National Health Law Program Inc.

“The finance committee of the board shall have the responsibility for reviewing the organization's form 990 (including all pertinent schedules) before it is filed with the internal revenue service. A draft of the form 990 should be ready for review by the finance committee of the board prior to the filing deadline. If the next finance committee of the board meeting is not scheduled soon enough, the draft will be sent to all the board members via email. Board members can then ask or make questions, comments, and suggested revisions. In conducting their review of the draft of the form 990, it is preferred that the finance committee of the board shall conduct a top-level or big-picture type of review. However, if the finance committee of the board desires or deems it necessary to conduct a more detailed review of the form 990, then they should contact the preparer of the form 990 to request copies of the relevant detailed tax return workpapers which they would like to see. Once the finance committee of the board has completed its initial review of the form 990, a meeting or conference call will be scheduled with the coo or preparer of the form 990 (regardless of whether the form 990 is externally or internally prepared) to discuss any questions, comments, and suggested revisions identified by the board. The preparer of the form 990 should make any revisions to the form 990 as soon as feasibly possible to ensure that the form 990 is filed with the internal revenue service on a timely basis. All of the questions, comments, and suggested revisions set forth by the finance committee of the board should be documented, along with any responses from the preparer of the form 990, if applicable.”

“The organization requires all board members to complete an annual questionnaire to verify there are no conflicts of interest or that any conflicts of interest are documented.”

“The organization follows the procedures below in determining insider compensation: the insiders of the organization are deemed as follows: -any member of the board of directors -any officer of the organization -executive director -any family member for any of the aforementioned definition of compensation - all-inclusive, including all compensatory benefits received (other than nontaxable fringe benefits); includes salaries, bonuses, taxable fringe benefits, retirement plan contributions, loan agreements, and deferred compensation amounts. Definition of reasonable compensation - amount of compensation a similar enterprise, whether taxable or tax-exempt, would pay for similar services under similar circumstances; reasonableness of compensation can be established by independent compensation surveys and actual written offers from similar institutions. When determining the annual compensation for any insider, the organization shall always undertake and satisfy all three prongs of the rebuttable presumption set forth in the internal revenue code regarding intermediate sanctions (section 4958). 1. Compensation arrangement approved in advance by independent members of the organization's governing body (board of directors or a subcommittee thereof) that is composed of persons who do not have a conflict of interest with respect to the compensation arrangement. 2. Before making the reasonable compensation determination, the governing body (or subcommittee thereof) relied upon comparability data (comparability data includes compensation paid by comparable and similarly situated entities) in deciding whether to approve the compensation. 3. Governing body contemporaneously documents its basis for making a reasonable compensation determination, as follows: a. Terms of the approved compensation and the date approved by the board, b. Members of the board present during debate on the compensation amount and those who voted on it and how they voted on it, c. Description of the comparability data obtained and relied upon and how such data was obtained, d. Any actions by a board member having a conflict of interest (e.g. Disclosure of the conflict of interest; recusal from the discussion), e. Documentation of the basis for the compensation determination before the later of the next board meeting or 60 days after the final actions of the authorized body are taken. It is essential that any individual whose compensation is being discussed not be present during such discussions. All identified payments of unreasonable compensation to an insider should be corrected (undoing of the unreasonable compensation to the extent possible) as soon as feasibly possible; for example, the insider should pay back to the organization the unreasonable compensation amounts plus interest to put the organization in a financial position no worse than that in which it would be if the insider were dealing under the highest fiduciary standards. The reasonable compensation discussion should be undertaken by the board at least annually. The organization shall refrain, whenever possible, from paying contingent compensation to insiders and also avoid the payment of golden parachute payments to insiders.”

“Procedures for public inspection of documents the following organizational documents of the organization will be available (for inspection or copying) at the organization's main office during normal business hours at no charge: - tax exemption application (form 1023) - internal revenue service determination letter - articles of incorporation - by-laws - public inspection copy of the form 990 for the previous three years the public inspection copy of the form 990 will not include schedule a - excess contributors or schedule b - names and addresses of contributors. The organization will make best efforts to ensure that the forms 990 held at their main office are the most updated versions of such. For example, in the instance where a form 990 has been amended, the amended version of the form 990 should be the one available for public inspection. When responding to a public inspection request for any organizational document or form 990 by anyone, the organization shall fulfill such request in a timely fashion without inquiring as to the reason for the public inspection request.”

“Depreciation - book/tax difference 2,232.”