Path Drug Solutions

“The form 990 was prepared by an outside accounting firm (gelman, rosenberg & freedman, cpas), using information provided by path accounting services staff. Path senior management reviewed the draft form. A copy of the draft was sent to pds's board of directors for comment. After the comment period, the chief financial officer signed and filed the return.”

“Pds has a written conflict of interest policy under which all pds board members and officers must complete a conflict of interest disclosure form each year. Pds does not have employees. Pds is a supporting organization to path within the meaning of internal revenue code section 509(a)(3) and contracts with path for management services. Path has a written conflict of interest policy under which all path board members, officers, and staff at higher than a designated level must annually complete a conflict of interest disclosure form. All pds and path disclosure forms are reviewed and kept on file. A conflict management plan is developed for any employee with a significant actual or perceived conflict of interest. Path also has a well-defined procedure for identifying and reporting actual and potential conflicts of interest among board members. New board members are asked to complete a conflict of interest disclosure form within 30 days of joining the board and to complete a new form annually thereafter. In addition, members are reminded to report any new issues that arise outside of the annual disclosure period. The disclosure forms are reviewed by path's general counsel and, if any actual or potential conflicts are identified, general counsel makes a recommendation to the chair of the governance committee and the chair of the board for a management plan to properly manage any conflicts. A formal management plan is then agreed upon with the board member and the entire board of directors is informed at the next regularly scheduled board meeting.”

“Pds makes its governing documents, conflict of interest policy, and financial statements available to the public upon request.”

“From time to time, unspent award funds (or unused obligation) may be returned to a funder for a variety of reasons including, but not limited to, early termination of a project by a funder or a reduction in funds required to accomplish a project's scope of work. -1,440,000.”