Beth Israel Lahey Health Specialty Care F/K/A Northeast Medical Practice

“For the period covered by this filing, beth israel lahey health, inc. (bilh) served as direct or indirect sole member of: beth israel deaconess medical center, inc. (bidmc), mount auburn hospital (mah), new england baptist hospital (nebh), beth israel deaconess hospital milton, inc. (milton), beth israel deaconess hospital needham, inc. (needham), beth israel deaconess hospital plymouth, inc. (plymouth), lahey clinic foundation (lcf) , lahey clinic (lci), lahey clinic hospital d/b/a lahey hospital and medical center (lhmc), winchester hospital (winchester), northeast hospital corporation (northeast), anna jaques hospital (ajh), beth israel lahey health pharmacy, joslin diabetes center, exeter health resources, inc. (ehri) and exeter hospital. Each of these affiliates may have, in turn, served as member of additional entities within the bilh network of affiliates. In addition, harvard medical faculty physicians at beth israel deaconess medical center, inc. (hmfp) is the dedicated physician practice of bidmc and an entity integrally related to helping bidmc and other affiliates in the bilh network accomplish their charitable purposes. For this same period hmfp served as the sole member of affiliated physicians of harvard medical faculty physicians at beth israel deaconess medical center (aphmfp) as well as the direct or indirect member of several additional entities. Two or more of the persons listed in this form 990 part vii have a business relationship with each other by virtue of sitting on one or more boards of directors/trustees or by serving in an employment relationship with one or more entities within the network of the affiliated organizations noted above. Additional detail is provided in the explanatory notes to this form 990 schedule j.”

“For the period covered by this filing, beth israel lahey health, inc. (bilh) served as direct or indirect sole member of: beth israel deaconess medical center, inc. (bidmc), mount auburn hospital (mah), new england baptist hospital (nebh), beth israel deaconess hospital milton, inc. (milton), beth israel deaconess hospital needham, inc. (needham), beth israel deaconess hospital plymouth, inc. (plymouth), lahey clinic foundation (lcf) , lahey clinic (lci), lahey clinic hospital d/b/a lahey hospital and medical center (lhmc), winchester hospital (winchester), northeast hospital corporation (northeast), anna jaques hospital (ajh), beth israel lahey health pharmacy, joslin diabetes center, exeter health resources, inc. (ehri), exeter hospital and to affiliates of these entities.”

“A majority of the northeast medical practice, inc.'s board serve in their position ex-officio.”

“A majority of the northeast medical practice, inc.'s board serve in their position ex-officio. Not withstanding any provisions to the contrary, any action taken by the board with regard to the following matters shall not be effective without the approval of the sole member: (a) execution of any unbudgeted debt instruments, notes, guarantees, mortgages or pledges above $50,000 require approval of the sole member; execution of any unbudgeted debt instruments, notes guarantees, mortgages or pledges of $50,000 or less require approval of the president of the sole member as well as the board of this corporation. (b) execution of any unbudgeted contracts for sale, lease, exchange, or other disposition or acquisition of property, real or personal, (i) having an annual or single transaction cost in excess of $100,000 shall require approval of the sole member and (ii) having an annual or transaction cost in excess of $50,000 shall require approval of the president of the sole member. (c) incurrence of any unbudgeted expenses (i) in excess of $50,000 shall require approval of the president of the sole member and (ii) in excess of $250,000 shall require the approval of the sole member. (d) execution of any unbudgeted contracts generating annual revenue in excess of $100,000 shall require approval of the president of the sole member and (ii) generating annual revenue in excess of $400,000. Shall require approval of the sole member. (e) filing of petitions for voluntary dissolution or for voluntary bankruptcy. (f) adoption of amendments to the by-laws or articles of organization, such power to be exercised exclusively by the sole member. (g) adoption of annual operating and capital budgets. (h) adoption or significant revision to any long-range strategic plan, business development plan, or any action requiring the filing of an application for a determination of need or any significant transaction having long term strategic implications. (i) acquisition of the corporation or its assets by another entity or consolidation of the corporation with any other entity whether accomplished through acquisition, merger, consolidation or delegation of control powers or acquisition of another entity by the corporation. (j) appointment of trustees of the corporation, such power to be exercised exclusively by the sole member. (k) removal of trustees of the corporation, such power to be exercised exclusively by the sole member after notice to the chairperson of the corporation and an opportunity for the chairperson to be heard by the board of trustees of the sole member, except in circumstances where the sole member determines that an immediate removal action is necessary to preserve the assets of the corporation. (1) any decision concerning the exercise or non-exercise of veto power heldby the corporation relative to the actions of any corporation of which the corporation is the controlling member. (m) the power to select and remove any or all officers of the corporation shall be exercised solely by the sole member after consultation with the chairperson of this corporation. (n) the power to appoint and remove the chairperson of this corporation shall be exercised exclusively by the sole member after consultation with the board of trustees of this corporation and an opportunity for that board to suggest candidates. (o) compensation for the president/chief executive officer and all senior executives (cumulatively "senior executives") of this corporation shall be set by the president of the sole member and shall be subject to approval by the compensation committee of the board of the sole member. The term "compensation" shall include, but not be limited to, salary, bonuses, severance benefits, deferred compensation (whether provided through salary deferral, insurance vehicle, serp or other retirement funding vehicle), any payment, contingent or otherwise, which is intended to provide funding or other benefits to the senior executives whether vesting immedia”

