Scpmg Veba Trust for Collectively Bargained Retirees

“The daily operational governance has been delegated to a bank trustee (state street bank and trust co.). Performance and policy oversight for the trust is generally managed by two executives of the southern california permanente medical group (the medical director of business management and the chief financial officer), however, significant decisions pertaining to the veba trust must be made through a vote by the scpmg board of directors [comprised of 46 partners (45 voting and 1 nonvoting)].”

“NOT APPLICABLE”

“NOT APPLICABLE”

“The irs form 990 is prepared after an independent audit of the veba trust financial statements is performed. This audited information is used to complete the irs form 990. Once completed, an independent tax review is performed by the external tax accountants for the southern california permanente medical group. A review of the completed irs form 990 is the responsibility of the chief financial officer, and then final review and sign off is performed by the partnership representative of the southern california permanente medical group on behalf of the scpmg board of directors. The partnership representative will report any tax reporting concerns to the board of directors, if applicable. The irs form 990 is available to board members upon request.”

“The southern california permanente medical group has written policies pertaining to conflict of interest, whistleblowers, and document retention and destruction. Scpmg staff follow existing policies related to all work performed on behalf of scpmg and its related organizations, including the veba trust. Staff and managers of scpmg participate in mandatory annual compliance training and provide an attestation that they will comply with the organizational policies and procedures to report any conflicts of interest, etc. That come to their attention. Separate annual audits are performed by external auditors for scpmg and the veba trust in accordance with u.s. Generally accepted auditing standards and include independent reviews of financial statements.”

“The governing documents, conflict of interest policy, and financial statements for the veba trust may be released subject to a written request and upon approval of the chief financial officer.”

“State street, as the institutional trustee for the veba, issues 1099s for fees paid out of the veba trust (the veba trust is a trust designed solely for the investment of funds to satisfy the obligation to provide post retirement benefits to employees of scpmg pursuant to collectively bargained agreements).”

“The southern california permanente medical group is a related organization to the veba trust (the veba trust is designed solely for the investment of funds to satisfy the obligation to provide post retirement benefits to employees of scpmg pursuant to collective bargaining agreements). Scpmg has an audit committee that will address any concern related to the veba trust. The selection of the independent accountant and review of the audited financial statements for the veba trust is delegated to the partnership representative and chief financial officer. If any audit issues are not appropriately addressed, the independent accountant will disclose issues directly to the audit committee.”