Details of Alleged MA Initiative Campaign Finance Violations In New OCPF Complaints
Part 2 of a series. Part 1 can be found here.
In a new series of complaints to the Massachusetts Office of Campaign and Political Finance (OCPF), former staff members of the 2024 Massachusetts psychedelic ballot initiative say a pattern of communications to 501(c)(3) nonprofit groups from a campaign consultant allegedly sought to conceal the staffer’s political activities.
Graham Moore and Jamie Morey – both former staffers on the Yes on 4 campaign – say they were instructed by the consultant not to disclose any connection to the campaign on invoices and contracts they sent to two nonprofits who advocate for access to psychedelics.
The failed initiative which would have legalized psychedelic-assisted therapy services and decriminalized personal use and home cultivation of certain psychedelics, raised millions of dollars and was leading slightly in the polls just a week before the election, only to fail decisively at the ballot box.
The Yes on 4 initiative, also known as Massachusetts for Mental Health Options (MMHO), was first proposed by Washington, D.C.-based New Approach PAC. As reported in part 1 of this series, New Approach’s political action committee served as a major financial backer of Yes on 4 and led prior psychedelic ballot initiatives in Oregon, Colorado and other states. The complaints allege that New Approach and Yes on 4, used nonprofit organizations as part of their political operation, allowing the campaign to raise and spend money without the transparency required by law.
According to the allegations, the staff of New Approach PAC and the New Approach Advocacy fund raised at least $7.25 million for the campaign of which an estimated $6.5 million was raised for the Yes on 4 campaign and at least $750,000 for the Heroic Hearts Project (HHP), a (501(c)(3). Moore and Morey further allege that HHP then gave at least $200,000 of these funds to the 501(c)(3) organization Open Circle Alliance, co-founded in part by Yes on 4 Grassroots Campaign Director Emily Oneschuk. HHP also gave $22,000 to the 501(c)(3) Students for Sensible Drug Policy for campaign outreach. Neither of these organizations allegedly disclosed this funding as in-kind donations or registered as a referendum committee as required by law for organizations soliciting donations for a ballot question.
Part 1 of this series documented the first complaints last month about alleged improprieties filed by Moore and Morey. In that report, Heather Ferguson, director of state operations for the campaign finance watchdog group Common Cause, noted that when donors give money to 501(c)(3) tax-exempt organizations, these groups are not permitted to use those funds for electioneering, only public education.
In their complaints, Moore and Morey alleged that OCA functioned as an extension of the Yes on 4 referendum committee. As reported in part 1, Oneschuk’s dual-leadership of the campaign and as treasurer of OCA raises questions about the group’s claim that OCA was, “not associated with the Yes on 4 Campaign.”
One of the latest complaints specifically points out the alleged conflicts in Oneschuk’s dual-roles with OCA and the campaign. “Oneschuk, while simultaneously being paid a 6-figure salary by the ballot question committee, served as the treasurer of the new nonprofit, Open Circle Alliance, which functioned as an extension of the campaign’s political operation,” reads the complaint. Oneschuk did not reply to multiple requests for comment regarding this allegation.
Moore and Morey further allege that HHP and OCA together raised more than several hundred thousand dollars for the Yes on 4 campaign. Under campaign finance laws, neither organization is allowed to raise money for political purposes without declaring it as a political or campaign related contribution.
According to Moore and Morey, the alleged violations had far reaching implications. “The consequence was MA voters were denied the transparency they were entitled to about the sources and extent of spending to influence their votes, and donors were denied transparency about how their money was being spent to support the ballot question, since 501(c)(3) spending is not subject to the same disclosure requirements as ballot question committee spending. A situation in which fraudulent contracts are used to compensate individuals is ripe for abuse.”
Jessie Gould, executive director and founder of HHP declined to respond to the most recent complaints. In a prior statement regarding the first round of complaints, Gould said that, “we are aware that a complaint has been filed. We don’t comment on pending complaints or ongoing matters under review. OCPF hasn’t elevated these isolated claims or issued any findings or determinations, so we will respect that process. We always remain committed to transparency and integrity in all of our activities and will continue to move forward with the important work of serving veteran families.”
SSDP leadership also did not respond to requests for comment on the allegations.
While OCA did not provide a comment to Lucid News about the latest complaints, an article about the allegations published by The Boston Globe included a statement by the OCA asserting that the organization did not receive any funding “from the campaign or New Approach.” As previously reported by Lucid News, an email sent by OCA co-founder Stefanie Jones to fellow Massachusetts psychedelic advocates on March 24, 2025, acknowledged however, that, “the original idea and funding for a community org originated in collaboration with New Approach.”
$10,000 was also paid to Morey and $6,000 to Moore through what the former staffers say were fraudulent contracts and invoices from HHP. The former staffers say that their contracts specifically say that they do not cover compensation for lobbying and campaign work as defined by law. In the latest three of the 8 total complaints filed with the OCPF, Moore and Morey say the payments that they and OCA received should have been earmarked as “in-kind” contributions to staffers in accordance with state law.
The new complaints filed on July 3 with the OCPF include documentation and correspondence provided by Moore, with text messages indicating that Morey was explicitly told not to characterize payments received for her work as connected to the campaign. HHP declined to comment on the allegations of fraudulent contracts and invoices.
