Sturdy Memorial Associates Inc

“Form 990, Part V, Line 2a Sturdy Memorial Hospital, Inc. is the common paymaster for Sturdy Memorial Associates, Inc. Form W-3 is filed under Sturdy Memorial Hospitals employee identification number and included 376 Sturdy Memorial Associate, Inc. employees. Federal Employment tax Returns Form 990, Part V, Line 2b Sturdy Memorial Hospital, Inc. is the common paymaster for Sturdy Memorial Associates, Inc. and files all required federal employment forms.”

“Form 990, Part VI, Section A, Line 6 Sturdy Memorial Foundation, Inc., a Massachusetts charitable corporation, acting through its Board of Directors, is the sole member of Sturdy Memorial Associates, Inc.”

“Form 990, Part VI, Section A, Line 7a Foundation members are eligible to attend all meetings of the Corporation and to hold office. New members are elected to membership by the existing members for three year terms. The Members elect and may remove or suspend trustees of Sturdy Memorial Associates, Inc.”

“Form 990, Part VI, Section A, Line 7b All matters involving real property, including without necessary limitation, sales, leases and purchases, shall first require approval of the Member acting through the Board of Directors of Sturdy Memorial Foundation, Inc.”

“Form 990, Part VI, Section B, Line 11b THE FORM 990 IS PREPARED BY STURDY MEMORIAL'S TAX PROVIDERS, GRANT THORNTON LLP, USING INFORMATION PROVIDED BY MANAGEMENT UPON COMPLETION OF THE ANNUAL INDEPENDENT AUDIT. THE INFORMATION PROVIDED IS THE RESPONSIBILITY OF THE CFO AND THE STURDY FISCAL SERVICES DEPARTMENT. THE RETURN IS REVIEWED BY GRANT THORNTON LLP, THE CONTROLLER AND CFO, AND compensation and benefit sections are specifically reviewed BY THE VICE PRESIDENT OF HUMAN RESOURCES FOR STURDY MEMORIAL HOSPITAL, INC. THE FORM 990 IS THEN PRESENTED TO THE AUDIT COMMITTEE FOR REVIEW AND RECOMMENDATION OF APPROVAL. PRIOR TO FILING THE FORM 990 WITH THE INTERNAL REVENUE SERVICE, THE COMPLETE FORM AND ALL SCHEDULES ARE PROVIDED TO EVERY BOARD MEMBER AND ANY QUESTIONS ARE ANSWERED.”

“Form 990, Part VI, Section B, Line 12c Sturdy Memorial Associates, Inc. follows the Conflict of Interest Policy of Sturdy Memorial Hospital, Inc., its affiliate. Under the direction of the Hospital's Integrity Officer, all managers and supervisors (including officers and key employees) must complete and sign an annual Conflict of Interest Disclosure Statement. The Statement requires disclosure of any outside interests in any business, outside activity, gifts or entertainment that may have influenced the employee. In addition, the employee must disclose if they have shared any hospital information for their own personal advantage or if they had knowledge of any integrity or ethical issues not previously reported. These signed statements are reviewed by the Integrity Officer and any potential conflicts are resolved. The Integrity Officer discusses disclosed conflicts with the reporter, so that the reporter knows what business activities they cannot participate in (e.g., purchasing decisions, board votes, etc.). Any gifts received that create a conflict or are in violation of the Conflict of Interest Policy must be returned or paid for by the individual at fair market value. CONFLICTED INDIVIDUALS ARE NOT ALLOWED TO VOTE ON AREAS RELATED TO THEIR CONFLICT OR PARTICIPATE IN OTHER DECISIONS SURROUNDING THE ENTITY THEY HAVE A CONFLICT WITH. The Integrity Officer reports annually to the Board of Directors of any new conflicts. Article VI of the Associates by-laws requires Board members to disclose any potential conflict. Board members, officers and key employees must attest in writing each year, to any potential conflict. The Conflict of Interest Statements are reviewed by the Executive Director and Chief Financial Officer and any potential conflicts are resolved. DOCUMENT RETENTION AND DESTRUCTION POLICY Form 990, Part VI, Section B, Line 14 During fiscal year 2016 Sturdy Memorial Associates did not have a written document RETENTION and destruction policy but does comply with Massachusetts law with respect to record retention requirements. Where state law does not require retention limits, the Associates uses the "Business Records Retention Schedule" from the Office of the Federal Register and other relevant and reliable sources (such as attorney letters and recommendations from accounting forms). A formal policy has been drafted and is expected to be implemented in fiscal year 2017.”

“Form 990, Part VI, Section B, Line 15 The CEO (Executive Director), the CFO and the Director of Operations of Sturdy Memorial Associates, Inc. are compensated entirely through Sturdy Memorial Hospital, Inc. which is why there is no compensation reported on Form 990, Part VII, column D. The CEO and senior managers listed on the Form 990 are compensated on a merit system, as part of their compensation review in Sturdy Memorial Hospital, Inc. The CEO and senior managers prepare goals at the start of each fiscal year and are evaluated for merit increases based on those goals and their accomplishments relative to the goals. The CEO's accomplishments (relative to the established goals) are documented in an annual report which is submitted to the Chairman of the Board of Managers. The Board Chairman is provided with comparative market data obtained through compensation surveys prepared by an independent consultant specializing in such matters. The comparative data is for similar hospitals in Massachusetts and is sent directly from the independent consultant to the Board Chairman. The data includes comprehensive salary and benefits information for CEOs and senior managers (key employees) including comparison of base pay, incentive pay, benefits and total compensation. In addition, the Chairman is provided with performance information for Massachusetts hospitals obtained through the Massachusetts Center for Health Information & Analysis. The Hospital's Vice President of Human Resources provides the Chairman with the CEO's current actual salary and benefits. The Chairman of the Board of Managers provides the above information along with the annual report of the CEO's accomplishments (relative to established goals including the hospital and the Associates) and a history of the CEO's compensation to the Executive Committee which serves as the Compensation Committee for this purpose. The Executive Committee reviews the comparative data for the CEO base salary, bonus (incentive) and total compensation along with the survey data for benefits. Based on the goals achieved and the comparative data provided, the Executive Committee votes to approve the salary, bonus and benefits of the CEO. A summary of the discussion and the decision of the Executive Committee are reflected in the meeting minutes. The Chairman of the Board of Managers communicates the decision regarding compensation changes in a letter to the Vice President of Human Resources to execute the change. The CEO uses comparative market data, obtained from an independent consultant, for the hospital senior managers. The CEO compares the senior managers current base salary and bonus (incentive pay) to the survey data. The senior managers' performance is evaluated based on the goals established at the start of the year. The CEO determines the base pay amount and bonus for each senior manager based on performance and the compensation survey. Base salary and bonus payments for each senior manager, including survey information, are reviewed with the Executive Committee by the CEO. The Executive Committee votes to accept the recommendations of the CEO for all senior managers except the CFO. The Executive Committee votes to approve the CFO's compensation separately.”

“Form 990, Part VI, Section C, Line 19 Sturdy Memorial Associates, Inc. makes available copies of its by-laws, the conflict of interest policy of Sturdy Memorial Hospital, Inc. and financial statements to the public upon request.”