“As noted in various disclosures throughout this filing, beth israel lahey health, inc. (bilh) is the direct or indirect sole member of beth israel lahey health specialty care f/k/a northeast medical practice. This form 990 is prepared by the bilh tax department in conjunction with deloitte tax, llp (deloitte). As part of this process, the bilh tax department works with other disciplines and functions within bilh and beth israel lahey health specialty care f/k/a northeast medical practice to ensure that all financial and non-financial disclosures are complete and accurate. Examples of such departments include but are not limited to: finance and accounting, human resources and payroll, treasury, compliance, legal, community benefits, financial assistance and reimbursement, governance, development, graduate medical education, government relations, research and/or research finance. Beth israel lahey health specialty care f/k/a northeast medical practice's form 990 is reviewed internally by the bilh assistant vice president, taxation and externally by deloitte. Beth israel lahey health specialty care f/k/a northeast medical practice's form 990, along with the forms 990 of all entities in the bilh network, are discussed with the bilh audit and compliance committee. Deloitte signs the final returns. A copy of the complete return is then provided to each member of beth israel lahey health specialty care f/k/a northeast medical practice's board of trustees prior to submission to the internal revenue service.”

“As noted throughout this filing, beth israel lahey health specialty care f/k/a northeast medical practice is a member of the beth israel lahey health (bilh) system of affiliates. All entities in the bilh network adhere to the bilh conflict of interest policy and maintain a written, comprehensive conflict of interest policy at the entity level. Pursuant to these policies, bilh entities' officers, trustees and key employees as well as certain other individuals are required to complete the annual conflict of interest and tax questionnaire (coi-tq). The coi-tq is designed to require disclosure of any business and family relationships and affiliations maintained by officers, trustees, or key employees and their family members and which may result in a real or perceived conflict of interest. The bilh office of integrity and compliance, in conjunction with the bilh tax department, administers the coi-tq process annually. Bilh integrity and compliance collects and reviews all disclosures. Disclosures for bilh executives and key employees are assigned appropriate follow-up action in accordance with the bilh policy. A summary of positive responses for each bilh affiliate is provided to the compliance officer for that entity for review final determination of any potential or actual conflict. Any activity that requires action under the conflict of interest policies is subject to ongoing review by beth israel lahey health specialty care f/k/a northeast medical practice as well as the bilh integrity and compliance office. Pursuant to the bilh conflict of interest policy, certain activities which could create conflicts of interest are prohibited while other types of relationships are permitted, subject to compliance with a management plan to require disclosure and recusal, including appropriate documentation in the minutes. In addition, as noted above, the annual coi-tq process outlined above is jointly issued by the bilh tax department, to ensure that the questionnaire is distributed to all current and former members of the beth israel lahey health specialty care f/k/a northeast medical practice board of trustees as well as former officers and key employees. The coi-tq process is designed to gather the information necessary for beth israel lahey health specialty care f/k/a northeast medical practice to completely and accurately complete form 990 schedule l, transactions with interested persons and form 990, part vi, question 2, family and business relationships between officers, directors/trustees and key employees.”

