Uvmc

“This 990 filing and attached schedules (the return) are prepared by a staff member in the premier tax department, of which uvmc is an affiliate. The return is reviewed by the manager and director of tax compliance of premier. After all changes from the above persons are made, the return is reviewed by the vice-president/controller of premier. A final version of the return is then provided to the board of trustees for review. At a board of trustees meeting, the vice president/controller of premier (or designee) shares detailed information on compensation and other key areas, as well as addresses any questions from the board of trustees, pending their review. The 990 filing is also shared with the audit committee of premier.”

“Premier, with which uvmc is an affiliate, requires all board members, board committee members, medical directors, supply chain division members, authorized signers, directors, executives, medical executive committee members, medical department and section chairs, physician partnership committee members, physician guidance group members, and all employed physicians to annually review the premier comprehensive conflict of interest statement, an explanatory memorandum, the antitrust compliance policy, and complete an individual questionnaire disclosing any potential conflicts as defined in the conflict of interest policy. This is accomplished either by way of an electronic communication sent out directly by the corporate compliance department or by way of a memo sent out from the chairman of the board and chief executive officer of premier. It also includes an explanatory memorandum of specific activities that might give cause to a conflict and an individual questionnaire to disclose all such activities. This questionnaire must be completed and signed by the individual. This correspondence includes a copy of the antitrust compliance policy that must be signed by the individual. All of these documents are sent to the corporate compliance department. The corporate compliance department ensures all forms are returned and retains the documents for five years. In addition, at each meeting of the board or any board committee, following approval of the previous meeting's minutes, the board or committee chair shall request any board member who perceives a potential conflict of interest on any of the meeting's agenda items to disclose the potential conflict. Additionally, at any board or board committee meeting where the subject of conflict of interest is discussed, the minutes shall contain the name of the party discussing a potential conflict of interest, the nature of the potential conflict of interest and whether a conflict of interest was found to exist. If a conflict of interest is determined by the board to exist, the member will be excused from participating in any discussion or voting on the particular agenda item. The chief compliance and enterprise risk officer reports the results of the premier conflict of interest questionnaires no less than annually to the board of trustees by way of the compliance and audit committee. This review is documented in the minutes of the meeting. Periodically, the internal audit department will review a sample of completed conflict of interest questionnaires and report the results to the compliance and audit committee. The annual conflict of interest questionnaires are individually summarized in a document and sent electronically to the finance department for any necessary disclosures required on the 990 filing.”

“The governing documents and financial statements are made available to the public when required by law or for accreditation purposes. The conflict of interest policy is available upon request.”

“Equity transfer -5,810,000. Captial donations -745,203.”