recreational items for use by employees;
(3) recreational or entertainment events for the benefit of a significant number of
employees;
(4) a tribute to an employee or an employee’s immediate family;
(5) travel funds; and
(6) charitable contributions to community organizations. 43
IDOC is required to “review and authorize all expenditures from benefit funds”; the EBF
Committees, which are appointed by IDOC’s Chief Administrative Officer, are tasked with this
responsibility.44
[IDOC Employee 1] said that at each individual facility, the EBF Committee members
have control over the EBF, and that it is up to each Committee to decide how to spend EBF funds.
She said that if there is a disagreement within the Committee, the matter would go to IDOC Chief
of Staff Edwin Bowen. She said that the EBFs are cash based, many hands touch the money, and
there is no oversight of the money.
The FACTS records and EBF meeting minutes for the Springfield, Pinckneyville,
Sheridan, and Dixon EBFs revealed that the EBFs spend their money on various events and
activities, including employee parties, employee awards and prizes, food, gifts for retiring
employees, donations, and funeral flowers.

43
44

IDOC Admin. Directive 02.43.102(II)(E)(5) (2000).
IDOC Admin. Directive 02.43.102(I)(B) & (II)(E)(1) (2000).

15

Christmas Parties and Employee Appreciation
For example, the Springfield EBF Committee transaction records referenced various EBF
events, including cookouts, cadet meals, and a Christmas party. Christmas party expenditures in
2016 included a $19,581 payment to a hotel in Springfield, and a total of about $8,000 for prizes.
The transaction records also listed a number of large checks written from the Springfield EBF
account to the Springfield EBF Committee Chair, [IDOC Employee 6]. For example, the records
showed that on November 28, 2016, a check for $6,100 was written to [IDOC Employee 6], with
the description “Christmas Party Cash Prizes.” The records also showed that a $3,000 check was
written to [IDOC Employee 6] on May 4, 2017, with the description “Employee/Officer of the
Year Nominees.”
In his interview, [IDOC Employee 6] said that the Springfield EBF’s employee Christmas
party costs about $30,000 a year, including money spent on the venue, food, beverages, a DJ, and
prizes. He said that usually about 300 people attend, of whom about 150 to 175 are IDOC
employees and the remainder are their guests. In addition to the employee Christmas party, [IDOC
Employee 6] said the Springfield EBF also has spent its funds on items and events such as flowers
for employees who have had a death in the family; plaques for awards; a television, DVD player,
cable, and pasta dinners and cookouts for the cadets on campus; campus beautification;
maintenance of the employee weight room; and free turkeys for Thanksgiving.
[IDOC Employee 6] was asked about the checks for $6,100 and $3,000 that were made out
to him from the EBF account. He explained that the $6,100 check was prize money for the
Christmas party; he said the cash from the check was stuffed into envelopes and distributed to
prizewinners at the party, who signed receipts for the amounts. He said the $3,000 check was for
awards given to the Employee of the Year and nominees for that award; he said there were also
receipts for those awards. [IDOC Employee 6] explained that EBF Committee members do not
have access to the EBF account or have check-signing privileges, and that the “workaround” to
get the money for the prizes and awards was to write the checks to an EBF member. He said this
was not the best practice, looked bad on paper, and made him uncomfortable.
Sheridan EBF Committee Chair [IDOC Employee 4] also said that until recently, the
Sheridan EBF’s largest expenditures were for employee Christmas parties, as well as employee
recognition gifts; she said that the last Christmas party was held in 2015, and that the EBF paid for
the alcohol, which cost about $1,500. Pinckneyville EBF Committee Chair [IDOC Employee 3]
said that the Pinckneyville EBF’s largest expenditure was for Employee Appreciation Week, which
involves catered meals and other food, and free soda; [IDOC Employee 3] said the EBF spends
about $4,000 on this event. She said the Pinckneyville EBF also spends its funds on funeral
flowers, plaques for retiring employees, Employee of the Month and Year awards, and Christmas
parties, among other things. Dixon EBF Committee Chair [IDOC Employee 5] said the Dixon
EBF’s largest expenditures were for Employee Recognition Week, Christmas parties, and Easter
egg hunts. She said that during Employee Recognition Week in 2017, the EBF provided a meal
every day, and gave out gift cards to be used in the employee commissary.
Golf Outings

16

Although IDOC’s Administrative Directives require EBF expenditures for recreational or
entertainment events to benefit a significant number of employees, some EBF expenditures
referenced in the documents obtained from IDOC were for activities that appeared to have
benefitted only a small number of employees. For example, the records reflect that the
Pinckneyville EBF paid $150 to cover half of a $300 fee for a team to play in Menard Correctional
Center’s K4 Open Golf Scramble in June 2017. 45 [IDOC Employee 3] noted in a May 26, 2017
email to IDOC employee [IDOC Employee 8]: “I know our team from last year had contacted the
Warden asking for the $300 sponsorship to be paid again . . . .” According to a flyer for the event,
the fee included 18 holes of golf, the use of a golf cart, a meal, and awards.
[IDOC Employee 3] confirmed in her interview that the Pinckneyville EBF paid half the
fee to send a team to play in Menard Correctional Center’s golf event. According to [IDOC
Employee 3], the Warden posted a flyer to put together a team on a first-come, first-serve basis,
but said she was not aware if employees other than the four selected for the team were given an
opportunity to attend the event. [IDOC Employee 3] said she viewed the expenditure as a
charitable donation to support another facility’s EBF, rather than simply benefitting the four
employees who participated. [IDOC Employee 3] said the Warden made the final decision for the
EBF to pay half the fee.
Similarly, the FACTS records also referenced a Dixon EBF expenditure of $320 on August
19, 2016 for “[Golf Event Sponsor 1] Director’s Golf Outing Fees,” and a Springfield EBF
expenditure of $640 on August 16, 2016, for two “9/1/16 [Golf Event Sponsor 1] Golf Outing
Sponsorship[s].”
When asked about the Dixon EBF’s $320 expenditure for golf outing fees, [IDOC
Employee 5] said the IDOC Director’s golf outing is a mandatory recurring expenditure that is
made regardless of the EBF Committee’s approval. She said that such mandatory expenditures
usually are communicated from the IDOC Director’s office to the Wardens, and that the Dixon
accounting office notifies her. [IDOC Employee 5] said that a notice is posted seeking volunteers
to participate; however, she said she did not know how the participants were selected. [IDOC
Employee 6] acknowledged that the Springfield EBF had sponsored two teams to attend [Golf
Event Sponsor 1]’s golf outing in 2016 and 2017 and said that the participants were chosen through
a blind drawing of names of people who expressed interest, in response to an email that was sent
to all employees.
F.

Use Of Inmate Labor

The investigation also revealed that many EBFs use inmate labor for fundraising events
such as car washes and shoe shining events. However, the Unified Code of Corrections strictly
limits the types of work IDOC may have inmates perform:
The Department shall provide inmate workers for Illinois Correctional Industries
to work in programs established to train and employ committed persons in the
production of food stuffs and finished goods and any articles, materials or supplies
45

The records also reflect that in 2016, the Pinckneyville EBF paid $150 to Menard for half of a golf entry fee and
paid $320 for an entry fee for an [Golf Event Sponsor 1] golf outing.

17

for resale to State agencies and authorized purchasers. It may also employ
committed persons on public works, buildings and property, the conservation of
natural resources of the State, anti-pollution or environmental control projects, or
for other public purposes, for the maintenance of the Department’s buildings and
properties and for the production of food or other necessities for its programs. The
Department may establish, maintain and employ committed persons in the
production of vehicle registration plates. A committed person’s labor shall not
be sold, contracted or hired out by the Department except under this Article.46
Because using inmates for a non-public purpose, such as assisting employee fundraisers, would
violate this statutory limitation, the OEIG examined the EBFs’ practice of using inmate labor.
The OEIG obtained a spreadsheet from IDOC that showed revenues received by the EBFs
from FY 2016 through the second quarter of FY 2018 from fundraisers that used inmate labor. In
her interviews, [IDOC Employee 1] explained that the data presented in the spreadsheet was
compiled by searching FACTS for revenues from the types of services that inmates typically
provide, such as car washes, shoe shines, haircuts, and wood and plant sales. According to the
spreadsheet, 18 facilities held fundraisers using inmate labor from FY 2016 through the second
quarter of FY 2018, which brought in a total of about $56,300. [IDOC Employee 1] told
investigators that the inmates receive their normal inmate pay for this work. 47
IDOC [Identifying Information Redacted] [IDOC Senior Staff Employee 1] told
investigators that previously, the EBFs kept all profits from the fundraisers they held that used
inmate labor, but 12 to 18 months ago there was a policy decision with IDOC Chief of Staff Edwin
Bowen that required the EBFs to split the profits from such fundraisers equally with the Inmate
Benefit Fund and the institution’s 523 fund.48 Nevertheless, [IDOC Senior Staff Employee 1] said
he felt that using inmate labor to raise funds for the EBFs is “bad optics,” “bad ethically,” and “bad
morally.” He added: “It’s really hard for me to just honestly stomach the idea that ... employees
benefit from offender labor.”
Pinckneyville EBF
The FACTS records obtained in the investigation show that the Pinckneyville EBF took in
approximately $5,923 between January 2016 and July 2017 from car washes, as well as
approximately $402 from haircuts and shoe shines.49 In her interview, Pinckneyville EBF
Committee Chair [IDOC Employee 3] confirmed that the Pinckneyville EBF holds car washes as
a fundraiser, and that inmates sometimes wash the cars. [IDOC Employee 3] said that the inmates
are paid for their work and that they can refuse to wash the cars. She said that until recently the
EBF retained all of the profits from the car washes, but now she has been told that the profits must
either be split with the Inmate Benefit Fund and the 523 fund or that all profits must be given to
46

