Sturdy Memorial Hospital Inc

“The bylaws of Sturdy Memorial Hospital state that "the Executive Committee shall have the power to transact all regular business of the Hospital during the interim between the meetings of the Board of Managers except for such matters as are specified in Section 55 of the [Massachusetts] General Laws, Chapter 156B." The Executive Committee consists only of members of the Board of Managers of Sturdy Memorial Hospital.”

“Sturdy Memorial Foundation, Inc., a Massachusetts charitable corporation, acting through its Board of Directors, is the sole Member of the Sturdy Memorial Hospital Corporation.”

“The Board of Managers of Sturdy Memorial Hospital consists of those persons who serve as the Directors of Sturdy Memorial Foundation, Inc. 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 3 year terms.”

“The preparation of the Form 990 is the responsibility of the CFO and the Sturdy Fiscal Services department, with review by Sturdy's tax providers, Grant Thornton. The Form 990 is prepared by the finance staff upon completion of Sturdy's annual independent audit and reviewed by the Controller, CFO, and Grant Thornton. In addition, compensation and benefit sections are reviewed by the Vice President of Human Resources for Sturdy Memorial Hospital. Prior to filing the Form 990, the complete form and all schedules are provided to every board member and any questions are answered.”

“Under the direction of the 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 any 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 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 Managers of any new conflicts. Article V, Section 12 of the Hospital 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 President and Chief Financial Officer and any potential conflicts are resolved.”

“The hospital does not have a written document retention and destruction policy but does comply with Massachusetts law with respect to record retention requirements. For example, Massachusetts law requires that the hospital maintain its medical records for a minimum of 20 years. Where state law does not require retention limits, the hospital 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 firms). The hospital has begun drafting a formal policy.”

“The CEO and senior managers, as well as all other hospital employees, are compensated on a merit system. 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 evaluation extends to his/her responsibilities as the Chief Executive of Sturdy Memorial Associates (an approximately fifty-nine physician multi-specialty group practice) as well as her responsibilities at the remaining affiliated corporations. The CEOs compensation is paid entirely by the hospital (there is no additional compensation from the related organizations). Several of the other senior managers have responsibilities that extend to the affiliated corporations and their compensation is paid entirely by the hospital as well (there is no additional compensation from related organizations). 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 Center for Health Information and Analysis. The 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) 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 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 (key employees). 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 except for the CFO, the Executive Committee votes to approve the CFO's compensation.”

“The hospital does not have a written policy or procedure requiring the hospital to evaluate its participation in joint venture arrangements under applicable federal law; however, any joint venture agreement would be reviewed and approved by outside counsel. The hospital currently has two partnership agreements. The first agreement provides radiation therapy services (LLC). The patient volume, from the hospital's service area alone, would not have justified the cost of purchasing the radiation therapy building and equipment as well as providing the service. The hospital partnered with a for-profit company which specializes in building and managing radiation therapy services. The LLC is governed by a Board consisting of two people, one from each organization, thus ensuring that the not-for-profit hospital has sufficient control over the organization to ensure its exempt purpose. In addition, Article I of the LLC Agreement, requires that the LLC "shall operate under a charity care policy that is consistent with the charity care policies of its charitable Members". The LLC has not engaged in activities that would jeopardize the hospital's exemption, such as substantial lobbying activities. The second agreement is an investment in Yankee Alliance Supply Chain Solutions LLC. This investment produces unrelated business income which has been reported on the Hospital's 990T.”

“The Hospital makes available copies of its by-laws, conflict of interest policy, and financial statements to the general public upon request.”

“Linda Shyavitz served as President & CEO until 3/1/14 and was replaced by Bruce Auerbach, MD on 3/2/14.”

“The hospital provides high quality care to the sick and injured, on both an inpatient and outpatient basis, without regard to race, creed, national origin, age, gender, disability, or ability to pay. In fiscal year 2014, the hospital provided 6,003 free care visits and 218 partial free care visits. The hospital treated 8,832 inpatients and observation patients, including births, of which there were 737. The hospital treated 51,551 patients in the emergency room during the year. The hospital performed surgery on 1,931 inpatients and 7,254 outpatients. The hospital provides many other services of which the following is a partial list: Oncology - 7,396 visits; Mansfield Health Center - 22,084 visits; Cardiac Rehabilitation - 13,322 visits; Wound Care - 4,572 visits; and Cardiac Catheterizations - 116 procedures. In addition, the hospital provides a variety of ancillary services - a partial list includes: laboratory, radiology, mammography, computerized tomography, MRI, nuclear medicine, vascular, ultrasound, sleep study and physical therapy. The hospital provided $5,534,819 in services for those who could not pay (free care) or would not pay (bad debt) in fiscal year 2014. In addition, the hospital provided approximately $3,069,007 in un-reimbursed MassHealth (Medicaid) services during the year. Further, the hospital provides a number of programs to benefit our community either at no charge or at reduced rates. The hospital also provides leadership in the integration of health services for the communities it serves.”

“Sturdy Memorial Hospital is a common paymaster for Sturdy Memorial Associates and Sturdy Memorial Foundation. Therefore, the total number of employees listed in Part V, line 2a includes only employees from the Hospital (1,639). The total number of employees on the Form W-3 is 2,018.”

“Pension and other postretirement benefit adjustment.”