“As noted throughout this filing, beth israel lahey health specialty care f/k/a northeast medical practice is a member of the beth israel lahey health (bilh) network of affiliates with bilh serving as beth israel lahey health specialty care f/k/a northeast medical practice's sole member, or if not as direct sole member, indirectly as the member in its capacity as parent of the beth israel lahey health network. In this role bilh maintains the responsibility for setting compensation for executives and senior management of the entities which comprised the beth israel lahey health network. The bilh compensation committee is therefore responsible for assuring that the total compensation provided to these individuals is fair and reasonable using current and credible market practice information and is responsible for ensuring compliance with applicable legal and regulatory guidelines, the bilh compensation committee is composed of independent members of its board of trustees and except as otherwise noted below or in form 990 schedule j, the compensation reported in this form 990 for beth israel lahey health specialty care f/k/a northeast medical practice's officers, trustees and key employees was set by the bilh compensation committee. The bilh compensation committee process for setting compensation is below. The beth israel lahey health (bilh) compensation committee establishes the policies and the compensation structure, including benefits, for the beth israel lahey health network of affiliates including the bilh chief executive officer as well as other members of senior management at bilh and its affiliates. The compensation committee is responsible for assuring that the total compensation provided to these individuals is fair and reasonable using current and credible market practice information and is responsible for ensuring compliance with applicable legal and regulatory guidelines. The bilh compensation committee is composed of independent members of its board of trustees in setting compensation, the compensation committee relies upon published compensation surveys and studies produced by independent compensation consulting firms that regularly assess executive compensation and benefits of substantially similar organizations. The compensation committee meets to review the compensation structure of the individuals described above and at that time reviews the compensation survey details prepared by the independent compensation consulting firm. For some categories of positions, the compensation committee will review the compensation structure and targets as a group, rather than by individual. Compensation for the bilh ceo and other senior executives is reviewed on an individual basis. The compensation committee then votes to approve the compensation arrangements of all individuals described above except for the bilh ceo. The compensation package for the bilh ceo as voted by the compensation committee is submitted to the full board of trustees for approval. All deliberations for both the compensation committee and the board of trustees are contemporaneously documented in minutes. The compensation committee processes and procedures as described above are designed to meet the requirements of treasury regulation section 53.4958-6(c), rebuttable presumption that a transaction is not an excess benefit transaction.”

“As noted throughout this filing, beth israel lahey health specialty care f/k/a northeast medical practice is a member of the beth israel lahey health (bilh) network of affiliates with bilh serving as beth israel lahey health specialty care f/k/a northeast medical practice's sole member, or if not as direct sole member, indirectly as the member in its capacity as parent of the beth israel lahey health network. Beth israel lahey health specialty care f/k/a northeast medical practice's governing documents, conflict of interest policy and financial statements are available to the general public upon request at the following location: beth israel lahey health tax department schrafft's city center, 4th floor, 529 main street charlestown, ma 02129”

“Beth israel lahey health specialty care f/k/a northeast medical practice (bilhsc fka nmp) primary mission is to provide high quality medical care to the patients of northeast hospital corporation (beverly hospital, addison gilbert hospital bayridge hospital and lahey outpatient center, danvers). Nmp accomplishes its mission in conjunction with the beth israel lahey health (bilh) network of affiliates as described further in this form 990.”

“Beth israel lahey health specialty care f/k/a northeast medical practice (bilhsc fka nmp) primary mission is to provide high quality medical care to the patients of northeast hospital corporation (beverly hospital, addison gilbert hospital bayridge hospital and lahey outpatient center, danvers). Nmp accomplishes its mission in conjunction with the beth israel lahey health (bilh) network of affiliates as described further in this form 990. During the fiscal period covered by this filing, beth israel lahey health (bilh) served as the sole member of anna jaques hospital (ajh), beth israel deaconess medical center, inc. (bidmc), mount auburn hospital (mah), new england baptist hospital (nebh), beth israel deaconess hospital -- milton, inc. (milton), beth israel deaconess hospital -- needham, inc. (needham), beth israel deaconess hospital -- plymouth, inc. (plymouth), lahey health shared services (lhss), lahey clinic foundation (lcf), winchester hospital (winchester), northeast hospital corporation (nhc) which includes beverly, addison gilbert and bayridge hospitals, northeast behavioral corporation (nbhc), the beth israel lahey health performance network (bilhpn), exeter health resources inc. (ehri) and the beth israel lahey health pharmacy. The lahey clinic foundation in turn served as the sole member of lahey clinic inc, and lahey clinic hospital d/b/a lahey hospital and medical center (lhmc) and exeter health resources inc served as the sole member of exeter hospital. Each of the entities listed here may have also, in turn, served as member to other network affiliates. Bilh is an integrated health care system committed to expanding access to extraordinary patient care across eastern massachusetts and southern new hampshire and advancing the science and practice of medicine through groundbreaking research and education. The bilh system is comprised of academic and teaching hospitals, a premier orthopedics hospital, primary care and specialty care providers, ambulatory surgery centers, urgent care centers, community hospitals, homecare services, outpatient behavioral health centers and addiction treatment programs. Bilh's community of clinicians, caregivers and staff includes approximately 4,700 physicians and 39,000 employees.”