730 ILCS 5/3-12-2(a) (emphasis added). “Department” is defined as IDOC and the Department of Juvenile Justice.
See 730 ILCS 5/3-1-2(e).
47
See 730 ILCS 5/3-12-5 (stating that inmates performing a work assignment may receive wages pursuant to IDOC
rules and regulations).
48
As noted above, the 523 fund is used for staff salaries and various other purposes.
49
The records indicated that the Pinckneyville EBF paid approximately $1,242 for car wash supplies between February
2016 and July 2017.

18

the Inmate Benefit Fund. However, the FACTS records for the Pinckneyville EBF did not show
any transactions described as payments to the Inmate Benefit Fund.
Springfield EBF
Springfield EBF Committee Chair [IDOC Employee 6] said the Springfield EBF holds car
washes seasonally, twice a week, at which inmates wash employees’ personal vehicles, as well as
motor pool and executive staff vehicles. He explained that inmates are brought to the Springfield
campus from other facilities to do janitorial and other work there during the day, and that the
inmates are paid for the work. He said the EBF purchases the supplies for the car washes and
gives the profits to the Inmate Benefit Fund.50 He said the EBF does not make money from the
car washes, and that they are done for the benefit of the employees whose cars are washed.
G.

Direction And Guidance Provided To The EBFs

In light of the variation in practices observed in the EBFs examined in the investigation,
the OEIG asked the EBF Committee Chairs what direction and guidance IDOC provides staff
involved in the EBFs about how to run them. [IDOC Employee 3] and [IDOC Employee 4] told
investigators that they had not been given any written procedures or rules about how to run the
EBFs. [IDOC Employee 5] said that most direction she has received has been through word of
mouth, past practice, and the Administrative Directives. [IDOC Employee 6] also said that the
Administrative Directives are used, but he noted that they are vague. Some of the EBF Committee
Chairs interviewed in the investigation said they attend quarterly meetings of EBF Committee
Chairs, where they discuss EBF issues, ideas, and events, and can ask questions. However, none
reported having received any formal training about how to run the EBFs.
H.

Lack Of Centralized Oversight Of The EBFs

In their interviews, the Pinckneyville, Dixon, and Sheridan EBF Committee Chairs said
that they report to the Wardens of their individual facilities about EBF matters, and that the
Wardens make the final decisions about those matters. [IDOC Employee 6] said that because the
Springfield central office is not a prison and therefore does not have a Warden, he reports to IDOC
Chief of Staff Edwin Bowen on Springfield EBF matters.
Investigators interviewed IDOC [Identifying Information Redacted] [IDOC Employee 9]
regarding whether IDOC conducts internal audits of EBFs.51 [IDOC Employee 9] said that the
IDOC Office of Internal Audit audited the Springfield EBF in February 2016, which resulted in a
report,52 and that the office started an audit of the Springfield EBF store that was never finished.
[IDOC Employee 9] said that the IDOC Office of Internal Audit has not audited any other facility’s
EBF. She explained that the Chief Internal Auditor retired at the end of December 2016 and had
50

The FACTS records listed expenditures the Springfield EBF made for the car washes, and payments made to the
Taylorville and Jacksonville Correctional Centers’ Inmate Benefit Funds, referencing car wash workers.
51
[IDOC Employee 9] was interviewed on November 3, 2017.
52
The OEIG obtained a copy of the audit report, dated February 2016, which found that the Springfield EBF lacked
proper controls over expenditures and receipts, and did not have a procedure to address outstanding checks when stop
payments are not issued. The report also found that the EBF Committee failed to review all expenditures. The report
indicated that the Springfield EBF Committee accepted the audit’s recommendations.

19

not been replaced, and without a person in that position there were no plans for future audits of
EBFs. In his interview, IDOC [Identifying Information Redacted] [IDOC Senior Staff Employee
1] said that he did not know what the audit plan is for the EBFs, but he added that audits should
still be conducted even without a Chief Internal Auditor in place.
[IDOC Employee 1] said that in her capacity of overseeing IDOC’s locally held funds, her
interaction with the EBFs includes involvement in quarterly reporting, helping the EBFs with
monthly variances and with their journal entries, and answering questions. She said that until
recently, she played less of a role regarding the EBFs than with other locally held funds because
Chief of Staff Edwin Bowen handled EBF oversight responsibilities that would normally be the
responsibility of the Accounting Department. [IDOC Employee 1] said that when she received
calls from EBFs, she would direct them to Mr. Bowen because he oversees the EBFs and is
responsible for providing information for them. In addition, [IDOC Employee 1] said that Mr.
Bowen told her multiple times that he wanted to be included on all EBF communications.
However, [IDOC Employee 1] said that in an April 18, 2018 meeting with the Wardens, Mr.
Bowen directed them to address questions about the administration of the EBFs to [IDOC
Employee 1] and her staff, and that she has responded to many questions since then.
[IDOC Senior Staff Employee 1] said that he has told Mr. Bowen that at some point, IDOC
is going to have to centralize the EBFs. [IDOC Senior Staff Employee 1] explained to investigators
that it “doesn’t make sense to have . . . 27 some-odd bank accounts kind of managing themselves
at the institutional level . . . .” [IDOC Senior Staff Employee 1] said that if the EBFs were
centralized, he would be more aware of how the EBFs obtained their funds. He added that if
someone decides not to follow the procedures, “there is no real check and balance” unless the
EBFs are centralized.
I.

Changes Made During The Investigation

The OEIG learned that during the investigation, IDOC began implementing changes to the
EBFs that addressed some of the issues identified in the investigation.
[IDOC Employee 1] said that at the April 18, 2018 Wardens meeting, Mr. Bowen
distributed EBF guidelines to the Wardens that she had drafted, and Mr. Bowen told the Wardens
that the EBFs no longer were permitted to hold raffles. The OEIG obtained a copy of the
guidelines, which stated that cash and gift cards could not be distributed for Employee
Appreciation Week and noted various tax rules. [IDOC Employee 1] said that in a May 29, 2018
meeting with EBF Committee Chairs and Business Administrators, she told them that all EBF
sales should be conducted through the commissary.
Investigators also obtained a document titled “Frequently Asked Questions regarding the
EBF,” which was emailed from Mr. Bowen to “DOC.DL-Warden’s Adult Group” on June 26,
2018. The document included directions such as that EBF sales must be run through the
employee’s commissary with the applicable markup and profit splits, raffles may only be held
through a charitable organization with all profits going to the charity, and EBFs cannot profit or
benefit from offenders’ work.

20

[IDOC Senior Staff Employee 1] said that he, [IDOC Employee 1], and Mr. Bowen
discussed alternatives to the EBFs approximately two weeks before [IDOC Senior Staff Employee
1]’s OEIG interview. He said that the employees could set up a fraternal order outside IDOC, with
an outside bank account, instead of using the EBFs. [IDOC Senior Staff Employee 1] said he has
discussed this alternative with Mr. Bowen.
J.

