Bon Secours Charity Health System Affiliated Group

“Members or stockholders: the members of BSCHS are as follows: WMC Rockland, Inc. - 60% BSHSI, together with SOC - 40% Pursuant to New York State Law, as an organization engaged in the profession of medicine, Bon Secours Charity Health System Medical Group, P.C. (MedPC) was the sole shareholder of the organization who is engaged in the practice of medicine and licensed to practice in the State of New York.”

“Power to elect or appoint members: The governing bodies of the members within the Group, with the exception of MedPC, are appointed by its members, WMC-Rockland, BSHSI and SOC and are subject to the approval of its members.”

“Decisions reserved to members or stockholders: Certain authorities of the members of the Group, with the exception of Bon Secours Charity Health System Medical Group, PC, are jointly reserved to WMC-Rockland, BSHSI and SOC, certain authorities are reserved to BSHSI and WMC-Rockland, and certain authorities are reserved solely to BSHSI.”

“Process used to review the Form 990: The Form 990 was prepared by our tax advisors together with our finance department with the assistance from various departments throughout the organization. The Form 990 was reviewed by internal leadership. Upon completion of the various reviews, the Form 990 was presented to the board of the organization for approval prior to filing with the IRS.”

“The organization monitors and enforces compliance with the Conflict of Interest policy by means of a survey developed and approved by the WMCHealth Chief Compliance Officer. The survey is sent to all trustees, officers, and key executives for completion. All survey responses are reviewed by the Chief Compliance Officer. Any potential conflicts identified in the responses are discussed with senior management and/or referred to the WMCHealth Conflicts of Interest Committee for discussion. Potential actions to be taken in response to a conflict can be one or more of the following: 1) disclosure of the conflict, 2) individual recusal from decisions for transactions where that individual may have a conflict, 3) request in writing the individual alleviate the conflict, or 4) removal of the individual from employment.”

“The organization has a comprehensive process for the oversight and management of remuneration for the CEO and other senior executives and disqualified parties. Compensation for such key employees is set by reviewing and relying on objective market data to ensure they receive compensation that is in full compliance with the IRS' rebuttable presumption of reasonableness. The organization maintains a compensation philosophy, reviews pay practices against SIMILAR healthcare organizations and approves all remunerative decisions for this group of individuals. Further, the organization ensures that all levels of pay within the organization are reasonable based on performance and validates that incentives payments, if any, are adequately supported. Such decisions are documented in Board and other relevant Committee minutes.”

“Governing documents, conflict of interest policy and financial statements are made available to the public upon request.”

“Other changes in net assets Transfers to Affiliates ($34,310,988)”