“As noted throughout this form 990, beth israel lahey health specialty care f/k/a northeast medical practice (bilhsc fka nmp), is a not-for-profit physician group and member of the beth israel lahey health network of affiliates. Bilhsc fka nmp is a network of community-based physicians affiliated with beth israel lahey health and providing care in conjunction with, and in the communities served by, northeast hospital corporation (nhc) (beverly hospital, addison gilbert hospital bayridge hospital and lahey outpatient center, danvers) these practices are committed to improving the health of the communities served by nhc and bilhsc fka nmp by providing high quality, personalized health care with compassion, dignity and respect for patient rights in a cost effective and safe environment and is dedicated to providing care to patients in the communities where they live and work, providing care to in the community to medicare, medicaid and all other patients regardless of their race, color, religion, sex, sexual orientation, national origin, ancestry, age, or disability. During the period covered by this filing, bilhsc fka nmp provided primary/family and specialty care to its patients. In addition, when advanced care is needed, bilhsc fka nmp provides leading edge treatment at its affiliate, nhc and leading-edge treatment from beth israel deaconess medical center (bidmc) or lahey hospital & medical center as well as and other bilh affiliates. Lahey hospital & medical center (lhmc) or beth israel deaconess medical center (bidmc), each a level i trauma center and provide tertiary care and care in a wide range of specialties. Primary care bilhsc fka nmp with 48 physicians that specialize in the delivery of primary care and providing care in the beverly, danvers, gloucester, ma, communities served by bilhsc fka nmp and nhc. Primary care physicians (pcps) are community-based medical doctors who generally provide the first contact for a patient with a non-emergent undiagnosed health concern, as well as continuing care for a variety of medical conditions. During the fiscal year covered by this filing, bilhsc fka nmp had 75,361 primary care / family care patient visits. Specialty care in addition, to primary care, bilhsc fka nmp has 3 specialty care providers who provide care in a wide range of specialty care areas including nephrology in beverly massachusetts. During the fiscal year covered by this filing, bilhsc fka nmp had a total of 4,252 specialty care visits across these disciplines. In addition to the accomplishments noted above for beth israel lahey health specialty care f/k/a northeast medical practice, and as noted throughout this form 990, beth israel lahey health specialty care f/k/a northeast medical practice is a member of the beth israel lahey health (bilh) network of affiliates. The bilh core values and principals are listed here as well as network-wide accomplishments during the fiscal period covered by this filing. The bilh network is delivering on the promise to bilh patients and communities to expand access and provide extraordinary care, while also advancing medicine through discovery and education. The bilh purpose statement articulates the impact that each bilh affiliate strives to make in the communities served. These shared values guide each entity's daily efforts and keep each affiliate aligned in the pursuit of the bilh purpose, showing how "we care" for patients, each other and the communities served. Purpose statement: bilh creates healthier communities one person at a time through seamless care and ground-breaking science, driven by excellence, innovation and equity. Bilh we care values: wellbeing. We provide a health-focused workplace and support a healthy work-life balance. Empathy. We do our best to understand others' feelings, needs and perspectives. Collaboration. We work together to achieve extraordinary results. Accountability. We hold ourselves and each other to behaviors necessary to achieve our collecti”

