Covenant Health Inc

“The directors of the Organization are elected by the members of Covenant Health, a public juridic person of pontifical right under the laws of the Roman Catholic Church (the "CHS Public Juridic Person").”

“Any change in the written statements of philosophy or mission of the organization must be approved by the Covenant Health Public Juridic Person before such change becomes effective.”

“The Form 990 is provided to the governing body for their review and approval prior to filing.”

“This process is the responsibility of the Compliance Officer. A conflict of interest disclosure form is submitted to all leadership, board members, board committee members, employed physicians, medical directors and certain employees in key positions annually to be completed. Reminders are sent to all persons of interest to ensure that all conflict of interest disclosure forms are completed and collected.”

“Every two-to-three years the Compensation Committee of the Covenant Health Board of Directors engages an external consultant to provide competitive market data from various survey sources, which is then used to develop recommendations for changes to the compensation program. Since 2003, the Compensation Committee has engaged a human resources consultant to conduct this analysis. Objectives of the analysis are to assess the compositeness of the total cash compensation levels of the senior leadership team, develop market based competitive salary ranges for all executive positions, and ensure that the annual incentive opportunities, if there are any, are competitive and reasonable. Form 990, Part VI, Section B, line 16b: Although written policies were not in place as of the end of the year covered by this tax return requiring the Organization to evaluate its participation in joint venture arrangements under applicable federal law to ensure that the Organization's exempt status is protected, the Organization performed due diligence with respect to its joint venture arrangements to safeguard the Organization's exempt status.”

“The Organization's Form 990, governing documents, conflict of interest policy, and financial statements are made available to the public upon request. The Organization's Form 990 is also made available at the following web address: https://covenanthealth.net/financials/”

“Admin and office support: Program service expenses 10,379,218. Management and general expenses 3,176,398. Fundraising expenses 0. Total expenses 13,555,616. Management and profesional consulting: Program service expenses 5,548,858. Management and general expenses 1,709,640. Fundraising expenses 0. Total expenses 7,258,498.”

“Transfers to affiliates -367,068. Receipt of beneficial interest in trust 6,820,030.”

“The audit process has not changed from the previous year.”

“This statement is pursuant to regulation section 1.351-3(a) by Covenant Health, Inc. (EIN 22-2484505), a significant transferor. On various dates during 2021, Covenant Health, Inc. (EIN 22-2484505) transferred the following property to Covenant Health Insurance LTD (EIN 04-3360127), a Cayman Islands-based foreign corporation: Cash-fair market value and adjusted tax basis equal to $11,973,266. No private letter ruling was received in connection with the Section 351 exchange. Additionally, Covenant Health has prepared a filed a 2022 Form 926 to report the transaction in greater detail.”