Ohio State University Physicians Inc.

“The process of reviewing the Form 990 entails a detailed review by the organization's accounting department and Chief Financial Officer. The governing body discusses the document at the Finance committee of the Board as it is ultimately filed with the IRS.”

“The Board of Directors, officers and staff of Ohio State University Physicians, Inc. ("OSUP") deal with a variety of issues involving OSUP's clinical services and related business activities. OSUP is well served by the fact that many of its employees who are involved in policy development and implementation, or otherwise may have a role in business or clinical decision-making for OSUP, have diverse interests and are involved in a number of professional and business activities outside the organization. This interest and involvement enhance the expertise, which these individuals bring to the various roles they fill in representing OSUP. On occasion, situations may exist in which an individual serving OSUP in an elected or appointed position or as an employee, has some outside interest in an entity doing business with OSUP or competing with OSUP which would constitute a conflict of interest or which could be perceived as constituting a conflict of interest. Generally, a conflict of interest could be said to exist when individuals have material interests outside OSUP which could influence them or could be perceived as influencing them to act contrary to the interests of OSUP and for their own personal benefit. The purpose of the Conflict of Interest Policy is to protect both the individual employee and OSUP, as a corporation, when OSUP is contemplating entering into a business transaction or other arrangement that might benefit the private interest of a member of the Board of Directors, an officer, or a member of the staff of OSUP. This Policy applies to the members of the Board of Directors, trustees, employed physicians, independent contractors and staff of OSUP (each, an "Associate"). It is each Associate's obligation to disclose any actual or perceived conflict of interest on a written Disclosure Statement attached to this Policy. If Associates are unsure as to whether their activities are a conflict of interest, they are advised to err on the side of caution and disclose the potential for such. If the individual is unwilling to disclose the details giving rise to the conflict of interest, he or she should disclose the fact of the conflict and withdraw from the situation concerned. Associates review the OSUP Conflict of Interest Policy and complete the attached "Conflict of Interest Disclosure Statement" for OSUP. This process is completed, initially upon employment and annually, and also when a potential conflict of interest situation arises. Notification of a potential -actual or perceived- conflict of interest involving an OSUP Associate or another Associate known to the OSUP Associate should be reported to the individual's direct supervisor. All Disclosure Statements should include the company/individuals involved, the nature and extent of work/relationship and an explanation of the potential conflict. Occasionally, information being disclosed could be sensitive in nature and should be handled with tact and a reasonable effort made to keep it confidential. Third parties may raise concern of possible conflicts of interest, if there are reasonable and substantial grounds for such a conflict to exist. The serious nature of third party disclosures must be emphasized to avoid frivolous or mischievous allegations. The notification should be taken to the person with responsibility for the issue or area (usually the direct supervisor). Associates who refuse to take the necessary steps to resolve the conflict in accordance with this policy may be subject to disciplinary action up to and including termination of employment. Depending on the severity of conflict, legal action may be necessary. The response to a disclosure of a conflict of interest should be appropriate to the circumstances. Not all relationships described in a Disclosure Statement constitute an actual conflict of interest. Additionally, the existence of a conflict or a potential conflict does not necessarily imply that the activity or relationship should cease. the d”

“all salaried positions within osup are reviewed annually with benchmark data from the association of academic medical center's data to insure reasonableness.”

“The organization makes its documents available through its legal counsel”

“Rounding Adjustment 477.”