The Wright Center Medical Group PC

“In order to be eligible to apply for fqhc and fqhc look-alike status, the organization converted from a tax-exempt pennsylvania professional corporation with members and a board of directors to a pennsylvania nonprofit corporation with a board of directors but no members. In 2018, wcmg engaged a consultant to consider and pursue, if appropriate, a designation by the us health resources and services administration (hrsa) as a federally qualified health center (fqhc) or a fqhc look-alike. In order to be eligible to apply for either designation, wcmg was required to convert from a tax-exempt pennsylvania professional corporation to a nonprofit corporation and dramatically change the make-up of its governing body to meet the requirements of the public health service act section 330(k)(3)(h), 42 cfr 51c.304 and 42 cfr 56.304. Wcmg's board of directors consisting of licensed health professionals actively practicing in pennsylvania courageously and unanimously approved this conversion, which necessarily required that the licensed professionals vote themselves off the board in favor of a community-based patient-majority led board of directors in accordance with phsa requirements. All appropriate documentation was filed with the pennsylvania department of state, including articles of conversion, amended and restated articles of incorporation and amended and restated bylaws. As part of the conversion, wcmg eliminated members and became governed strictly by a board of directors that met the requirements of phsa section 330 requirements. The conversion was complete and effective october 1,2018. Wcmg was designated as a fqhc look-alike effective june 1,2019. In addition, a fictitious name application was submitted registering "the wright center for community health" as a fictitious name for wcmg.”

“In order to be eligible to apply for fqhc and fqhc look-alike status, the organization converted from a tax-exempt pennsylvania professional corporation with members and a board of directors to a pennsylvania nonprofit corporation with a board of directors but no members. In 2018, wcmg engaged a consultant to consider and pursue, if appropriate, a designation by the us health resources and services administration (hrsa) as a federally qualified health center (fqhc) or a fqhc look-alike. In order to be eligible to apply for either designation, wcmg was required to convert from a tax-exempt pennsylvania professional corporation to a nonprofit corporation and dramatically change the make-up of its governing body to meet the requirements of the public health service act section 330(k)(3)(h), 42 cfr 51c.304 and 42 cfr 56.304. Wcmg's board of directors consisting of licensed health professionals actively practicing in pennsylvania courageously and unanimously approved this conversion, which necessarily required that the licensed professionals vote themselves off the board in favor of a community-based patient-majority led board of directors in accordance with phsa requirements. All appropriate documentation was filed with the pennsylvania department of state, including articles of conversion, amended and restated articles of incorporation and amended and restated bylaws. As part of the conversion, wcmg eliminated members and became governed strictly by a board of directors that met the requirements of phsa section 330 requirements. The conversion was complete and effective october 1,2018. Wcmg was designated as a fqhc look-alike effective june 1,2019. In addition, a fictitious name application was submitted registering "the wright center for community health" as a fictitious name for wcmg.”

“Between july 1, 2018 and september 30, 2018, wcmg's bylaws provided that the members of the corporation had the power to elect individuals to the board of directors at the annual meeting. Effective october 1, 2018, in order to achieve eligibility to apply for fqhc status, wcmg converted from a tax-exempt pennsylvania professional corporation to a pennsylvania nonprofit corporation governed by a patient-majority led board of directors with no members.”

“Form 990 is prepared by the finance department and an outside cpa firm. A copy is provided to the organization's chief executive officer and executives for review, constructive input, and approval. Copies of the form 990 are then reviewed and approved by the audit committee of the board. The 990 is then provided to all members of the organization's governing body for review and approval. Upon completion of this review, the form 990 is signed by the organization's chief executive officer and filed with the irs.”

“A conflict of interest policy has been approved by the board. An annual conflict of interest disclosure statement is completed and updated by the directors, officers and key employees of the corporation, and as more frequently as necessary should a conflict or potential conflict arise during the year. Potential conflicts, if any are fully disclosed, vetted by the audit committee and reviewed by the board. Education on conflicts of interest is provided to the board annually during review and renewal of the conflict of interest policy. Compliance with the policy is monitored by the audit committee and supported by the governance officer.”