Interview Of IDOC Chief Of Staff Edwin Bowen

Investigators interviewed Mr. Bowen on August 27, 2018. Mr. Bowen said he has been
the IDOC Chief of Staff since approximately June 2015, and that he previously worked at IDOC
from 1988 through 2005, including as the Warden at Centralia Correctional Center. Mr. Bowen
said he reports to IDOC Acting Director John Baldwin.
Mr. Bowen said IDOC had EBFs when he began working for IDOC in 1988, and that his
colleagues who began working at IDOC in the 1960s reported that the EBFs existed then as well.
He said the Wardens oversee the EBFs in their facilities, and that they do not report to anyone
regarding the EBFs. Mr. Bowen said that he does not have any official duties regarding the EBFs,
including the Springfield EBF, but that he has been heavily involved in promoting their activities,
with “the blessing of the Director.” 53
Mr. Bowen said that the EBFs have been a longstanding tradition at IDOC, and he opined
that they are necessary to ease the pressure that corrections staff are under. However, he
acknowledged that the EBFs also “have been operating outside the probably technically statutory
authority forever.” Mr. Bowen said he has regular conversations with Mr. Baldwin about EBF
activities, and that he has discussed EBF issues with Mr. Baldwin on several occasions.
Mr. Bowen said he was aware that under the IDOC Administrative Directives, the EBFs’
primary source of revenue is supposed to be vending machine and commissary profits, and he said
he understands “primary” to mean that the majority of EBF revenues must come from those
sources. Mr. Bowen said he believed that the EBFs’ primary source of revenues is commissary
profits, and that it would surprise him to hear that IDOC records reflected that in FY 2017, the
EBFs’ revenues came mostly from other sources.
Mr. Bowen said he was not aware that EBFs had solicited donations from local businesses.
He said that approximately two years ago an EBF Committee Chair asked if the EBFs could do
so, and that he consulted then-IDOC [Identifying Information Redacted] [IDOC Employee 10]
about it. Mr. Bowen said he did not recall what [IDOC Employee 10]’s response was, but he
recalled that the EBFs were told that they cannot solicit donations from businesses that do business
with the State. Mr. Bowen said he did not follow up with the EBFs about whether they were
complying with this direction, and that he did not know if any follow up was done.
Mr. Bowen said the EBFs had been holding raffles since at least 1988, when he first began
working at IDOC. However, he said he instructed the EBFs to stop holding raffles after [IDOC
Senior Staff Employee 1] or [IDOC Employee 1] pointed out that because the EBFs are not
53

Mr. Bowen added, “If you’re looking for someone to hang the EBF on, it’s the Chief of Staff with the Director’s
knowledge.”

21

501(c)(3) organizations they cannot legally obtain raffle licenses. Mr. Bowen said he had
discussions with Mr. Baldwin about the raffles, but that it was his (Mr. Bowen’s) decision to stop
them.
Mr. Bowen said he was aware that the EBFs sell merchandise to raise funds, and said they
keep all profits from items sold outside the employee commissary. Mr. Bowen said the EBFs are
now limited to charging a 10% markup. Mr. Bowen noted that although the commissary markup
is statutorily limited to 10%, he believed that most items sold through the employee commissaries
had a higher markup. He said the EBFs are required to follow the Procurement Code when they
purchase items to sell in fundraisers, 54 and that it would be a State Officials and Employees Ethics
Act violation for an EBF to select a supplier based on a personal relationship an EBF Committee
member had with a vendor. However, Mr. Bowen said that IDOC does not require the EBFs to
document how they select their suppliers, and that he would have no way of knowing if an EBF
selected a supplier based on a personal relationship.
Mr. Bowen said that employees are allowed to do EBF activities on State time. He said he
was unaware of any rules governing how much time employees can spend on EBF activities, and
said that the Warden at each individual facility makes that determination. Mr. Bowen said that
employees may spend 20 hours working on EBF activities during Employee Recognition Week,
and that that was acceptable because the EBFs were part of IDOC’s mission. He said employees
also spend a lot of time on EBF activities around Christmas. According to Mr. Bowen, other than
these events, employees involved with the EBFs probably spend a couple of hours per week
working on EBF activities at the most.
Mr. Bowen said that the EBFs “pretty much are on their own” in deciding how to spend
their money. He said that one of the EBFs’ largest expenditures is for Christmas parties, and that
the EBFs also spend money on employee meals, donations, funeral flowers, retirement gifts, and
other expenditures. Mr. Bowen said that a number of the EBFs used to give out cash or gift cards
to employees as prizes or for recognition awards, but that they were told to stop doing so one to
two years ago because [IDOC Employee 1] said the practice violated tax rules. Mr. Bowen said
he did not have any concerns about how the EBFs were accounting for the cash, and that he was
not aware of EBFs spending their money for any purposes that were not listed in the Administrative
Directives.
Mr. Bowen said he was aware that some of the EBFs use inmates to work at EBF
fundraisers, such as car washes, and noted that the Springfield EBF holds car washes at which
inmates wash the employees’ personal vehicles. He said that until approximately three years ago,
the EBFs kept the profits from the car washes. However, he said that following discussions
between himself, Mr. Baldwin, and IDOC’s legal and fiscal units, the current IDOC administration
has required the EBFs to share the profits with the Inmate Benefit Fund. Mr. Bowen said he was
unaware of any statute that said it was inappropriate to use inmates for EBF activities, and that he
was not familiar with Section 5/3-12-2(a) of the Unified Code of Corrections, relating to types of
inmate employment. When shown a copy of the provision in his interview he opined that it only
applied to Illinois Correctional Industries and did not apply to work assignments in correctional
facilities.
54

However, he noted that the EBFs’ purchases would not reach the Procurement Code’s small purchases threshold.

22

Mr. Bowen said he has not had any discussion with staff in the IDOC Office of Internal
Audit about auditing the EBFs, and that he was unaware of any internal audits of an EBF since the
Springfield EBF was audited in February 2016. Mr. Bowen said the Chief Internal Auditor
position has been posted several times since the previous Chief Internal Auditor left IDOC at the
end of 2016, but that the position has not been filled. He stated that he was unaware of the EBF
Committee Chairs or committee members receiving any training about how to run the EBFs.
K.

Interview Of IDOC Acting Director John Baldwin

On September 26, 2018, investigators interviewed Mr. Baldwin. Mr. Baldwin said he has
been IDOC’s Acting Director since August 2015.
Mr. Baldwin said that he has no direct duties and responsibilities regarding the EBFs, and
that he does not approve EBF decisions. However, he said, in the context of setting global policy
at IDOC, he participates in conversations about issues such as how to take care of staff, and that
some of those conversations involve the EBFs. Mr. Baldwin said that Mr. Bowen is the point
person for the EBF system, but that as IDOC Director, he (Mr. Baldwin) has ultimate authority
over the EBFs.
Mr. Baldwin said he was not aware that under the IDOC Administrative Directives, the
EBFs’ primary source of revenue is supposed to be vending machine and commissary profits, and
said he did not know whether the EBFs’ funds come mostly from other sources. He said he was
not aware of whether EBFs solicit donations from local businesses, or whether, if they do, they are
required to check to make sure the businesses are not IDOC or State vendors. Mr. Baldwin said
he was aware that the EBFs had held raffles, and said they were told to stop doing so based on
questions raised by IDOC accountants. He said he did not know what profits EBFs can keep from
sales of items, or what markup they can charge.
Mr. Baldwin said he was aware that IDOC employees were spending some State time on
EBF activities, but that he did not know how much. Mr. Baldwin said that in extreme cases there
is a limit to how much State time an employee should be spending on EBF activities, but that he
did not know what the limit was; he said that would be dependent on circumstances such as how
often it happened and whether the employee was gearing up for a big event.
Mr. Baldwin said he did not know what types of things the EBFs spend their money on,
and that he was not aware that expenditures of EBF funds are required to be for a purpose listed in
the Administrative Directives. Mr. Baldwin said that at some point, Mr. Bowen and [IDOC Senior
Staff Employee 1] told him that some EBFs gave out cash or gift cards to employees. Mr. Baldwin
said he did not know if the EBFs have paid to send teams to the “Director’s” golf outing or whether
they have been provided any direction regarding how to select participants.
Mr. Baldwin said he had been told that some of the EBFs use inmates to work at fundraisers
like car washes and said that he has no issue with the practice as long as the inmates already work
outside and are asked if they want to do the work. He said that at some point he had a passing
conversation with [IDOC Senior Staff Employee 1], and possibly Mr. Bowen and [Identifying

23

Information Redacted] [IDOC Senior Staff Employee 2], about requiring the EBFs to share the
profits from such fundraisers with the Inmate Benefit Fund, but said he did not recall the outcome
of the conversation. Mr. Baldwin said he was not familiar with Section 5/3-12-2(a) of the Unified
Code of Corrections, and when investigators showed him a copy of the provision during his
interview he opined that it was focused on Illinois Correctional Industries.
Mr. Baldwin said he did not know if EBFs are given any written procedures or rules about
how to run an EBF. He said he did not know whether EBF Committee Chairs and members receive
any training about how to run the EBFs.
Mr. Baldwin said he did not know what changes had been made in the last year regarding
the operation of the EBFs. He said that in the future, he intends to update IDOC’s policies based
on his review of the current policies during the interview. Mr. Baldwin said he had not previously
considered eliminating the EBFs as an IDOC fund and requiring the employees to do any
fundraising activities through an independent organization outside work, but he said he may
consider that as a result of his OEIG interview.
IV.

