Blue Cross and Blue Shield Plans National Retiree Health Benefits Trust

“Certain members of the national employee benefits committee ("committee") serve together on the board of blue cross and blue shield association. All members of the committee are either employees of the blue cross and blue shield association or one of the member plans.”

“Form 990's content and source of information are reviewed by subject matter experts including, but not limited to, internal and external tax and accounting professionals and internal legal personnel, and the audited financial statements are presented to the committee that serves as the governing body by the independent auditors.”

“Blue cross blue shield association (bcbsa) maintains a comprehensive code of conduct and compliance program applicable to all employees and officers, including those who either serve on the committee (that governs and acts for the organization) or act on behalf of that committee. In addition, all employees, officers, and directors (including those who serve on the committee or act on its behalf) are required to complete an annual conflict of interest form. The bcbsa chief auditor and compliance officer is charged with investigating any allegations of non-compliance with the code of conduct, including any complaints reported through the anonymous hotline maintained through an independent organization. The results of the compliance program's effectiveness are reported to the audit committee of the bcbsa board of directors on an annual basis. Failure to adhere to the code of conduct may result in disciplinary action, up to and including termination of employment. Moreover, committee members receive fiduciary training from the bcbsa chief employee benefits counsel regarding their fiduciary duties, including the erisa fiduciary conflict of interest rules. Bcbsa's chief employee benefits counsel also provides the committee with an annual assessment of the organization's and committee's legal compliance, including compliance with erisa. As employees of various blue plans, each committee members not employed by bcbsa is subject to additional conflict of interest restriction under policies adopted by his or her employer plan.”

“The organization does not require compensation policies as it does not compensate any officers, management officials, or key employees.”

“The governing documents and form 990 are made available to participants in the employee benefit programs funded through veba upon request to the vice president, national employee benefits administration, blue cross and blue shield association, 225 n. Michigan avenue, chicago, il 60601.”