Contradictory Claims
The information included in the new OCPF complaints appear to contradict statements by Jared Moffat, a senior campaign consultant and now-former policy director for the New Approach Advocacy Fund, a social welfare organization based in Washington, D.C. Advocacy funds primarily focus on influencing policy through lobbying, public awareness campaigns, and other non-electoral means, while PACs are specifically designed to pool campaign contributions and donate those funds to campaigns for or against candidates, ballot initiatives, or legislation.
In a statement provided in response to a request for comment on the latest complaints filed with the OCPF, Moffat strongly rejected any claim that the Yes on 4 campaign violated campaign finance laws.
“The campaign has consistently followed the guidance of experienced legal counsel and has fully complied with all applicable campaign finance rules and regulations,” wrote Moffat. “Any allegation suggesting that the campaign failed to properly report its activities is false. The campaign has been diligent and transparent in its reporting obligations and stands by its record of compliance.”
The complaints allege that HHP’s “public education” TV ad was created by the Yes on 4 referendum committee. Emails provided by Morey and Moore also appear that Moffat personally directed payments from HHP to SSDP, Morey and Moore. Emails and text messages between Moffat, Moore, and Morey included in the latest OCPF complaints appear to show Moffat instructing the staffers to note in their contracts that their work on the campaign was instead part of a post-election psychedelic “public education project.”
A portion of Moore and Morey’s fees for their campaign work were paid by HHP. In a separate email to Gould, Moffat asks Gould to co-sign a one-time payment to Morey for a “public education project,” but Morey contends that she never did any public educational work beyond the campaign.
When asked “why the change on the contract?” In relation to $10,000 worth of campaign-related work to be paid by HHP after the election, Moffat told Morey “we ended up with a little bit extra $ in the campaign in last minute donations.” He directed Morey to send her invoice to Gould and “change the title of the invoice,” saying it “can’t be ‘yes on 4.’”
“These are serious allegations and they warrant review by the Office of Campaign and Political Finance,” said Maya Majikas, Communications Strategist for Common Cause. Majikas added that the latest round of complaints “underscores the need for greater transparency in the ballot question disclosure process.”
Moffat said that the Yes on 4 campaign has not been contacted by OCPF or any regulatory agency regarding the allegations. “Should any regulator contact us, the campaign will cooperate fully and comprehensively with any inquiry. The campaign is confident that any investigation will confirm its compliance with all applicable laws and regulations.”
The OCPF review will need to determine whether these instructions to staffers violate Massachusetts state campaign finance law, which states that “no person shall, directly or indirectly, make a campaign contribution… in any manner for the purpose of disguising the true origin of the contribution.”
Why Does Disclosure of Donors Matter?
While this seemingly nuanced dispute might be a non-starter in other states, Massachusetts’ campaign finance laws are strict about these sorts of disclosures. In 2016, Families for Excellent Schools, a New York-based charter school faced similar scrutiny when they contributed more than $15 million to a ballot initiative to help expand charter school programs in Massachusetts. At the time, an OCPF investigation found that the group was used “as a passthrough for wealthy donors” – two of whom were high-ranking members in the administration of then-Governor Charlie Baker.
Families for Excellent Schools said they “relied in good faith” on the information they’d been given by the school, but were forced to pay nearly half a million dollars in fines, the highest penalty of its kind in state history.
Morey and Moore said that HHP was likely kept in the dark about how the money they raised to educate the public about psychedelics had been used.
“We greatly respect the work Heroic Hearts Project has done in providing care to veterans, and we believe the organization was misled and misused by the campaign,” said the former staffers.
Gould of HHP declined to comment as to whether the organization was misled by the campaign or unaware of campaign finance or reporting requirements.
Former Campaign Staffers Say Consultants Cut Corners
After serving on the Question 4 campaign, Morey founded Mass Healing – a 501c(3) nonprofit organization, “dedicated to improving public health and wellness by making psychedelic therapies affordable, accessible, and legal” – with Moore joining the new organization earlier this year.
As for why they chose to come forward and speak out about the Yes on 4 campaign, the former staffers say they felt obligated to alert state officials.
“We decided to come forward after uncovering serious misconduct, including potential violations of campaign finance laws,” said Moore and Morey in a statement. “The lack of transparency by the campaign raised the probability of misuse of funds, embroiled well-meaning supporters in possibly illegal activity, and, in a state where rival campaigns routinely levy accusations of campaign finance violations, needlessly threatened the viability of the campaign.”
In response to the latest OCPF complaints, Gould reiterated his organization’s commitment to complying with campaign finance law. Gould asserted that HHP “does not and cannot speak on behalf of other organizations or individuals named in these filings.”
While the OCPF maintains a strict policy of not commenting on the, “existence of complaints or investigations,” Moore and Morey confirmed to Lucid News that they have been notified by OCPF Deputy General Counsel Maura Cronin via email that she has been assigned to investigate the complaints.
This article was published in a partnership between Lucid News and The Boston Institute for Nonprofit Journalism. This article is syndicated by the MassWire news service of the Boston Institute for Nonprofit Journalism.