2024-10-10T15:56:44-05:00 2023-12-31 562306396 BEACH FREEMAN LIM & CLELAND LLP 861 PARKVIEW DR N SUITE 200 EL SEGUNDO CA 90245 990 2023-01-01 953080947 NATIONAL HEALTH LAW PROGRAM INC NATI 3102046010 3701 WILSHIRE BLVD 315 LOS ANGELES CA 90010 ELIZABETH TAYLOR EXECUTIVE DIRECTOR 3102046010 2024-10-09 1 0 STEVE CLELAND P00367242 3104471234 2023 2024-10-15 13:58:12Z ELIZABETH TAYLOR 3701 WILSHIRE BLVD 315 LOS ANGELES CA 90010 11543569 0 X WWW.HEALTHLAW.ORG X 1976 CA TO PROTECT AND ADVANCE THE HEALTH RIGHTS OF LOW INCOME AND UNDERSERVED INDIVIDUALS. 14 14 56 11 0 0 10734416 8293724 40712 655406 206798 734964 95203 69703 11077129 9753797 2429379 976243 0 0 5955117 7499012 0 0 677604 1516207 1744679 9900703 10219934 1176426 -466137 25831527 26323333 1751201 2035717 24080326 24287616 X SEE SCHEDULE O.THE NATIONAL HEALTH LAW PROGRAM PROTECTS AND ADVANCES THE HEALTH CARE RELATED CIVIL RIGHTS OF LOW-INCOME INDIVIDUALS, FAMILIES, AND UNDERSERVED COMMUNITIES. OUR ADVOCACY STRIVES TO GIVE VOICE TO LOW-INCOME PEOPLE AND FAMILIES IN FEDERAL AND STATE POLICY MAKING. THE NATIONAL HEALTH LAW PROGRAM LITIGATES TO ENSURE THAT LOW-INCOME PEOPLE AND UNDERSERVED COMMUNITIES CAN OBTAIN QUALITY HEALTH CARE TO WHICH THEY ARE ENTITLED BECAUSE OF VARIOUS FEDERAL AND STATE LAWS, SUCH AS MEDICAID, THE AFFORDABLE CARE ACT, AMERICANS WITH DISABILITIES ACT, THE CHILDREN'S HEALTH INSURANCE PROGRAM, THE CIVIL RIGHTS ACT OF 1964 AND MANY OTHER LAWS AND POLICIES. 0 0 3980400 976243 316826 SEE SCHEDULE O.LITIGATION:PARTNERING WITH STATE AND LOCAL ADVOCATES ACROSS THE COUNTRY, ATTORNEYS FOR THE NATIONAL HEALTH LAW PROGRAM REPRESENTED LOW-INCOME INDIVIDUALS AND FAMILIES IN LITIGATION TO ENFORCE PROVISIONS OF THE MEDICAID ACT AND OTHER FEDERAL AND STATE HEALTH AND CIVIL RIGHTS LAWS.FOR EXAMPLE, IN 2023, THE ORGANIZATION BROUGHT LITIGATION TO PREVENT STATES FROM UNLAWFULLY DROPPING PEOPLE FROM THE MEDICAID ROLLS AS THEY REDETERMINE MEDICAID ELIGIBILITY NOW THAT THE COVID EMERGENCY HAS OFFICIALLY ENDED. WE ALSO CONTINUED LITIGATION TO ENSURE TRANSPARENCY AND ACCOUNTABILITY, DUE PROCESS, AND ACCESS TO SERVICES, INCLUDING SEVERAL CASES TO ENSURE THAT MEDICALLY FRAGILE CHILDREN RECEIVE THE SERVICES THAT ARE GUARANTEED THEM UNDER MEDICAID'S EARLY AND PERIODIC SCREENING, DIAGNOSTIC AND TREATMENT PROVISIONS AND CASES TO ENFORCE THE ANTI-DISCRIMINATION PROVISIONS OF THE AFFORDABLE CARE ACT. 1581385 21755 SEE SCHEDULE O.NATIONAL POLICY:THE NATIONAL HEALTH LAW PROGRAM'S HEALTH POLICY WORK ADVOCATES FOR PROTECTION AND EXPANSION OF HEALTH AND CIVIL RIGHTS