Conflict of Interest Queries Engulf DHCD Director

Conflict of Interest Questions Surface Over Leticia De Lara

PALM SPRINGS — First, conflict of interest questions surfaced over former Desert Healthcare District CEO Dr. Conrado Barzaga. Now, Director Leticia De Lara finds herself in a similar predicament.

De Lara has a financial interest in money the District’s Board of Directors has given the Regional Access Project. She is the CEO of RAP.  And because she has a financial interest, the DHCD Board is prohibited by law from entering a contract even if the board member recused him or herself according to the Government Code 1090.

According to Government Code 1090 (See FPPC attachment) “Initially, we note that when Section 1090 applies to a member of a governing body of a public entity, the prohibition generally cannot be avoided by having the interested board member abstain from the decision. Rather, the entire governing body is precluded from entering the contract. (Thomson, supra, at pp. 647-649.)”

De Lara’s salary is drawn from contracts and grants coming to RAP.

According to section 1091.5 (8), De Lara and the rest of the Board would be exempt if De Lara was an uncompensated officer of RAP.

Sparked by civic vision recognizing how vital nonprofits are in strengthening our communities, the Regional Access Project Foundation (RAP) identified a need for programs and services that would empower nonprofits to become more efficient and effective. Nonprofit Organization Centric (NPO Centric) was founded in 2016 to provide essential tools, knowledge, and skills to help nonprofits build their capacity and become vibrant and sustainable organizations.

NPO Centric is a subsidiary of RAP – Regional Access Project Foundations.

IRS nonprofit search website does not list NPO Centric as a separate entity from RAP.  https://apps.irs.gov/app/eos/

DHCD agenda and minutes shows that NPO is part of RAP: https://www.dhcd.org/media/2393/02-14-23%20PC%20District%20Signed%20Minutes.pdf

In the audio/video recording, staff member Donna Craig states that this is not a grant to RAP/NPO, but a vendor contract.  However, the staff report shows that the funds would come from the District’s 22/23 Grant Budget.

NPO Centric received a $250,000 contract from DHCD to draw down over two years in February 2023 according to this April 2023 release. 

This contract should be voided according to California law, according to some obssesrvers.

This is why Government Code 1090 is so important.

Here is an example of an elected board member who is one of seven bosses for the district’s CEO, who supervises staff that decides on who should or should not be presented to the Board to receive a $250,000 grant over two years.