ANALYSIS

The OEIG recognizes the difficult nature of the work for many IDOC employees and
understands that promoting positive employee morale at IDOC is important. It is therefore
reasonable for IDOC employees to participate in activities designed to improve employee
performance and increase retention by boosting employee morale. As important as those goals
are, however, they must be carefully balanced against IDOC’s obligation to provide good value
and oversight for the taxpayer funds that pay the employees’ salaries.
As discovered in this investigation, IDOC lacks adequate centralized oversight and controls
over EBF funds. Without such oversight or controls, it is difficult to determine whether funds are
properly collected or used and thus, exposes these funds to mismanagement, abuse or fraud. In
addition, the failure of proper oversight has allowed various problematic practices to develop in
the individual EBFs, including an expansion of the EBFs’ revenues beyond what is permitted by
IDOC Administrative Directives, solicitation of donations from businesses without ensuring that
they are not State vendors, sales of merchandise outside statutory and IDOC requirements,
improper raffles, waste of State time and resources, and the improper use of inmate labor.
Failure to Adhere to Administrative Directives Regarding Revenues
IDOC’s Administrative Directives require that the “[p]rimary sources of revenue” for the
EBFs shall be profits from vending machines and employee commissaries. 55 However, this
investigation discovered that IDOC facilities have expanded the scope of their EBFs’ revenue
stream through fundraising. Each year from FY 2012 through FY 2017, more than 70% of the
EBFs’ revenue statewide was derived from sources other than vending and commissary profits. In
FY 2017, the EBFs derived $959,987 from such other sources, or 80% of the total EBF revenues.

55

IDOC Admin. Directive 02.43.101(II)(E)(2) (2001).

24

The OEIG’s review of EBF transactions records and interviews of IDOC employees
confirmed that the EBFs’ revenues largely came from fundraising activities, including selling
merchandise and food, soliciting donations from local businesses, holding car washes, and
conducting raffles. Due to such fundraising efforts, in FY 2017, 86% of the EBFs derived over
half their revenue from sources other than vending and commissary profits, and 34% of the EBFs
derived over 90% of their revenue from other sources.
No Check on Solicitations of Donations
EBF fundraising efforts, and the lack of oversight and controls over them, have led to other
problematic practices as well. For example, some EBFs solicited donations from local businesses,
but IDOC does not have a mechanism in place to ensure that such solicitations do not create a
conflict of interest. IDOC does not maintain a list of businesses that are asked to donate to the
EBFs, and no one checks whether a potential donor is a State vendor. As [IDOC Employee 1]
noted in her OEIG interview, without an accurate donor list, IDOC simply trusts the EBFs to ensure
that there are no conflicts of interest with the donations they accept.
As the OEIG discovered, that trust is misplaced, as individual EBFs do not take steps to
ensure that they are not soliciting State vendors. [IDOC Employee 3] told investigators that in
2016, she solicited nearly every business listed in the Pinckneyville telephone directory for
donations, and that the Pinckneyville EBF solicited local businesses in 2017, as well. One local
business donated money to the Pinckneyville EBF after an EBF member reminded it that the
Pinckneyville Correctional Center is “the largest employer in Perry County,” and in a mass email
[IDOC Employee 3] urged employees to show “gratitude” to the sponsors of the event. Although
[IDOC Employee 3] maintained that she would have known if any of the businesses she solicited
were IDOC vendors, she acknowledged that she had no process in place to ensure that the sponsors
were not State vendors. Similarly, [IDOC Employee 4] said that she solicited donations or
sponsorships from local businesses for a Sheridan EBF event without checking whether the
businesses were State vendors. Without any checks or controls in place, solicitations such as
[IDOC Employee 3]’s and [IDOC Employee 4]’s could easily create conflicts of interest.
Problems Caused by EBF Merchandise Sales And Raffles
The EBFs’ practice of selling items outside the employee commissaries allowed for
statutory and IDOC requirements to be evaded. Although employee commissaries are statutorily
limited to a 10% markup on their sales,56 the EBFs charged a higher markup on their sales of
merchandise outside the commissaries. In addition, the EBFs kept all the profits from such sales,
instead of being limited to the 40% of the profits they receive from commissary sales. 57
In addition, some EBFs may be using problematic practices when they purchase the
merchandise they resell in their fundraisers. Although some of the EBF Committee Chairs
interviewed maintained that they are careful to follow applicable rules when they purchase items
for EBF fundraisers, [IDOC Employee 3] said that the Pinckneyville EBF selected suppliers

56
57

See 730 ILCS 5/3-7-2a.
See IDOC Admin. Directive 02.44.110(II)(E)(1)(a)(1) (2004).

25

through word of mouth, and that one supplier she selected was someone she knew from her
hometown.
The investigation also revealed various other problems with the revenue sources of the
EBFs. For example, until recently EBFs commonly held raffles to raise funds for the EBFs,
although the EBFs are IDOC funds, and as such would not appear to have qualified for the raffle
licenses some received.58 Since this investigation began, IDOC wardens have been advised that
raffles may not be held unless they are held through a charitable organization with all profits going
to the charity. However, it has yet to be determined whether this directive is being enforced at all
facilities.
Waste of State Resources
If the EBFs complied with the Administrative Directive’s requirement limiting their
primary sources of revenue to vending machine and commissary profits, other issues discovered
in this investigation likely would not have occurred either. For example, employees would have
spent far less State time on EBF activities, because employees do not service the vending machines
or run the commissaries. However, with the expansion of the scope of EBF activities to include
extensive fundraising efforts, employees also expanded the amount of State time and resources
they devote to EBF activities.
For example, [IDOC Employee 3] told investigators that she spent up to 10 to 20 hours in
a week on Pinckneyville EBF activities, and she noted that all the employees in her office helped
sort shirts for EBF sales as well; investigators also discovered that [IDOC Employee 3] sent and
received nearly 600 emails at work relating to EBF matters during just one month in 2017. In
addition, [IDOC Employee 4] told investigators that she spent a week’s worth of time preparing
for an employee recognition event at Sheridan. [IDOC Employee 5] estimated that ten employees
spend about 40 hours each of mostly working time over five months preparing for Employee
Appreciation Week at Dixon. [IDOC Employee 1] said that employees have stated that State work
could not be done because they were attending an EBF event or out purchasing items for the EBF,
and [IDOC Senior Staff Employee 1] said that it was “not uncommon” for business office
employees to say that the EBFs were “consuming” their time.
Improper Use of Inmate Labor
The OEIG also discovered that some EBFs improperly use inmate labor for fundraising
events such as car washes, even though that work benefits the employees and the EBFs rather than
serving a public purpose. The Unified Code of Corrections prohibits IDOC from hiring out
inmates to perform work other than what is described in the statute, such as working for Illinois
Correctional Industries, producing license plates, producing food and other necessities for IDOC,
working on conservation and public works projects, and other activities that serve a public
purpose.59 Although Mr. Bowen and Mr. Baldwin took the position in their interviews that this
provision governs Illinois Correctional Industries’ activities, and therefore would not apply to the
circumstances here, their reading of the statute is erroneous. The plain language of the statute
58
59

See 230 ILCS 15/2.
730 ILCS 5/3-12-2(a).

26

discusses what the “Department” -- IDOC -- can and cannot do. Therefore, IDOC is prohibited
from allowing inmates to be employed for non-public purposes.
Contrary to this prohibition, IDOC has a longstanding practice of allowing the EBFs to use
inmate labor for EBF fundraisers. In these fundraisers, inmates wash employees’ personal
vehicles, and some of the EBFs retain at least part of the profits to use for activities and events that
benefit the employees. Even to the extent that the EBFs now share a portion of the car wash profits
with the Inmate Benefit Fund, the EBFs are still allowed to use some profits from inmate labor to
fund employee events such as holiday parties, and individual employees benefit from having their
personal vehicles washed. Neither purpose is a “public purpose” permitted under the statute.
Lack of Oversight or Control over EBF Funds
The EBFs have been significantly increasing their amount of revenue over the years:
nearly $1 million was brought in statewide in FY 2017 alone. Although the EBFs take in and
spend large sums of money each year, the investigation discovered that IDOC has exercised little
to no centralized oversight of them. Each facility independently runs its own EBF activities and
maintains its own EBF account; moreover, many of the EBFs’ transactions are cash based, making
oversight and controls all the more important. Furthermore, IDOC has not had a Chief Internal
Auditor in place for approximately two years, and although there is other internal audit staff, they
have conducted no internal audits of the EBFs other than an audit of the Springfield EBF in
February 2016. IDOC does not otherwise perform oversight; in addition, necessary controls were
significantly lacking.
The EBFs self-report their transactions, with staff at each individual facility inputting
descriptions of the transactions into IDOC’s electronic accounting system, FACTS. However,
IDOC has no uniform procedure or requirements for describing the transactions. As a result, the
individual facilities describe the EBFs’ transactions inconsistently or fail to identify the source of
funds. Therefore, in many cases it was virtually impossible to ascertain how an EBF obtained or
spent particular funds.
For example, donations an EBF solicits and purchases an EBF makes may be described in
FACTS in any number of ways. IDOC does not require the EBFs to otherwise document what
companies they solicit for donations or from which they buy items, making it impossible for IDOC
to check whether EBFs may be soliciting donations from State vendors, or buying items from a
vendor with which an EBF Committee member has a personal relationship. As a result, there is
no check on these activities, and the EBFs themselves take no steps to ensure that they are not
acting improperly.
The EBFs also decide how to spend their funds without any centralized oversight or
controls. For example, the Springfield EBF spends an extraordinary amount on its annual holiday
party: about $30,000 per year, for an event typically attended by about 150 to 175 employees plus
their guests. In addition, although expenditures of EBF funds for recreational or entertainment
events are required to benefit a significant number of employees, 60 the OEIG identified instances
in which EBFs paid entry fees for small groups of employees to participate in golf outings.
60

IDOC Admin. Directive 02.43.102(II)(E)(5) (2000).

