Chapters Health System Inc.

“the compensation of all other officers and key employees is determined by the president/ceo. the president/ceo uses COMPARABILITY DATA AND AN INDEPENDENT COMPENSATION CONSULTANT TO DETERMINE THE COMPENSATION. THE DECISIONS ARE DOCUMENTED IN EACH EMPLOYEE'S file. THIS PROCESS TOOK PLACE DURING 2017.”

“The executive committee, made up of the president and ceo, cfo, chief medical officer, the vice chairperson of the board and the secretary, shall carry out the work of the board of directors between meetings and make recommendations to the board of directors for its action. The executive committee shall have all the authority of the board of directors except as may be limited by florida law and subject to the approval of the sole member.”

“Chapters Health System, Inc. retains an independent tax advisor to assist management in the preparation and review of its IRS Form 990. Prior to filing the return, management and the independent tax advisor review the return and all required schedules with the Compensation Committee of the Board of Directors. The Compensation Committee is composed of independent directors of the Company. Upon completion of its review, the Compensation Committee recommends to the Executive Committee of the Board of Directors that management be authorized to sign and file the return. Under the Company's bylaws the Executive Committee has the authority to take this action on behalf of the Board of Directors. A COMPLETE copy of the Form 990 is provided to the full board prior to filing with the IRS and the Executive Committee reports its activities to the Board of Directors on a quarterly basis.”

“Annually, each officer, director and key employee signs an acknowledgement and disclosure form attesting that they have read the Conflict of Interest Policy and agreeing to comply fully with its terms and conditions during their services with Chapters Health System, Inc. They further agree that if, at any time subsequent to the submission of the disclosure form, they become aware of any actual or potential conflict of interest or the information previously submitted becomes inaccurate or incomplete, they will promptly notify the CHS Board of Directors or the President and CEO of Chapters Health System, Inc. DETERMINATION OF AND REMEDIES FOR CONFLICTS OF INTEREST 1. Disclosure. In connection with any actual or possible conflict of interest, an interested person must disclose the existence of his or her financial interest and must be given the opportunity to disclose all material facts to the Directors (and members of committees) considering the proposed transaction or arrangement. The disclosure shall be made as soon as practicable following the realization by the interested person that an actual or possible conflict of interest exists. Ordinarily, disclosures by interested persons should be to the Chairperson of the Board. When an actual or possible conflict of interest becomes apparent in the course of a Board meeting (or committee meeting), the interested person shall immediately disclose his or her financial interest and related material facts to the presiding Director or officer at such meeting. 2. Determining Whether a Conflict of Interest Exists. After disclosure of the financial interest and all material facts, and after any discussion with the interested person, the interested person shall leave the Board (or committee) meeting while the determination of a conflict of interest is discussed and voted upon. The remaining Board (or committee) members shall decide if a conflict of interest exists. 3.Procedures for Addressing the Conflict of Interest. (a) An interested person who has a conflict of interest may make a presentation at the Board (or committee) meeting, but after such presentation, he or she shall leave the meeting during the discussion of, and the vote on, the transaction or arrangement that result in the conflict of interest. The interested person who has a conflict of interest will not be counted as present for determining a majority with respect to the vote on the transaction or arrangement that results in the conflict of interest. (b) The Chairperson of the Board (or committee) shall, if appropriate, appoint a disinterested person or committee to investigate alternatives to the proposed transaction or arrangement. (c) After exercising due diligence, the Board (or Committee) shall determine whether Chapters Health System can obtain a more advantageous transaction or arrangement with reasonable efforts from a person or business entity that would not give rise to a conflict of interest. (d)If a more advantageous transaction or arrangement is not reasonably attainable under circumstances that would not give rise to a conflict of interest, the Board (or committee) shall determine by a majority vote of the disinterested Directors (or committee members) whether the transaction or arrangement is in CHS's best interest and for its own benefit and whether the transaction is fair and reasonable to CHS and shall make its decision as to whether to enter into the transaction or arrangement in conformity with such determination. Violations of the Conflicts of Interest Policy (a) If the Board (or committee) has reasonable cause to believe that an interested person has failed to disclose actual or possible conflicts of interest, it shall inform the interested person of the basis for such belief and afford the interested person an opportunity to explain the alleged failure to disclose. (b) If, after hearing the response of the interested person and making such further investigation as may be warranted under the circumstance”

“The organization engaged an independent compensation consultant to assist in establishing a Compensation Charter that details the organization's procedures for setting compensation of the President/CEO and all other officers and key employees of the organization. The Compensation Charter established the Compensation Committee, the independent body responsible for establishing the compensation of the President/CEO. The Compensation Committee relies on a recent compensation study performed by an independent compensation consultant, which is done on an annual basis, that provides compensation data for similarly qualified persons in comparable organizations to support its decision-making process and reports its activities to the Board of Directors at the next regularly scheduled meeting. The Compensation Committee adequately documents its compensation determinations in the meeting minutes on a timely basis. THIS PROCESS TOOK PLACE DURING 2017.”

