Put employee assistance contracts on the settlement account

The Township paid its employee assistance program contracts from the Employee Wellness general fund line 01-20-101-290 every year from August 2020 through August 2024. From 2022 on the vendor history shows a recurring pair, 2,532.60 for the police contract and 5,600.00 for the non-police departmental contract. In 2020 and in 2021 it shows a single 2,532.60 payment. The last Employee Wellness payment is check 69170 on 08/06/2024. The first payment from the National Opioids Settlement account is check 71640 on 07/08/2025. The 2025 and 2026 renewals are the same product at the same prices, charged to the opioid account. One purchase order caption repeats the general fund years word for word, ANNUAL CONTRACT/EAP SERVICES. 5,600.00 on 07/08/2025 plus 2,532.60 on 10/07/2025 plus 2,532.60 on 04/07/2026 equals 10,665.20. A payment falls in every calendar year from 2020 through 2026. The scope did not change, only the fund that pays. That is substitution of settlement funds for an existing source of funding for the same expense, which N.J.S.A. 26:2G-39(f) bars. The vendor payment histories show 40,128.20 of these contracts bought since 2020, of which 29,463.00 was paid from the general fund before the opioid account took over. The FY2026 report, published 10/01/2026, certifies the three payments, 10,665.20 to the cent, as an Employee Assistance Program, and gives 01/01/2020 as the date the program was funded and launched (pages 8 and 9). By the Township's own report, the program predates the settlement money that now pays for it.