Covenant Foundation Inc.

“IRS Form 990 Part IV Lines 12a-12b and Part XII Lines 2a-2c: Effective May 1, 2016, Iowa entities transferred their ownership interest from Wheaton Franciscan Services, Inc. to Mercy Health Network, Inc. For the year ending June 30,2016 the system parent organization did not conduct its regular consolidated audit, therefore the Iowa region conducted their own audit, which included just the Iowa entities (and not Wheaton Franciscan Healthcare or Mercy entities). We have therefore answered NO, YES accordingly. IRS Form 990 Part VI Section A Lines 6-7b: Covenant Foundation, Inc. has one member which holds several reserved powers over Covenant Foundation, Inc. These reserved powers include, but are not limited to, the election of members of the governing body and election of officers, approval of certain financial expenditures in accordance with policy, and approval of budgets and strategic plans; these approvals are based on recommendations from the governing body. IRS Form 990 Part VI Section B Lines 11a and 11b: Ministries that were affiliates of Wheaton Franciscan Healthcare during the fiscal year ending June 30, 2016 used a multiple-level review process on all IRS Forms 990 to ensure accurate and timely filing for all organizations. Under the direction of the Tax Manager, the Accounting Department prepares Forms 990, 990-T, and associated state filings. When complete, the return is first reviewed by a Senior-Level (or higher) associate in the Finance Department, who focuses on the income statement and balance sheet items, and schedules where transactions of this type might be reported. If discrepancies are found, the item will be corrected prior to the next step in the review process. Once cleared through Finance, the return is provided to the Tax Department, where the Tax Manager concentrates primarily on consistency of reporting between all returns, accuracy of tax related information, and explanation and understanding of any outliers. Again, any problems or questions are investigated and corrected. Depending on the level of complexity of the year in question, as well as the individual issues specific to that filing, certain returns may be selected for outside review by a public accounting firm. This decision will vary from year to year based on many factors, and sometimes outside review is not utilized at all. Also, certain schedules, such as Schedule H or Schedule J may be reviewed by committees, such as the Community Benefit Team or the Compensation Committee in selected years. The board has asked for formal presentations on various 990 topics over the years. This decision will vary from year to year, again based on many factors. Once all levels of review have been completed, the Tax Manager (or the designated employee in the applicable region) will schedule an appointment with the signer of the 990. This is normally a Senior Vice President or CFO of the applicable region, who will perform an additional, normally high level review prior to signing the return. Once signed, the return is cleared to provide to members of the Board of Directors, who at a leater date but prior to efiling, are provided access to all 990's throughout their assigned region via an online portal. Additionally, as a courtesy, an individual who is listed on any 990 as a reportable individual will also receive access to the portal, where they can view the 990 if they so choose, prior to it being filed with the IRS. IRS Form 990 Part VI Section B Lines 12a - 12c: The organization has a Conflict of Interest policy which states that if at any time, an officer or director become aware that the board may discuss or act upon any transaction or arrangement which may have any bearing of any kind upon, or may relate in any manner to, a financial interest of the individual, the financial interest must be disclosed. All associates of the organization must disclose a potential conflict of interest any time it arises. The disclosures are reviewed and a determinat”

“Disclosure Statement Related to Forms 5471 Under the constructive ownership rules of Internal Revenue Code Sections 958(a) and (b), the taxpayer is required to file Forms 5471, Information Return of US persons with respect to certain foreign corporations, as a category 4 and/or 5 filer with respect to Wheaton Franciscan Insurance Company, FEIN #98-0691609. These filing requirements are or will be satisfied through the filing of Forms 5471 with respect to the foreign corporation on the taxpayer's behalf by the US taxpayers identified below who have the same filing requirement. Taxpayer name: Wheaton Franciscan Services, Inc. Address: 26 w171 Roosevelt Road, Wheaton IL 60187 FEIN number of US Tax return with which form 5471 was filed: 36-3262111 IRS Service Center where US Tax return was or will be filed: e-filed”