“The wcmg executive committee with support from the personnel committee performs an annual review of the chief executive officer's performance, employment and compensation package with full disclosure to the full wright center medical group board. Multi-source independent comparable employment compensation survey data is obtained. The deliberation and decision is contemporaneously substantiated and noted in the committee minutes. Compensation of key executive employees is determined by the organization's chief executive officer and human resource department. A formal, external, comprehensive, organizational-wide compensation analysis by a contracted vendor responsible to the personnel committee of the board is done on a periodic basis, generally every three years. Moreover, data from the american job center network website, medical group management association (mgma), and other regional and national sources may be consulted when necessary to provide additional comparable salary ranges for various positions within the organization, including all executives.”

“Wcmg's governing documents, conflict of interest policy, and financial statements, as well as form 990, are available for public inspection by appointment during business hours at the organization's offices. Copies will be provided upon request.”

“Joseph ferrario - 530-2 sherwood ave, dunmore, pa 18512. Carlon preate - 715 glenburn rd, clarks summit, pa 18411. Ken powell - 1 highlands blvd, suite 207, archbald, pa 18403. Sandra browder - 8 walsh plaza, olyphant, pa 18447. Luci kura - 438 front street, jessup , pa 18434. Allyson favuzza - 303 champion circle, throop, pa 18512. Dr. Min jung kang - 3900 city ave, apt. A304, philadephia, pa 19131. Dr. Qi shi - 103 lake scranton road, scranton, pa 18505. Dr. Julio ramos - 397 drinker turnpike, covington twp., pa 18424.”

“Through october 1, 2018, the wright center medical group, pc (wcmg) was a professional corporation, which requires in its bylaws that its board consist of licensed professionals. During 2017-2018 all directors of the board were individuals employed by wcgme/wcmg who were licensed providers. Therefore, the directors were compensated and were non-independent by definition. As noted in schedule o, form 990, part vi, section a, line 6, on october 1, 2018 the corporation was converted to a non-profit corporation and revisions were made to the articles of incorporation and by-laws requiring changes to board composition compliant with public health service act 330 to honor the organizational commitment to pursue federally qualified look alike and or full federally qualified health center designation by hrsa.”

“As described more fully in the response to 990, part iii, line 4c, wcmg expanded program services to increase access to medication-assisted treatment and add a pilot housing program to support the recovery of individuals with opioid use disorder with the assistance of two separate grants from the commonwealth of pennsylvania. In addition the healthy maternal opioid medical support (healthy moms) program was launched with the support of a lackawanna/susquehanna office of drug and alcohol programs grant.”

“In the fourth quarter of 2017 wcmg and its affiliated organization wcgme executed a lease agreement for a 36,500 sq ft flagship medical facility and administrative offices with wyoming avenue development, llc, a company owned by common board member joseph ferrario. The conflict of interest policy described in form 990, part vi, section b, line 12c was followed and a legal ethics opinion as to best practices for addressing a conflict of interest was obtained from legal counsel. Joseph ferrario subsequently resigned from both the wcmg and wcgme boards on july 12, 2019. An amended lease agreement that clarified wcgme as the primary lessee was signed in late july 2019. Renovations of the building pursuant to the lease agreement occurred between early 2018 and december of 2019. The lease was operationalized on november 26, 2019.”

“The wright center medical group (wcmg) is an affiliate of the wright center for graduate medical education ("wcgme", ein: 23-2007832). Wcgme is a common pay agent for w-2 reporting for both entities, with the exception of the separate payroll maintained by wcmg, beginning in october 2018, to compensate three key employees of wcmg, the chief executive officer, chief medical officer and chief operating officer. Wcgme reports all other employees on its form w-3; however, employee fte's are allocated to each entity based on time tracking of services provided. Per irs instructions, employees included on part v, line 2a, have been deemed to be the fte equivalent of employees allocated to this organization.”