The New Clinical Program

“Part i, line 4 & part vi, line 1b: number of independent voting members of the governing body - the organization sought to confirm the independence of each voting member of its governing body by requesting that each such voting member respond to a questionnaire containing the pertinent instructions and definitions and designed to elicit the information necessary to determine independence. Based on responses to the questionnaires received by the organization and annual conflicts of interest disclosures, the organization was able to confirm that all voting members are independent.”

“The organization's current officers and/or trustees serve as officers and/or directors of taxable affiliates within the organization's corporate system or joint ventures in which the organization's corporate system has an ownership interest. The individual officers do not have personal financial interests in the taxable affiliate and serve only as a function of their roles with the organization or within the organization's corporate system.”

“This form 990 and attached schedules were prepared by employees of the system's tax department. Upon completion, the return is reviewed by kpmg llp and subsequently reviewed by the system's director of finance. After all necessary revisions are made, the return is reviewed by the treasurer of the organization and sent back to kpmg llp for final review. In addition, the final return is provided to the board prior to filing.”

“As an affiliate of yale new haven health system, the "system", the organization is covered by the system's conflicts of interest policy and document retention and destruction policy which, while not approved by the organization's governing body, were approved by the system compliance committee, a corporate committee overseen by the system audit committee, a standing committee of the system board. As such, all directors, officers, and key employees, if any, are required to disclose annually interests that could give rise to conflicts. Form 990, part vi, section b, line 13 explanation: while the system has a non-retaliation and non-retribution for reporting policy that applies to system entities, the organization has no employees.”

“The organization makes its governing documents, including its application for recognition of tax-exempt status (form 1023), and annual returns (form 990) available upon request. The annual returns, financial statements and form 1023 are maintained by the system tax department. The organization's governing documents are maintained by the system's legal and risk services department.”