27

Until recently, the EBFs were given no direction regarding the distribution of cash, which
was commonly done at events such as Employee Appreciation Week and holiday parties. As
[IDOC Employee 6] described, the “workaround” the Springfield EBF designed to distribute cash
prizes and awards to employees involved writing multiple large checks directly to [IDOC
Employee 6] from the EBF account. Those cash prizes included over $6,000 in cash that [IDOC
Employee 6] said was distributed to attendees of a 2016 Christmas party. Although [IDOC
Employee 6] said he obtained receipts for the cash that was distributed, this action was not pursuant
to any IDOC requirement or procedure. Such a system is ripe for fraud or abuse.
Without centralized oversight of EBF activities, no one examines how the EBFs obtain
their funds, or how they spend them. It is critical for IDOC to provide direction to EBF staff on
how to properly operate the EBFs. However, IDOC has no written procedures other than the
general policies contained in the Administrative Directives, and the personnel involved in
managing the EBFs receive no training.
Conclusion
The EBFs have been in existence for many years and some of the issues identified in the
investigation are not new. However, the level of fundraising by EBFs has increased significantly
without direction or much if any oversight. Controls must be implemented from the top down, but
as the investigation discovered this has not been done with the EBFs despite the amount of money
involved in their operation. As Chief of Staff, Mr. Bowen is the point person for the EBF system,
and admitted that he is heavily involved with the EBFs. IDOC Acting Director Baldwin
acknowledged that he has ultimate authority over the EBFs. Both Mr. Bowen and Mr. Baldwin,
however, did not take necessary steps to ensure that the EBFs complied with applicable statutes
and Administrative Directives; impose controls on the EBFs’ expenditures, especially their
handling of cash; or require the EBFs to document activities such as how they solicit donations or
select suppliers. Internal audits of these EBF accounts were not taking place on any regular basis.
In addition, although changes have recently been implemented to address some of the issues, Mr.
Bowen and Mr. Baldwin have continued to sanction such practices as allowing employees to spend
significant amounts of State time doing EBF activities, and allowing the EBFs to use inmate labor
for their fundraisers. In short, Mr. Bowen and Mr. Baldwin have failed to ensure that the EBFs
are managed properly.
For these reasons, the allegations that Mr. Bowen and Mr. Baldwin mismanaged the EBFs
and violated the Unified Code of Corrections’ prohibition against using inmate labor for nonpublic purposes are FOUNDED.61 Because it appears that the problematic practices identified in
this investigation are widespread and involve many of the EBFs, and because these practices have
been sanctioned or encouraged at a high level, the OEIG is not making findings against employees
involved in any individual EBF.
V.

FINDINGS AND RECOMMENDATIONS

61

The OEIG concludes that an allegation is “founded” when it has determined that there is reasonable cause to believe
that a violation of law or policy has occurred, or that there has been fraud, waste, mismanagement, misconduct,
nonfeasance, misfeasance, or malfeasance.

28

As a result of its investigation, the OEIG concludes that there is REASONABLE CAUSE
TO ISSUE THE FOLLOWING FINDINGS:
 FOUNDED – Illinois Department of Corrections Acting Director John Baldwin
mismanaged the Employee Benefit Funds.
 FOUNDED – Illinois Department of Corrections Chief of Staff Edwin Bowen
mismanaged the Employee Benefit Funds.
 FOUNDED – Illinois Department of Corrections Acting Director John Baldwin permitted
inmate labor to be used for a non-public purpose, in violation of 730 ILCS 5/3-12-2(a).
 FOUNDED – Illinois Department of Corrections Chief of Staff Edwin Bowen permitted
inmate labor to be used for a non-public purpose, in violation of 730 ILCS 5/3-12-2(a).
Based on these findings, the OEIG recommends that the Office of the Governor take
whatever action it deems appropriate regarding Mr. Baldwin and Mr. Bowen.
The OEIG also recommends that the Office of the Governor direct IDOC to:


implement and enforce written policies and procedures regarding the operation of the
EBFs, including rules governing a financial tracking system that allows for effective
review of the source and use of funds, and rules regarding the EBFs’ purchases and
sales of merchandise, solicitations of donations, and other fundraising activities;



take necessary steps to ensure that the EBFs are operated in accordance with all
applicable laws, regulations, and policies, including Administrative Directives
regarding the source of revenue;



implement and conduct training of employees involved in EBF activities;



conduct regular audits of the EBFs; and



cease allowing inmate labor to be used for EBF fundraisers.

No further investigative action is needed, and this case is considered closed.
Date: December 10, 2018

Office of Executive Inspector General
for the Agencies of the Illinois Governor
69 W. Washington St., Suite 3400
Chicago, IL 60602
By:

Angela Luning
Deputy Inspector General
Reginald Spears

29

Investigator #124

30

Appendix A
Sources of EBF Revenue, FY 2017
Facility

Total EBF
Revenue
(FY 2017)

Big Muddy
Centralia
Danville
Decatur
Dixon
East Moline
Fox Valley62
Graham
Hill
Illinois River
Jacksonville
Kewanee63
Lawrence
Lincoln
Logan
Menard64
Peoria65
Pinckneyville
Pontiac
Robinson
Shawnee
Sheridan
Southwestern Ill.
Springfield66
Stateville
Taylorville
Vandalia
Vienna
Western Ill.

$14,231
$43,857
$28,609
$26,264
$21,604
$11,656
$1,133
$56,956
$17,653
$31,293
$32,291
$6,883
$19,786
$35,029
$42,781
$54,600
$30,199
$44,167
$31,182
$18,644
$40,588
$43,787
$19,396
$163,529
$17,086
$20,260
$37,349
$17,392
$31,779

Revenue from
Vending
Machines and
Commissary
$60
$3,120
$4,343
$5,994
$3,423
$5,169
$0
$11,056
$3,114
$16,642
$1,581
$338
$4,706
$7,998
$9,981
$28,569
$20,720
$655
$6,602
$4,298
$6,800
$3,627
$915
$5,452
$5,540
$5,102
$1,332
$4,671
$17,170

62

Other Revenue

$14,171
$40,737
$24,266
$20,270
$18,181
$6,487
$1,133
$45,900
$14,539
$14,651
$30,710
$6,545
$15,080
$27,031
$32,800
$26,031
$9,479
$43,512
$24,580
$14,346
$33,788
$40,160
$18,481
$158,077
$11,546
$15,158
$36,017
$12,721
$14,609

% of Revenue Not
from Vending
Machines and
Commissary
99%
93%
85%
77%
84%
56%
100%
81%
82%
47%
95%
95%
76%
77%
77%
48%
31%
99%
79%
77%
83%
92%
95%
97%
68%
75%
96%
73%
46%

Fox Valley is an Adult Transition Center.
Kewanee is a Life Skills Re-Entry Center.
64
The data provided regarding Menard Correctional Center’s EBF receipts for FY 2017 reflected an accounting error
where $147,000 of Inmate Benefit Fund money was accidentally credited into the EBF and later debited back to the
Inmate Benefit Fund. Accordingly, the OEIG subtracted $147,000 from the “Other Revenue” amount for Menard in
this chart.
65
Peoria is an Adult Transition Center.
66
Springfield is IDOC’s central office.
63

31

Office of Executive Inspector Gene.-al
for the Aaencies of the Dlinol'- Gm·ernor
www.,nspectorgenerai.11lmo1s.gov

AGENCY OR ULTIMATE JURISDICTIONAL AUTHORITY
RESPONSE FORM

Case Number:

17-01266

Return 20 Days After Receipt

Please check the box that applies. (Please attach additional materials, as necessary.)
□

We have implemented all of the OEIG recommendations . Please provide details as to
actions taken:

We will implement some or all of the OEIG recommendations but will require additional
time to do so.
We will report to OEIG within l.2-days from the original return date.
l\,Z.otft)

(:S°"'ua.d

□

We do not wish to implement some or all of the OEIG recommendations. Please provide
details as to what actions were taken , if any, in response to OEIG recommendations:

o~u ~ -J"il
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OFFICE OF THE GOVERNOR
JRTC, 100 W. RANDOLPH, SUITE 16- 100
CHICAGO, ILLINOIS 60601

BRUCE RAUNER
GOVERNOR

CONFIDENTIAL

January 11, 2019
Susan M. Haling
Acting Executive Inspector General
Office of Executive Inspector General
69 West Washington, Suite 3400
Chicago, Illinois 60602
Re: OEIG Complaint Number #17-01266 Response to Final Report

Dear Acting Executive Inspector General Haling,
This letter is in reply to the Final Summary Report ("Final Report") issued to the Governor's
Office by the Office of Executive Inspector General ("OEIG") in the above-captioned matter.
With the issuance of this Final Report, the OEIG has determined that no further investigative
action is needed, and this case is considered closed. The OEIG has asked the Governor's Office
to reply to the Final Report by listing all actions the Governor' s Office has taken to address the
recommendations the OEIG has made relative to the investigation.
The OEIG determined there was reasonable cause to issue the following findings:
(1) Illinois Department of Corrections Acting Director John Baldwin mismanaged the
Employee Benefit Funds.
(2) Illinois Department of Corrections Chief of Staff Edwin Bowen mismanaged the
Employee Benefit Funds.
(3) Illinois Department of Corrections Acting Director John Baldwin permitted inmate labor
to be used for a non-public purpose, in violation of 730 ILCS 5/3-12-2(a).
(4) Illinois Department of Corrections Chief of Staff Edwin Bowen permitted inmate labor to
be used for a non-public purpose, in violation of 730 ILCS 5/3-12-2(a).

