General Health System Foundation

“During the preparation of the system 990s, senior finance leaders are consulted to provide any additional information of certain, various transactions on an as-needed basis. Upon completion of the 990 but prior to filing, said leaders are provided with a draft copy of all forms/schedules for their review and comments. Upon clearing any review comments, revised draft copies are forwarded to members of the board's finance committee for their review and recommendation to the full system board . Ultimately, final approval is given for filing of the completed 990 return.”

“The ghs compliance office coordinates obtaining conflict disclosures from the leadership and board members of the system. The compliance office reviews and organizes the results and does a first review of the reported disclosures for possible conflicts. Further information is obtained from management as needed to clarify or rectify any issues noted. Any potential conflicts are reviewed for appropriate mitigation to ensure the best interests of the organization drive business decisions. Results are discussed with the chief executive officer and chief financial officer and shared with the chairman of the board and audit committee.”

“The president/ceo and cfo are employed and compensated by general health system, parent company of the foundation. The compensation committee of the ghs board oversees all executive compensation. The committee engages an independent third party consulting firm to conduct an annual market-based compensation review of executives in comparable healthcare systems and uses this data in determining reasonable and appropriate compensation levels. The committee considers many factors in determining executive compensation levels including, but not limited to, the knowledge, experience and competencies of the executive, performance of the executive's areas of responsibility, importance of executive retention, peer calibration and talent management rating.”

“The taxpayer makes all governing documents, conflict of interest policies and tax returns available to the public on an as-requested basis. The taxpayer's 501c3 parent company, general health system (#72-0475545), provides centralized management, banking, accounts payable and accounts receivable/billing, payroll, accounting/tax, internal audit and compliance, human resources, risk management, insurance, employee benefits management, information technology and legal services to all members of general health system (ghs). All monies collected from or spent for all ghs-related entities are deposited into/spent from centralized ghs bank accounts and accounted for as received or disbursed.”

“The foundation is a wholly-owned subsidiary of parent company, general health system (ghs/the system). General health system (ein 72-0475545) is also a 501c3 organization. Page 6, part vi, sec b, line 11b during the preparation of the system 990s, senior finance leaders are consulted to provide any additional information of certain, various transactions on an as-needed basis. Upon completion of the 990 but prior to filing, said leaders are provided with a draft copy of all forms/schedules for their review and comments. Upon clearing any review comments, revised draft copies are forwarded to members of the board's finance committee for their review and recommendation to the full system board. Ultimately, final approval is given for ling of the completed 990 return. Page 6, part vi, sec b, line 12c the ghs compliance office coordinates obtaining conflict disclosures from the leadership and board members of the system. The compliance office reviews and organizes the results and does a first review of the reported disclosures for possible conflicts. Further information is obtained from management as needed to clarify or rectify any issues noted. Any potential conflicts are reviewed for appropriate mitigation to ensure the best interests of the organization drive business decisions. Results are discussed with the chief executive officer and chief financial officer and shared with the chairman of the board and audit committee. Page 6, part vi, sec b, lines 15a & b the president/ceo and cfo are employed and compensated by general health system, parent company of the foundation. The compensation committee of the ghs board oversees all executive compensation. The committee engages an independent third party consulting firm to conduct an annual market-based compensation review of executives in comparable healthcare systems and uses this data in determining reasonable and appropriate compensation levels. The committee considers many factors in determining executive compensation levels including, but not limited to, the knowledge, experience and competencies of the executive, performance of the executive's areas of responsibility, importance of executive retention, peer calibration and talent management rating. Page 6, part vi, sec c, line 19 the taxpayer makes all governing documents, conflict of interest policies and tax returns available to the public on an as-requested basis. The taxpayer's 501c3 parent company, general health system (#72-0475545), provides centralized management, banking, accounts payable and accounts receivable/billing, payroll, accounting/tax, internal audit and compliance, human resources, risk management, insurance, employee benefits management, information technology and legal services to all members of general health system (ghs) . All monies collected from or spent for all ghs-related entities are deposited into/spent from centralized ghs bank accounts and accounted for as received or disbursed.”