St Luke'S Hospital Foundation

“Daniel l. Wakeman is a compensated employee of a related organization, and as such, is considered a non-independent board member. Form 990, part vi, section a, line 2: keith burmeister and kerry burmeister have a family relationship.”

“St. Luke's holding company, inc. Is the sole member of st. Luke's hospital foundation.”

“St. Luke's holding company, inc. (slhc) is the parent corporation and sole member of st. Luke's hospital foundation. As the member, slhc has the right to (a) nominate and elect a minority of the members and remove the members of the board of trustees of st. Luke's hospital foundation, and (b) approve the nominees to fill any vacancies on the board of trustees, a majority of whom are nominated by st. Luke's hospital foundation.”

“While the board of trustees of each corporation is granted certain powers with respect to their operations, as the sole member, st. Luke's holding company, inc. (slhc) retains approval rights with respect to certain corporate actions such as (1) adoption of the corporation's strategic plans and financial plans, (2) expenditures for non-budgeted items in excess of certain dollar limits set from time to time by slhc, (3) expenditures for items which are included in the corporation's annual budgets but which exceed the budgeted amount by an amount in excess of certain dollar limits set from time to time by slhc, (4) incurrence, assumption or guarantee of any indebtedness, (5) sale, lease or other disposition of real property or assets with a value in excess of certain dollar limits set from time to time by slhc and (6) any merger, consolidation, reorganization, dissolution or liquidation.”

“Under the guidance of st. Luke's holding company, inc. (slhc) tax consultants, form 990's are prepared by the respective accounting department of each slhc subsidiary and reviewed by the respective subsidiary's finance leadership along with an independent accounting firm. After subsidiary's finance leadership approval, copies of the form 990 for slhc and their subsidiaries are provided to the respective company's board of trustees and reviewed and signed by the respective company's president prior to filing with the internal revenue service.”

“St luke's holding company, inc. And subsidiaries (slhc) have standards of ethical business practice that apply to all slhc board members and employees. Board members and employees are expected to certify their compliance with the applicable standards prior to election/appointment or prior to beginning employment.”

“St. Luke's hospital foundation's top management official and other officers are compensated by st. Luke's hospital (slh), a related tax exempt organization. Compensation determinations of st. Luke's hospital foundation's top management official and other officers are made by an executive committee of the board of slh. Each year independent consultants conduct an annual survey and recommend executive payroll base salary ranges based upon the market. The data is reviewed and approved by the slh executive committee of the board every november. Salary adjustments are determined at the november meeting of the executive committee of the board. The executive committee of the board approves other forms of compensation based upon the prior year performance at the february meeting each year.”

“St. Luke's holding company, inc. And subsidiaries provide any document open to public inspection upon request.”

“Annually (or immediately if new potential conflicts of interest arise), all board members are required to complete and return the board member certification statement within 30 days of dissemination. Board member certification statements are compiled and reviewed by the st. Luke's administration office. Summarized information is forwarded for review to the chief financial officer, legal counsel, st. Luke's president and the vice president of medical affairs. The purpose of this review is to both inform management of the disclosed conflicts and to bring any potential undisclosed conflicts to the attention of the st. Luke's administration office. The st. Luke's administration office then conducts an audit of all board member certification statements (along with any relationships noted through the above review) to identify any positional conflicts of interest and to test material transactions with board members/their affiliates for fair market value. Significant potential conflicts of interest are reviewed with general counsel for recommendations to the compliance committee for corrective action. Luke's administration office forwards the compliance officer a report of board members who have signed and returned the annual board member certification statement, significant potential conflicts disclosed and the resolution of such conflicts. The compliance officer issues a report to the compliance committee of these findings. The certification statement, or the filing of a false or incomplete certification statement, or failure to disclose immediately any new conflicts of interest that may arise, or failure to cooperate without condition, honestly and completely with any investigation or review of the board member's certification statement or his/her actions or circumstances shall be grounds for sanction by the board of trustees up to and including removal from the board/committee/council.”

“All new employees, excluding employed physicians, are provided a paper copy of the employee standards of ethical business and the employee certification statement which the new employee is required to complete prior to beginning employment. Annually (or immediately if new potential conflicts of interest arise), all salaried employees and specifically identified hourly employees, excluding employed physicians, are required to complete and submit an electronic employee certification statement by an established deadline that is communicated to the employee. The human resources department ensures that all statements, which are stored electronically, are completed and provides notification to the compliance officer of the number of annual employee certification statements sent and completed and copies of any statements containing disclosures that warrant further review. The human resource adminisrative director reports identified conflicts to the compliance committee. If the conflict is considered a significant exposure risk for slhc, a recommendation will be prepared by the compliance committee for final approval by the st. Lukes president. Failure to complete the certification statement, or the completion of a false or incomplete certification statement, or failure to disclose immediately any new conflicts of interest that may arise, or failure to cooperate without condition, honestly and completely with any investigation or review of the employees certification statement or his/her actions or circumstances shall be grounds for sanction up to and including termination of employment.”

“All new employed physicians are provided either an electronic or paper copy of the employed physician standard of conduct and the physician certification statement which the new physician is required to complete prior to beginning employment. Annually (or immediately if new potential conflicts of interest arise), all employed physicians are required to complete and submit an electronic physician certification statement by the established and communicated deadline. The human resource administrative director ensures that all certification statements, which are stored electronically, are reviewed. Identified conflicts are reported to the compliance committee. If the conflict is considered a significant exposure risk for slhc, a recommendation will be prepared by the compliance committee for final approval by the administrator with primary responsibility for the physicians employment agreement and/or the board of trustees. The human resources department forwards the compliance officer a report of the number of annual physician certification statements sent and completed and copies of any statements containing disclosures that warrant further review. The compliance officer issues an annual report to the compliance committee of these findings. Any items that meet criteria for public disclosure will be communicated to the appropriate physician by the assigned administrator. The administator will provide the physician-industry relationship disclosures to the applicable slhc marketing communications representative. The public disclosure will be posted on the st. Lukes hospital website (stlukeshospital.com) by the slhc marketing communications representative. Failure to file the certification statement, or the filing of a false or incomplete certification statement, or failure to disclose immediately any new conflicts of interest that may arise, or failure to cooperate without condition, honestly and completely with any investigation or review of the physicians certification statement or his/her actions or circumstances shall be grounds for sanction by the vice president of medical affairs or board of trustees up to and including termination of the physicians association/contract with slhc.”