The Governor's Office has reviewed the Final Report and the investigatory materials furnished
to it by the OEIG in support of these findings. The Governor's Office accepts and agrees with the
findings of the OEIG described in its Final Report. The Governor's Office concludes that the
issues found in the report arise from practice over many years, and that IDOC took steps to
correct several of the problems prior to issuance of this report. To the extent steps have not been
taken to address the recommendations, we agree that they should be taken. We will leave a copy
of our response and your report for the next administration.
Based on these findings, the OEIG made five recommendations to the Governor's Office and/or
the Illinois Department of Corrections ("IDOC" or "the Department"). This letter will address
each recommendation in tum. 1
1. The Governor's Office should direct IDOC to implement and enforce written
policies and procedures regarding the operation of the EBFs, including rules
governing a financial tracking system that allows for effective review of the source
and use of funds, and rules regarding the EBFs' purchases and sale of merchandise,
solicitation of donations, and other fundraising activities.

The Governor' s Office and IDOC accept and agree with this recommendation.
IDOC operates twenty-nine correctional centers and four adult transition centers across Illinois.
The Department employs approximately 12,000 employees who serve a population of more than
40,000 inmates and over 25,000 parolees. Each of IDOC's centers maintains an Employee
Benefit Fund ("EBF") to provide beneficial opportunities generally available to all IDOC
employees, like purchasing and repairing employees' recreational equipment, funding
entertainment events for employees, celebrating tributes to employees or an employee's
immediate family, supporting travel fund advancements and reimbursements, and making
charitable contributions to community organizations. A significant reason why the EBFs exist is
to provide stress relief and opportunities for camaraderie in the very high-stress and challenging
work environments that are correctional centers. EBFs or their equivalents are common tools
across United States correctional centers to boost employee morale.
IDOC created these EBFs pursuant to Administrative Directives established in 2000 and earlier.
By rule, EBFs are solely for the benefit of IDOC employees. Monies from the EBFs cannot be
used for operational expenses, cannot benefit inmates, and cannot inure to the benefit of only a
few employees. AD. 02.43. l 02.
IDOC recognizes the value that EBFs provide in maintaining good order and a positive work
environment for corrections staff. Nevertheless, as a result of both the OEIG's investigation and
IDOC's independent review of the management of the EBFs, IDOC agrees that there exist

1 This Office notes that, while it expresses herein its agreement with the OEIG's findings and recommendations and
expects IDOC will implement change to improve its management of Employee Benefits Funds, it will be the
responsibility of the next administration to monitor these efforts. Moreover, the next administration may have its own
and different perspectives about these issues, and those perspectives may shape IDOC's next steps. Therefore, the
Governor's Office accepts these recommendations and describes the changes it has directed IDOC to implement, but
the Governor's Office also intends to share this letter with the next administration for their consideration.

2

deficiencies in the way the Department has communicated to its employees about proper use of
EBFs and how EBFs' financial infonnation is tracked. For example, in April 2018, IDOC
proactively ended the practice of allowing EBFs to be beneficiaries of raffles to avoid actual
violation oflaw and any appearance of impropriety (Exhibit A). Further, in May 2018, IDOC
fiscal directed EBF chairs and business administrators that EBF sales must be made exclusively
through commissaries. In June 2018, in addition to developing an FAQ promulgated to staff
(Exhibit B), IDOC fiscal staff engaged in concerted efforts to interview and advise Chief
Administrative Officers ("CAOs") and facility personnel on the proper use of EBFs.
IDOC senior management, in consultation with its fiscal office, should develop an effective
financial tracking system for EBFs in 2019. Since at least July 2016, CAOs have been directed to
review EBF expenditures in committee. Meeting minutes of these committees must be
maintained by all members and all expenditure requests to the committee must be in writing and
described and justified (Exhibit C). However, IDOC senior leadership should ensure that these
requirements are actually being executed in practice across all facilities. Also, to the extent that
other best practices exist to provide financial transparency about the EBFs, such practices should
be fonnalized in new procedures in the Administrative Directives. The OEIG suggests
commonsense requirements for a tracking system that will account for the source and use of
funds, and the Governor's Office hereby directs IDOC to develop such a system.

2. The Governor's Office should direct IDOC to take necessary steps to ensure the
EBFs are operated in accordance with all applicable laws, regulations, and policies,
including Administrative Directives regarding the source of revenue.
The Governor's Office and IDOC accept and agree with this recommendation. Although EBFs
must be operated within the legal parameters of the Code of Corrections, the Governor's Office
and IDOC acknowledge that the Administrative Directives that govern the use of EBFs are
twenty years old and merit a careful review by IDOC Legal and the EBF committees to ensure
their actual practice confonns with the Administrative Directives' legal requirements. The
Governor's Office directs IDOC Legal to propose any necessary amendments to the
Administrative Directives promptly to IDOC senior management. IDOC Legal is further directed
to conduct a review and to ensure conformity between the Administrative Directives and the
State Officials and Employees Ethics Act, the State of Illinois Code of Personal Conduct, and
other laws and policies. To the extent the Administrative Directives are inconsistent with the
State's ethics laws, or could be revised to more clearly comply with State ethics laws, IDOC
Legal is directed to recommend amendment to the Administrative Directives.

3. The Governor's Office should direct IDOC to implement and conduct training of
employees involved in EBF activities.
The Governor's Office and IDOC accept and agree with this recommendation. IDOC intends to
issue a directive to staff regarding existing EBF rules within the next thirty days. The
Department will also institute annual trainings for all EBF chairs and for CAOs in the first
quarter of 2019. As described above, CAOs are the most senior hands-on, day-to-day
administrators monitoring EBF expenditures. Because of IDOC's size, it is imperative to senior
leadership that facility administrators and fiscal staff are well versed in the Code of Corrections
3

and the Administrative Directives. Although IDOC's standing practice has been to hold monthly
meetings with the Director, Chief of Staff, and facility CAOs, these new training efforts will be a
robust orientation to rules and regulations surrounding EBFs, sensitive to the changes IDOC
Legal may recommend. Because the Final Report identified one EBF that was improperly
soliciting donations from State vendors, all employees engaged in EBFs will receive a reminder
in the next thirty days that they are barred from soliciting monies from prohibited sources.
4. The G-Overnor's Office should direct IDOC to conduct regular audits of the EBFs.

The Governor's Office and IDOC accept and agree with this recommendation. IDOC intends to
implement annual audits of the EBFs as part of the Department's perfonnance review process.
The Governor's Office also directs IDOC to conduct regular audits as necessary to monitor the
perfonnance of EBFs.

5. The Governor's Office should direct IDOC to cease allowing inmate labor to be
used for EBF fundraisers.

The Governor's Office and IDOC accept and agree with this recommendation. IDOC has already
directed its staff that EBFs will no longer be allowed to profit from inmate labor.
Finally, the OEIG recommended that the Governor's Office ..take whatever action it deems
appropriate regarding Mr. Baldwin and Mr. Bowen." As referenced in footnote l, the Governor's
Office will provide the incoming administration with a copy of this letter and the OEIG's Final
Report for whatever action it sees fit to talce.
If you have any questions or require any further information with respect to this reply, please
contact gov.compliance@illinois.gov.
Sincerely,
Isl Christina McClernon

Christina McClemon
Associate General Counsel & Chief Ethics
Officer

Jill M. Hutchison
Deputy General Counsel & Chief
Compliance Officer

cc:
Lise Spacapan
General Counsel
Office of Governor Bruce Rauner
Camile Lindsey
General Counsel
Illinois Department of Corrections
4

Exhibit A

MINUTES
Illinois Department of Corrections
Statewide Monthly Warden's Meeting
July 19th, 2016 at 10AM
130 I Concordia Ct. - Auditorium
Springfield, lllinois 62794

1. Call to Order
The Illinois Department of Corrections Monthly Warden's Meeting met on Tuesday, July 19th, 2016 at
1301 Concordia Ct, Conkle Auditorium Springfield, IL. Dire<::tor Baldwin started the meeting at 10:04

a.m.