“The organization's articles of incorporation are filed with and viewable by the public at the official website of the Florida Department of State, Division of Corporations. The organization's Bylaws and conflict of interest policy are not made available to the public. Unaudited financial statements of the organization are filed and viewable by the public at the official website of the State of Florida, Division of Consumer Services. The organization is required to file its audited consolidated financial statements and other financial information with its annual Medicare cost report. This information is subject to a public records request. In addition, the organization reports its financial performance each year in its Annual Report, copies of which are available to the public upon request.”

“MANAGEMENT FEE INCOME - Total Revenue: 965792, Related or Exempt Function Revenue: 965792, Unrelated Business Revenue: , Revenue Excluded from Tax Under Sections 512, 513, or 514: ;”

“(continued from part iii) Chapters Health System provides significant management duties, including without limitation, financial and accounting services, human resources, legal and marketing services, information technology services, to its subsidiaries and wholly owned LLC's via a written Management Agreement. The amount of these services is reflected in the statement of revenue as Shared Services Revenue" and Management Fee Income. B. LifePath Hospice, Inc. LifePath Hospice is a Medicare-certified agency that provides end-of-life care in Hillsborough County, Florida. In 2017, LifePath Hospice served 7,358 patients in its community. Lifepath Hospice maintains 98.3% market share in Hillsborough County in 2017 as they are one of two hospice providers. The company has 880 trained volunteers whose donated time is valued at $2,000,000. LifePath Hospice provided $1,700,000 in charity care in 2017. C. Good Shepherd Hospice, Inc. Good Shepherd Hospice is a Medicare-certified agency that provides end-of-life care in Polk, Highlands and Hardee counties in Florida. In 2017, Good Shepherd Hospice served 3,795 patients in its communities. Good Shepherd Hospice maintains 53% market share in Polk Highlands and Hardee counties in 2017. The company has 383 trained volunteers whose donated time is valued at $603,360. Good Shepherd Hospice provided $674,000 in charity care in 2017. D. Hernando-Pasco Hospice, Inc. Hernando-Pasco Hospice is a Medicare-certified agency that provides end-of-life care in Hernando, Pasco and Citrus counties in Florida. Hernando-Pasco Hospice also provides home health services in Pasco and Pinellas counties. Hernando-Pasco Hospice affiliated with Chapters Health System, Inc. on February 1, 2015. In 2017, Hernando-Pasco Hospice served 3,509 patients in its communities. Hernando-Pasco Hospice maintains 44% market share in Hernando, Pasco and Citrus counties in 2017. The company has 450 trained volunteers whose donated time is valued at $1,300,000. Hernando-Pasco Hospice provided $237,000 in charity care in 2017. E. Chapters Health Palliative Care, LLC. Chapters Health Palliative Care provides pain and palliative care consults in hospitals and other facilities in Hillsborough and Polk counties. In 2017, Chapters Health Palliative Care provided 7,883 patient visits, which included 2,638 new palliative care consults at three hospitals and three nursing home/rehabilitation centers. F. Chapters Health Pharmacy, LLC Chapters Health Pharmacy is a not-for-profit subsidiary that provides medications for the patients of LifePath Hospice and Good Shepherd Hospice. Chapters Health Pharmacy improved staff efficiency with electronic medication orders, filling 158,824 prescriptions in 2017. Chapters Health Pharmacy provides free delivery of medications for hospice patients, at a cost of more than $1,032,205. G. Chapters Health Staffing, LLC. Chapters Health System established a not-for-profit subsidiary, Chapters Health Staffing, LLC, in 2009. Chapters Health Staffing operates a licensed health care services pool. This company provides temporary staffing of healthcare personnel to other Chapters Health System subsidiaries and enables Chapters Health System to centralize the management of clinical staff whose duties cross between multiple subsidiaries. Chapters Health Staffing staff includes physicians, nurses, respiratory therapists and managers for the oncology program, medical staff and infusion services. H. Chapters Health System Development Department The Chapters Health System Development Department is the fundraising entity for LifePath Hospice and Good Shepherd Hospice. Through community events and fundraising activities, the Development Department raises funds to support the unfunded programs of LifePath Hospice and Good Shepherd Hospice, which include charity care, community grief support and medical student education. In 2017, a total of 24,470 donors contributed $4,537,197 to the Chapters Heath System Development Department”

“(continued from part iii) chs also works to promote an understanding of the needs of persons with serious or life-limiting illnesses as well as the needs of its families and caregivers. Chs provides significant management duties, including without limitation, financial and accounting services, human resources, legal services, marketing services and information technology services, to its subsidiaries and wholly owned llc's via a written management agreement.”

“Gain on Investment in Affiliate - 114160; CHANGE IN VALUE OF SPLIT INTEREST AGREEMENT - -130262; Transfer of Net Assets to Affiliate - 1300000; Loss on Bond Refinancing - -465116;”