“Patient care delivery across the bilh network -- fiscal year ended september 30, 2024 hospital care: during the period covered by this filing, the bilh hospitals provided care to patients in a full spectrum of specialties and utilizing a wide range of modalities. Below are a sample of the hospital care provided to bilh patients. During the fiscal year covered by this filing, bilh hospitals had approximately 4.9 million outpatient encounters. Approximately 80,000 outpatient/ambulatory surgeries and over 100,000 endoscopies were performed, in addition, across bilh hospitals patients had more than 141,000 oncology visits and almost 111,000 oncology infusions, 268,000 ekgs, over 59,000 orthopedic procedures, more than 758,000 radiology exams, over 312,000 ct exams, more than 177,000 ultrasound procedures, over 142,000 mris, over 221,000 outpatient breast imaging exams, approximately 312,000 outpatient rehabilitation and physical therapy visits and more than 11.7 million outpatient lab tests were performed. The bilh hospitals also had approximately 432,000 emergency department visits, more than 35,000 observation cases and more than 137,000 inpatient discharges with approximately 729,000 inpatient days, including more than 44,000 inpatient psych days. During this period more than 31,000 inpatient surgeries were performed and approximately 14,000 newborns were delivered and there were approximately 52,000 pain clinic visits. Bilh hospitals also had more than 75,000 urgent care visits during this period. Non-hospital physician care: during the period covered by this filing, the bilh physicians provided care to patients outside of the hospitals and in physician office or other clinical settings. Below are a sample of the non-hospital physician services provided to bilh patients. During the fiscal year covered by this filing, more than 470 primary care and family practice providers had approximately 843,000 patient visits and providers across the full spectrum of specialties had more than 624,000 patient visits. In addition, joslin diabetes center had more than 27,000 patient visits related to diabetes care and there were more than 53,000 urgent care visits to non-hospital urgent care locations. Community benefits, uncompensated care, costs to provide care to medicaid and medicare patients fiscal year ended september 30, 2024 during the fiscal year covered by this filing bilh hospitals provided more than $52 million in net cost of charity care, including care for emergent services provided to non-paying patients and including payments to the health safety net trust. In addition to the charity care reported above, each of the bilh hospitals also provides care to patients who participate in other programs designed to support low-income families, including particularly the medicaid program, which is jointly funded by federal and state governments. The massachusetts health reform law provided an initiative for expansion of medicaid coverage to greater populations and for enrollment of uninsured patients in other insurance programs. Payments from medicaid and other programs that ensure low-income populations do not cover the cost of services provided. During the fiscal period covered by this filing, the cost of providing care to medicaid patients across bilh exceeded payments received for providing that care resulting in a combined shortfall exceeding $35.5 million related to treating medicaid patients. Medicare is the federally sponsored health insurance program for elderly or disabled patients. Payments from medicare do not cover the cost of services provided. All bilh hospitals provide care to patients who participate in the medicare program. During the fiscal period covered by this filing, the cost of providing care to medicare patients across bilh exceeded payments received for providing that care, resulting in a combined shortfall exceeding $161 million related to treating medicare patients. In addition to the costs noted above, durin”

“Laboratory services expansion and optimization bilh transitioned to centralized oversight of all laboratory draw sites in fy 2024 and created 11 new community-based lab draw stations, which increases patient access to lab services and improves both patient and provider satisfaction. The centralized oversight model better enables bilh to focus on quality, service, and phlebotomist recruitment. In addition, bilh continues to refine transportation routes for lab specimens, maintaining high standards for turnaround times and efficiency, which further improves the overall quality of laboratory services. Enhancement of care delivery across primary care practices bilh primary care ("bilhpc") continued to enhance care delivery and elevate the quality of care throughout its practices, as demonstrated by the following initiatives: partnered with a bilhpn pharmacist and local diabetes nurse educators to launch a diabetes hub and spoke model in the milton and needham primary care regions, where a diabetes-specialized advanced practice practitioner is embedded in the practice; collaborated with bilh pharmacy to plan the expansion of remote blood pressure monitoring for improved hypertension management; expanded the virtualist program, enhancing access to acute and overflow care; and introduced a self-scheduling tool for new patients seeking to establish care with a primary care provider. Education and awareness efforts to promote access to care in fy 2024, bilh worked to improve access for masshealth patients in eastern massachusetts through various communications initiatives. A key effort was launching a monthly newsletter, available in seven languages, to engage patients and share health information. New england baptist hospital ("nebh") hosted information sessions to educate underserved populations about its services. Nebh also performed outreach to community housing facilities, participated in boston mayor wu's hispanic heritage month luncheon, and partnered with neighborhood associations and main street boards.”