-■

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I

•

8. Fiscal Updates

-■►

Presentation on IBF and EBF (see attached)

Adjourn
The meeting ended at 2:02PM

Exhibit Al

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Autho.rity

Statute
* 730 ILCS 5/3-2-2
* 730 ILCS 5/3-4-3

Administrative Directives
* 02.43.101 - General Provisions
* 02.43.102 - Expenditures
* 02.43.103 - Maintenance of
Funds

* Profits from vending machines
* Disbursement of profits from the Employees'
Commissary Fund

EBF Exf)@nditures.
_,.----------Appropriate
* All employees have a similar
opportunity to benefit
* Purchase or repair of recreational

* Operational expenses
* Items the State is required to

provide through A.D. or Illinois
Statute
equipment used by employees
* Entertainment events for employees * Items related to the safety of
employees
* A tribute to an employee or an
* Items related to the health care
employee's immediate family
and well-being of employees
* Advancement or reimbursement of * Items related to the security of
employees
travel funds ( as approved by Chief
* Items related to religious
Administrative Officer)
practices of employees
* Charitable contributions to
* Items that benefit inmates
community organizations

Correctional Centers

*

5 members

Transition Centers
* 3 members

*

At least one employee in
the RC-6 Bargaining Unit
( or the RC-14 Bargaining
Unit for General Office)

*

At least one employee in
the RC-6 Bargaining Unit
( or the RC-14 Bargaining
Unit for General Office)

*

Representative of the
Business Office

*

Representative of the
Business Office

EBF Committee

* Committees shall meet when necessary to review
requests for expenditures

* Minutes shall be kept for each meeting
* A copy of the meeting minutes shall be distributed to
each member

Submitti.n.g EB.F Reque·Sits

* In writing to a committee member to present at the
next me.eting

* Includes nature of expenditure
* Includes justification for use of Employee Benefit
Funds

*

Includes total approximate cost

EBIF Committee·Approval

* Committees meet to recommend approval or denial
of each submitted request

* Chief Administrative Officer shall approve or deny the
committee's recommendations in writing

* Chief Administrative Officer may override a
committee's denial by advising the respective Deputy
Director, in writing, of the reason for such action

Procuring it.ems for EBF

* All procurement laws must be fallowed
* All bid/procurement documents should be kept on file

Exhibit B

MINUTES
Illinois Department of Corrections
Statewide Monthly Warden's Meeting
April l 81\ 2018 at 10AM
1301 Concordia Ct. - Conkle Auditorium
Springfield, Illinois
1. Call to Order

The Illinois Department of Corrections Monthly Warden's Meeting met on Wednesday, April 18d1, 2018
at 10AM.

►

Concern - EBF's - purchasing you make that support the EBF statutorily we only have
authority to make purchases through commissary operations, not EBF's. as we standardize
structure has to be sold at l 0% marku .

►

►

►

Handout regarding gifts - IRS says we cannot give out gifts - but everybody can receive the
same, diminished or small in nature. We can't give away gifts that include cash, gift cards,
travel.
Recognition, EOM and EOY - gifts are income and have to be reponed. Can be awarded
intangible recognition, i.e. They can get a parking space, in the newspaper, etc. Document
provided has lots of options, use them. Food fund.raisers are fine.
Raffles - have to be done by the charity. We sell the tickets, need a license number from your
charity of choice. We cannot have the EBF as a benefactor for raffles.

Exhibit C

Frequently Asked Questions regarding the EBF

Q - How do we handle bereavement money for staff/staffs family?

A - If a check is issued, it must be made to a registered charitable organization. If money is to be given
to a staff member, the money must be collected from employees and the cash given directly to the staff
member, it CANNOT go through the EBF fund.
Q- Can car washes be given as a prize for employee recognition?
A - No, there are outstanding issues surrounding this topic. Additionally, a car wash has a monetary

value to the employee.
Q - Can a plaque be given to C/0, Employee or Volunteer of the year?

A - For any type of C/0 or Employee of the year, awards are directed by the statute to be provided in a
large ceremony funded by GRF. Funding for one plaque was to come from ICI and to be paid out of GRF.
Q- ls there a dollar amount limit for the tangible items given for Employee of the Month, Vear, etc.?

A - IRS Publication 5137 states "Awards for performance, such as outstanding customer service,
employee of the month, or highest productivity" are always taxable as wages to an employee on the
W2. Therefore it does not qualify as de minimis (no cash or anything of value should be given out), nor
does it meet the achievement award plan rules. If you are going to present the plaques to the
employees, the value of it would have to be included on their W2 handled by the IOC/payroll.
Q - Can we maintain a wall plaque display at the facility for employee recognition?
A - Yes, as it is not given to the employee and is kept at the facility (displayed on the wall).

Q- Can the EBF give retirement gifts?
A - Yes, it must be a tangible gift, the policy must be documented and it must be presented at a

meaningful presentation. Retirement gifts should not exceed $100.
Q - Can we sell out of the EBF?

A- This would need to be ran through ECOM with the applicable markup and profit splits.
Q-Are our EBFs considered a not-for-profit? What taxpayer identification number is associated with it?

A - The EBF is NOT considered a not-for-profit. To be considered a not-for-profit your organization
MUST BE registered as a charitable organization at the Secretary of State, the Attorney General, and you
must receive your Sales Tax Exempt letter from Illinois Department of Revenue.

By Illinois Statute, the

EBF is part of the State Government Agency Illinois Department of Corrections, and therefore uses the
same Federal Tax identification number and sales tax exempt number that we use for our normal
operating expenses. Only charitable registered not-for-profit organizations can hold raffles. (see next
FAQ).
Q- Since the EBF is not considered a charitable organization, can we still fundraise for charity?

A - You may still fund raise as part of SECA per the Illinois State Statue governing SECA. OR you may
contact a charitable organization and THEY get the raffle license in their name and number for your

Frequently Asked Questions regarding the EBF

event (and THEY get 100% of the proceeds and handle the tax documents) then you may conduct the
event (per approval from your Warden and legal).
Q - Why are we not considered a not for profit? We are regulated by the State of Illinois because we

are part of Corrections.
A - Not all nonprofits are charitable. Our legal status at IOOC is governmental - therefore all of our

funds fall under this status. Our EBFs do NOT have a separate legal status.
Q - Can 50/S0s and trivia nights be hosted by EBF7

A - Both 50/S0s and trivia nights require a raffle license to be obtained by a nonprofit with all proceeds
to go to a charitable organization. As DOC does not fit these requirements, we cannot have 50/S0s or
trivia nights unless a bona fide charitable organization applies for the raffle license with their name/ElN
and ALL proceeds benefit a charity.
Q - Are we allowed to have cookouts?

A - Cookouts need to processed through the commissary with the applicable markups and profit share
per the ADs. The EBF could provide the meal to all employees and ask for a donation to be made vs
selling the meal.

This is the current practice however it is being further reviewed and could change in

the future.
Q -

How does Springfield expect us to build the employee benefit fund for employee morale, do

employee appreciation week, Christmas dinner and all other events for the employees thoughout the
year?
A - There are very specific laws governing raffles and fundralsing. The law states that raffle licenses

must be in the name/EIN of a nonprofit and all proceeds must go to a charitable organization. IDOC
does not meet either of these requirements. AD 02.43.101 states the primary sources (the majority) of
revenue for the Employee Benefit Fund shall be profits from vending machines and disbursement of
profits form the Employee's Commissary Fund.
Q- Can the EBF pay the entry fee for the IDOC Pistol Shoots and golf tournaments etc.?
A - EBF expenditures are to benefit all employees, if you feel this meets the criteria you may proceed

with the expenditure. EBF cannot host a golf outing as ourselves as the beneficiary, any golf event must
be for an organized charity (again they must get the license and agree to handle all of the tax forms).
EBF cannot keep the proceeds from these events.
Q - We have a greenhouse that is worked by offenders. EBF purchases some soil, seeds, pots, etc.
Items are available for purchase by employees and all monies are deposited into the EBF. Is this still
allowed?

A - The EBF is not allowed to profit from offender's work.

Q- EBF is interested in purchasing and selling T-shirts and the memorabilia coin. Will we be able to sell
and at what percentage of profit can we set?

Frequently Asked Questions regarding the EBF

A - Tangible products bought to be sold for EBF profit needs to sold through the commissary at the set
markup and profit share amounts.

Q - At times an employee will purchase items for an EBF event and bring the receipt to us for
reimbursement. Ideally this is not the best practice but can we still do this?
A - Correct, this is not a good practice. All monies should be tracked through the EBF due to statute. If
it is an occasional one-off and all documentation is retained, it will probably pass audit. As more best
practices are followed from this document, this situation should decrease.

