Gifford Health Care Inc

“The Form 990 is prepared by an independent accounting firm based on the audited financial statements and information provided by the accounting department of the organization. The completed Form 990 is presented and reviewed by the Finance Committee of the Board of Trustees and an electronic copy of the complete Form 990 is made available to all Board Members prior to filing.”

“Gifford Health Care, Inc. requires board members to complete an annual conflict of interest survey. Any duality of interest or possible conflict of interest on the part of any director shall be disclosed to the other board members. Any director having duality of interest or possible conflict of interest on any matter shall not vote or use his personal influence on the matter, and shall not be present for discussion of the matter. The minutes of the meeting shall reflect that a disclosure was made and that the director abstained from voting and discussion.”

“The Organization's CEO & other officers are compensated by Gifford Medical Center, a related organization. Compensation for the Chief Executive Officer is evaluated annually by a board compensation committee that relies on data and input from a variety of independent sources. The compensation information is then reviewed by the Executive Committee of the Board of Trustees and resultant recommendations are presented to the Board of Trustees for final approval. To evaluate the compensation of the Organization's other officers and key employees, the compensation review is administered by human resources and the CEO. The human resources department has some internal and external sources that are utilized to compare compensation amounts.”

“The Organization makes its conflict of interest policy available upon request. The financial statements are available on the Organization's website, and upon request.”

“Gifford Medical Center, a related organization of Gifford Health Care, files all W-2s and 1099s for the Organization. Salaries, pension, payroll taxes, and employee benefits of those individuals are then allocated for the amounts that represent work performed for Gifford Health Care. In addition, the CEO and CFO of Gifford Medical Center, Gifford Health Care, and Gifford Retirement Community compensation has been shown in Part VII as paid by Gifford Medical Center only, although their time spent is attributable to all three entities.”

“Section 1.263(a)-3(n) Election: Gifford Health Care, Inc. 44 South Main Street Randolph, VT 05060 EIN 46-0938716 Gifford Health Care, Inc. is electing to capitalize repair and maintenance costs under Regulation Section 1.263(a)-3(n).”

“Transfer from Affiliate 3,032,441.”