Lourdes Ancillary Services Inc

“The sole member of lourdes ancillary services is our lady of lourdes health care services. See line 7 for additional information.”

“Our lady of lourdes health care services is the sole member of lourdes ancillary services. Our lady of lourdes health care services has the right to appoint all persons to the board of trustees of lourdes ancillary services.”

“As sole member, our lady of lourdes health care services must approve certain decisions of the governing body, including the strategic plan and annual operating budget. Our lady of lourdes health care services must also approve significant changes such as a merger, dissolution, sale of assets in excess of certain limits and modifications to governing documents.”

“Prior to filing, the form 990 for lourdes ancillary services is reviewed by senior management. In addition, certain key sections of the form are reviewed by the our lady of lourdes health care services audit and ethics committee. Each member of the board receives a copy of the return in its final form before it is filed with the internal revenue service.”

“Lourdes ancillary services has adopted trinity health's governance policy no. 1, which sets forth the organization's conflict of interest policy and processes. It applies to all "interested persons" of lourdes ancillary services, which includes trustees, principal officers, key employees, and members of committees with board-delegated powers. Interested persons are expected to discharge their duties in a manner the person reasonably believes to be in the best interests of lourdes ancillary services and to avoid situations involving a conflict of interest. On an annual basis, interested persons are required to complete a conflict of interest disclosure statement and to affirm their receipt of the conflict of interest policy, compliance with its requirements, and agree to notify the organization of changes impacting their annual disclosure in accordance with the policy. The annual disclosures are provided to internal legal counsel and the integrity and compliance officer, from which legal counsel prepares a report for the board chair and ceo. A summary of potential conflicts is reviewed with the board of trustees of lourdes ancillary services (or a delegated committee of the board) on a yearly basis. Interested persons are required to make full disclosure to lourdes ancillary services of any financial or business interests that might result in or have the appearance of a conflict of interest. The board of trustees of lourdes ancillary services (or a delegated committee of the board) is responsible for the review of transactions to determine whether an actual conflict of interest exists. In the event of an actual conflict, the board (or a delegated committee of the board) will either avoid the conflict or appropriately scrutinize the transaction to ensure it is in the best interests of lourdes ancillary services. Interested persons are required to recuse themselves from discussion and voting on matters involving a conflict of interest. The policy further addresses the proper documentation of the proceedings and potential disciplinary and corrective action for violations of the policy. The policy is available to the public upon request.”

“Question 15a is answered "no" because the compensation for lourdes ancillary services' ceo and cfo is established by trinity health, a related organization. In establishing ceo and cfo compensation, trinity health follows a process and policy that is intended to mirror the irc section 4958 guidelines for obtaining a "rebuttable presumption of reasonableness" with regard to compensation and benefits. As part of that process, the compensation and benefits of the ceo and cfo of lourdes ancillary services are reviewed at least annually by the trinity health board or the trinity health human resources and compensation committee (hrcc) of the board, authorized to act on behalf of the board with respect to certain compensation matters. As part of its review process, the hrcc retains an independent firm experienced in compensation and benefit matters for not-for-profit health care organizations to advise it in the determinations it makes on the reasonableness of proposed compensation and benefits arrangements. Question 15b is answered "no" because the compensation for other officers and key employees is established and paid by our lady of lourdes health care services, a related organization. In establishing officer and key employee compensation, our lady of lourdes health care services follows a process which includes the following: a compensation committee oversees the total rewards practices for the executives of our lady of lourdes health care services and affiliates. The compensation committee utilizes the services of an independent executive compensation and total rewards consultant which provides the committee with market data for comparison. In addition, our lady of lourdes health care services has an executive compensation and performance appraisal policy which guides the compensation committee and is reviewed and approved by the compensation committee on a regular basis.”

“Lourdes ancillary services is a subsidiary organization in the trinity health system. Trinity health makes certain of its key documents available to the public on its website, www.trinity-health.org, in the "about us" section. In this section, the consolidated audited financial statements are publicly available. Lourdes ancillary services' governing documents and conflict of interest policy are available upon request.”

“Lourdes ancillary services' financial statements were included in the fy17 consolidated financial statements of trinity health, which were audited by an independent public accounting firm.”