“The boston, ma office of kpmg issued an unqualified opinion on the consolidated audited financial statements of the beth israel lahey health, inc. And affiliates for fiscal period ended september 30, 2024. These statements were prepared in accordance with generally accepted accounting principles (gaap) and included the accounts of the beth israel lahey health, inc. (bilh), and the entities for which beth israel lahey health, inc. (bilh) served as sole member during the fiscal period covered by this filing, (anna jaques hospital (ajh), beth israel deaconess medical center, inc. (bidmc), mount auburn hospital (mah), new england baptist hospital (nebh), beth israel deaconess hospital -- milton, inc. (milton), beth israel deaconess hospital -- needham, inc. (needham), beth israel deaconess hospital -- plymouth, inc. (plymouth), lahey health shared services (lhss), lahey clinic foundation (lcf), winchester hospital (winchester), northeast hospital corporation (nhc) which includes beverly, addison gilbert and bayridge hospitals, northeast behavioral corporation (nbhc), the beth israel lahey health performance network (bilhpn), the joslin diabetes center, exeter health resources, inc. (ehri) and the beth israel lahey health pharmacy. The lahey clinic foundation in turn served as the sole member of lahey clinic inc, and lahey clinic hospital d/b/a lahey hospital and medical center (lhmc). Ehri in turn served as the sole member of exeter hospital and other affiliates of ehri. Each of these bilh affiliates may in turn serve as member of additional entities within the network of affiliates, and whose accounts are included in the bilh audited financial statements. In addition, the bilh financial statements also include the accounts of harvard medical faculty physicians at beth israel deaconess medical center, inc. (hmfp), the dedicated physician practice of beth israel deaconess medical center and an entity integrally related to helping bidmc and other affiliates in the bilh network accomplish their charitable purposes. The accounts of the entities for which hmfp serves as member are also included in the hmfp and bilh audited financial statements. The audit and compliance committee of bilh's board of trustees assumes responsibility for oversight of the consolidated audit for the network as a whole.”

“As noted throughout this filing, beth israel lahey health (bilh) served as a support organization and the direct or indirect sole member of beth israel lahey health specialty care f/k/a northeast medical practice inc.. As part of that relationship, bilh provided centralized support to its network of supported organizations, including among other things, operational support such as processing payroll and accounts payable. In this capacity bilh issued all forms 1099 to not only its own vendors and service providers, but also to those who provided services to beth israel lahey health specialty care f/k/a northeast medical practice inc. Forms 1099 were all issued in the bilh name and under the bilh ein. However, in accordance with instructions to this form 990, beth israel lahey health specialty care f/k/a northeast medical practice inc. Is reporting the number of forms 1099 related to services performed for and payments related to, its service providers as if they were processed directly by beth israel lahey health specialty care f/k/a northeast medical practice inc. Each other affiliate is similarly reporting the number of forms 1099 which are attributable to their own service providers.”

“Beth israel lahey health specialty care f/k/a northeast medical practice inc. Did not receive any contributions of intellectual property and as such, was not required to file form 8899.”

“Beth israel lahey health specialty care f/k/a northeast medical practice inc. Did not receive any contributions of cars, boats, airplanes or other vehicles and as such, was not required to file form 1098-c.”

“Physcian services: program service expenses 19,810,354. Management and general expenses 0. Fundraising expenses 0. Total expenses 19,810,354. Purchased services: program service expenses 512,411. Management and general expenses 0. Fundraising expenses 0. Total expenses 512,411. Clinical professional fees: program service expenses 70. Management and general expenses 0. Fundraising expenses 0. Total expenses 70.”

“Transfer of net assets 27,826,757. Goodwill -621,600.”

“As noted throughout this form 990, beth israel lahey health specialty care f/k/a northeast medical practice inc. Is a member of the beth israel lahey health network of affiliates. Beth israel lahey health (bilh) serves as the direct or indirect member of beth israel lahey health specialty care f/k/a northeast medical practice inc. And beth israel lahey health specialty care f/k/a northeast medical practice inc. Is included in the consolidated audited financial statements of beth israel lahey health. The audit and compliance committee of bilh's board of trustees assumes responsibility for oversight of the consolidated audit for the network as a whole.”