Q - We have a garden worked by offenders which was previously funded by EBF and now funded by
GRF. In prior years some of the vegetables were sold to staff and those funds were deposited into EBF.
Now all vegetables will be sent to Dietary for offender meals.

Excess won't be given to food

pantries/charities. To make sure we are following the proper process -we can no longer have "Farmer's
Markets" and deposit funds in EBF, correct?

A- correct, EBFs cannot profit/benefit from offender's work.
Q - Can we raffle off a parking spot to raise money for Special Olympics/LETR?
A - If SOIL obtains the raffle license in their name, EIN and handles any applicable tax work.

Q - Can we send out a flyer to allow staff to win a donated trip to Branson? Lines to purchase on the
board is going to be sold rather than tickets and a winning number is on a pull tab.

A- If it is a SOIL event, just posting flyers around the facility is not an accounting issue. You may want to
ask your legal regarding non-lDOC events over IDOC email and involving staff time. If this is a non-lDOC
event, you won't want to collect any checks into your EBF on its behalf. You need to confirm SOIL did
approve of the pull tab in their name and confirm who is filing the necessary IDOR forms since that is a
heavily regulated type of gambling in Illinois, the rules are far more restrictive than the raffle act.

Q - Are we allowed to raffle off gift cards? Or should we only raffle items (tangible property??
A - EBF is not allowed to raffle in the IDOC name. Raffles can be held if the license is obtained in the
charity name and EIN and all proceeds go to the charity (no funds are kept by the EBF).

OFFICE OF THE GOVERNOR
207 STAn HOL'St
SPRIXGF![LD, 1LUNOlS 6270(,

JB

PRITZKER

GOVERNOR

CONFIDENTIAL
January 8, 2020

Via Electronic Mail
Susan Haling
Executive Inspector General
Office of the Executive Inspector General
69 West Washington, Suite 3400
Chicago, Illinois 60602

Re: OEIG Complaint Number #17-01266- Updated Response to Final Report
Dear Executive Inspector General Haling:
This letter serves as an update to the Governor's Office January 11, 2019 response to the Office
of the Executive Inspector General's (OEIG) Final Summary Report in the above captioned
matter.
In its initial response, the Governor's Office accepted and agreed with the OEIG's findings and
outlined several actions taken to address the OEIG's recommendations. The Governor's Office
and the Illinois Department of Corrections ("IDOC") have since taken additional corrective
actions in response to the Final Summary Report.
A. Revised EBF Procedures and Training
Each IDOC facility maintains an Employee Benefit Fund (EBF). The EBFs were created and
governed by Administrative Directives (ADs) established nearly twenty years ago that failed to
provide sufficient guidance and oversight. At the direction of the Governor's Office, IDOC has
undertaken a comprehensive review of these ADs and made significant revisions to provide
procedures for the operation, maintenance, and expenditures ofEBFs.
Most significantly, the revised ADs create a Central EBF Committee (Central Committee) to
ensure compliance and oversight, and establish revised and specific directives for local EBF
Connnittees (Local Co1mnittees) at the facilities, including the requirement that Local
Committees have a minimum of five (5) members and a maximum of eight (8) members (not
including the Transitional Security facilities). Central Committee members, along with Local
Connnittee members, are required to be trained.

Further, the ADs: (1) specify allowable expenditures and provide procedures for processing
expenditures; (2) remove all mention oflocal Employee Imprest Funds, effectively revoking the
previous authority to establish imprest funds; (3) prohibit the comingling of EBF funds with
monies collected from employees with the express purpose of being charitable contributions; (4)
prohibit the solicitation of donations from any source other than individual employees; (5) limit
involvement in all EBF activities to no more than 2% of compensated work time (approximately
4 hours per month); and (6) establish a centrally shared site to which documentation related to
the Central Committee and local Committees shall be uploaded and stored, which will be
managed by the Chief Financial Officer.
Although the ADs have always required that the primary sources of revenue for the EBFs
normally come from employee vending machine profits and disbursement of profits from the
Employee Commissary Funds, the revised ADs clarify that any additional sources of revenue
must be approved by the Central Committee.
With respect to the common practice of collecting revenue for EBFs from merchandise sales,
EBFs will be required to purchase all merchandise from Illinois Correctional Industries to
address any tax reporting obligations. Finally, the ADs solidify that EBFs shall not profit or
benefit from offender labor and shall only be used for purposes expressly pennitted by State and
federal laws, and Department rules and policies.
On September 3, 2019, a Memorandum was distributed to all IDOC staff to infonn them of the
revisions to the EBF ADs and other ethics rules. See Exhibit A, IDOC Memorandum dated
September 3, 2019 (referred to hereafter as "September 2019 Memo"). In addition, IDOC
provided training for all EBF committee members on the revised ADs.
B. Use of State Time and Resources
In response to findings that an impermissible amount of state time and resources were being
spent on fundraising activities, IDOC employees, including EBF committee members, may now
spend a maximum of2% of compensated work time (approximately 4 hours per month) on EBF
and non-EBF fundraising activities. All employees who participate in fundraising activities,
including EBF committee members, must document the time spent on fundraising activities and
upload monthly time logs to a SharePoint site designated by the central fiscal office.
C. Raffles
The Illinois Raffle and Poker Runs Act limits the types of entities that may receive raffle
licenses. See 230 ILCS 15. The OEIG found that the EBF at several IDOC facilities have
improperly obtained raffle licenses. The Governor's Office agrees with these findings and
directed the Deparhnent to issue appropriate guidance to its employees.
The September 2019 Memo informed all IDOC staff of the prohibition on the sale of raffle
tickets on state property for any fundraising activities unless properly licensed under the Illinois
Raffles and Poker Runs Act. Staff were infonned that EBFs and individual correctional facilities
do not qualify to receive raffle licenses under the law and that conducting a raffle without a valid
license is illegal.

2

D. Offender Donations
The September 2019 Memo informed IDOC staff that state employees may not solicit or
incentivize offenders to donate to charitable organizations or contribute to fundraisers, including
incentivizing offenders with the promise of an enhanced meal or outside food and beverage with
a donation going to a charitable organization.
E. Former !DOC Acting Director John Baldwin
The OEIG found that IDOC's Acting Director, John Baldwin, mismanaged the EBFs and
violated the Unified Code of Con-ections' prohibition against using inmate labor for non-public
purposes. The OEIG recommended that the Office of the Governor respond to these findings by
taking whatever action it deemed appropriate. In May 2019, Governor Pritzker replaced Mr.
Baldwin and appointed Rob Jeffreys as director ofIDOC.
F. Former IDOC Chief of Staff Edwin Bowen
While serving as IDOC's Chief of Staff, Edwin Bowen was found by the OEIG to have
mismanaged the EBFs and violated the Unified Code of Corrections' prohibition against using
imnate labor for non-public purposes. Mr. Bowen is no longer acting in this capacity and is now
serving as Public Service Administrator over Jail and Detention Standards. In this position, Mr.
Bowen does not have a role in the oversight or management of the EBFs.

In addition, at the direction of the Governor's Office, IDOC served Mr. Bowen with disciplinary
charges on October 21 , 2019 and a hearing was conducted on November 6, 2019. Due to the
severity of the infractions, the hea1ing officer concluded that a (30) day suspension was
warranted. Mr. Bowen served this suspension from November 30, 2019 to December 30, 2019.
Mr. Bowen has since initiated the grievance process in connection with this suspension.
If you have any questions or require any further information with respect to this response, please
contact gov.compliance@illinois.gov.
Sincerely,

Whitney Rosen
Deputy General Cotmsel & Ethics Officer
Office of Governor JB Pritzker

3

OFFICE O F THE GOVERNOR
207 STATE H OUSE
62706

SPRINGFIELD, ILUNOIS

JB PRITZKER
G OVERNO R

October 4, 2021
Via E-Mail to Antoinette Kwateng on behalf of:
Susan M. Haling
Executive Inspector General
Office of Executive Inspector General
69 West Washington, Suite 3400
Chicago, Illinois 60602
Re:

OEIG Case Complaint No. 17-01266 –
Final Response to Final Report

Dear Executive Inspector General Haling:
This letter serves to update and conclude previous responses to the Office of the Executive
Inspector General’s (OEIG) Final Summary Report in the above captioned matter.
The Governor’s Office previously accepted and agreed with the OEIG’s findings and
identified corrective actions taken in response to the Final Summary Report. The most recent
update noted former Chief of Staff Edwin Bowen grievance of his 30 day suspension (November
30, 2019 to December 30, 2019). The grievance process has concluded. Following a full hearing
on Mr. Bowen’s grievance, the Hearing Panel reduced the discipline from 30 days to 15 days on
April 28, 2021.
If you have any questions or require any further information with respect to this response,
please contact gov.compliance@illinois.gov.
Sincerely,
/s/ Ann M. Spillane
Ann M. Spillane
General Counsel