University Medical Group Inc

“Form 990, part vi, line 11b an outside accouting firm prepared the federal form 990. The controller and chief executive officer (ceo) of university medical group (umg) review the form 990. The ceo reports the organization's operating and financial results to the umg board of directors. The federal form 990 is also provided to the umg board of directors prior to filing.”

“Form 990, part vi, line 12c an institutional conflict of interest (icoi) may exist when umg board of director members or executives have external relationships or financial interest (hereinafter defined as significant financial interests) in a company or organization that has significant business transactions with the organization. These dual relationships may interfere, or appear to interfere, with the obligation to act in the organization's best interest. Because the appearance of a conflict may be as damaging to the public trust as an actual conflict, potential conflicts must be disclosed, evaluated, and managed with the same thoroughness as actual conflicts. The integrity program oversight council (ipoc) is the board-designated body to review potential icoi's as described above. Potential icoi's will be identified through the executive and board member conflict of interest disclosures and other sources. This policy applies to all umg board of directors members and umg executives. Umg board of directors members and umg executives shall disclose to the ipoc annually, on a form approved by the ipoc, relationships and circumstances that could, to the best of the executive's knowledge, pose a potential or actual conflict of interest under this policy. If the ipoc believes a disclosure poses a potential or actual conflict, it shall indicate to the umg board of directors member or umg executive how to dispose of or manage the conflict. Disclosures are due annually. If the responses to any of the questions change during the year, the disclosure form must be revised and resubmitted. Any real or apparent icoi must be reviewed by the ipoc, which may impose management conditions including, but not limited to: a. Ensuring that institutional financial interests and investments are being managed by individuals/departments that are not involved in purchasing, procurement, contracting, research, or other operations decisions and oversight; b. Requiring public disclosure of the institutional coi in publications, presentations, or other public announcements; c. Imposing an escrow period for realizing a financial gain (cashing out); d. Divesting the financial interest; e. Reassigning, removing, or otherwise making a firewall for executives who may be conflicted or perceived as not having "clean hands" for any business decisions or activities involving any entity with which the executive has a significant financial interest; f. Notification to a donor that gifts to umg will not be taken into account for future business relationships, or refusal or return of gifts, entertainment, or other prerequisites from an entity that has a business relationship with umg or in which umg and/or an executive has an investment; and/or g. Other management plans that the ipoc may design. Icoi management is in addition to any management that might apply for individual conflicts of interest.”

“Form 990, Part VI, Line 15A & 15B The compensation for the University Medical Group COO, also serving as the OHSU Director of Enterprise Revenue Cycle, was derived by data gathered from an engagement with Sullivan Cotter and Associates. With this data, the UMG CEO and OHSU Hospital CFO determined the base pay level. For incentive compensation, formulaic components consistent with the OHSU Management Incentive Program (MIP) were used to define the bonus amount based upon the rollup of various revenue cycle performance goals across both UMG and OHSU. The CEO and Hospital CFO presented the performance evaluation, bonus goal results and a base compensation & bonus proposal to the Dean of the OHSU School of Medicine and the OHSU Executive Vice President for their collective approval. The compensation for the University Medical Group CEO, also serving as the Sr. Associate Dean, Clinical Practice for the School of Medicine, was derived by data gathered primarily from two compensation survey sources: Gallagher Integrated National HealthCare Leadership Compensation Survey and Mercer/COTH (Council of Teaching Hospitals) Healthcare System and Hospital Survey. The Dean of OHSU School of Medicine ultimately determined base pay level. For incentive compensation, this position was deemed eligible for the OHSU University Incentive Plan, which consists of three components for award determination: Achievement of a minimum Financial Threshold, Individual Leadership, and Individual Performance Goals. Financial performance is confirmed by OHSU's CFO and Leadership and Individual Performance is reviewed and confirmed by the Dean of OHSU School of Medicine.”

“Form 990, part vi, line 19 while federal tax laws do not mandate that the organization's governing documents and financial statements be made available for public inspection, university medical group will provide these documents upon request.”

“FORM 990, PART VI, LINE 13 Commitment We are committed to fostering a climate of integrity and high ethical standards, which are reflected in our policies and procedures. We provide an environment where people are encouraged to ask questions and report concerns without retribution or retaliation. Protection Against Retaliation: UMG will not retaliate in any way against an employee because the employee has made a good faith complaint pursuant to this Policy, or because an employee has reported harassing or discriminatory conduct directed at others, or has participated in an investigation of such conduct, nor will UMG permit any other employee to do so. Any employee who is found to have retaliated against another employee in violation of this Policy will be subject to disciplinary action up to and including termination of employment. Responsive Action: Misconduct constituting harassment, discrimination or retaliation will be dealt with promptly and appropriately. Responsive action may include, for example, training, referral to counseling, monitoring of the offender and/or disciplinary action such as warning, reprimand, withholding of a promotion or pay increase, reduction of wages, demotion, reassignment, temporary suspension without pay or termination, as UMG believes appropriate under the circumstances. UMG will not tolerate any unlawful retaliation against anyone who makes a complaint in good faith or cooperates in an investigation in good faith. Any employee learning of an improper disclosure of confidential information shall report immediately to one of the following individuals: A. Their supervisor/manager B. Human Resources C. Executive Management to include the Compliance Officer, COO, and/or CEO. D. The OHSU Integrity Hotline, 877-733-8313. Reports can be made anonymously.”

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