OF LOW-INCOME INDIVIDUALS AND FAMILIES AND UNDERSERVED COMMUNITIES. THE NATIONAL HEALTH LAW PROGRAM'S HEALTH POLICY EFFORTS IN 2023 INCLUDED BUT WERE NOT LIMITED TO THE FOLLOWING: (1) ADVOCATING FOR LEGISLATION TO CLOSE THE COVERAGE GAP AND INCREASE FUNDING FOR HOME AND COMMUNITY BASED SERVICES; (2) WORKING TO PREVENT DAMAGE CAUSED BY THE END OF THE PUBLIC HEALTH EMERGENCY, THROUGH ADVOCACY AT THE FEDERAL LEVEL AND SUPPORT TO ADVOCATES AT THE STATE LEVEL; (3) PROVIDING LEGAL AND POLICY SUPPORT TO NATIONAL AND STATE BASED COALITIONS WORKING TO PROTECT, AND WHERE POSSIBLE, EXPAND ACCESS TO HEALTH CARE FOR LOW-INCOME INDIVIDUALS, FAMILIES AND UNDERSERVED COMMUNITIES; (4) PROVIDING LEGAL SUPPORT AND PROBLEM-SOLVING EXPERTISE TO POLICYMAKERS, ADVOCATES, AND PROVIDERS AS LEGAL ISSUES ARISE AT THE ADMINISTRATIVE (REGULATORY) AND STATE IMPLEMENTATION LEVELS; (5) PROVIDING LEGAL SUPPORT TO POLICYMAKERS TO CONSIDER NEW MODELS FOR PROVIDING HEALTH CARE TO ALL.DURING 2023 THE NATIONAL HEALTH LAW PROGRAM AGAIN INCREASED ITSSUBSTANTIAL EFFORTS TO COUNTER HEALTH CARE DISPARITIES AND DEFEND CIVIL RIGHTS LAWS, INCLUDING BY ADVOCATING FOR STRONG REGULATIONS TO ENFORCE SECTION 1557, THE ANTI-DISCRIMINATION PROVISION OF THE AFFORDABLE CARE ACT.IN 2023, NATIONAL HEALTH LAW PROGRAM STAFF PROVIDED STATE AND FEDERAL HEALTH CARE ADVOCATES LEGAL ASSISTANCE FOR MYRIAD POLICY AND LEGAL CONCERNS OF LOW-INCOME INDIVIDUALS AND FAMILIES. STAFF MEMBERS WERE ALSO INVOLVED IN AND/OR FEATURED IN SCORES OF CONFERENCES AND TRAINING EVENTS. STAFF ALSO PRODUCED NUMEROUS FACT SHEETS, ISSUE BRIEFS, Q&A'S, AND ADDITIONAL RESOURCES THAT WERE SHARED VIA LISTSERVS, EMAIL, SOCIAL MEDIA PLATFORMS, PRESS OUTREACH, AND OTHER MEANS. MUCH OF THIS WORK PRODUCT WAS ALSO POSTED ON THE ORGANIZATION'S WEBSITE. 1646574 315065 SEE SCHEDULE O.CALIFORNIA POLICY:IN 2023, THE NATIONAL HEALTH LAW PROGRAM ENGAGED IN SIGNIFICANT EFFORTS TO HELP DEVELOP AND IMPLEMENT IMPROVEMENTS TO CALIFORNIA'S PUBLICLY FUNDED HEALTH CARE SYSTEM. SOME OF THE KEY HEALTH CARE EXPANSION EFFORTS INCLUDED: EXPANDING ACCESS TO PREMIUM ASSISTANCE FOR MARKETPLACE INSURANCE REGARDLESS OF IMMIGRATION STATUS, IMPLEMENTING THE EXPANSION OF MEDI-CAL COVERAGE AND ACCESS TO SERVICES AMONG JUSTICE-INVOLVED POPULATIONS IN CALIFORNIA; INCLUDING COMMUNITY HEALTH WORKERS, DOULA BENEFITS, BEHAVIORAL HEALTH SERVICES, SERVICES FOR FOSTER YOUTH, AND MANY OTHERS, AS MEDI-CAL BENEFITS; CONTINUING ONGOING EFFORTS TO EXPAND ACCESS TO SEXUAL AND REPRODUCTIVE HEALTH CARE, INCLUDING DOULA AND CONTRACEPTIVE SERVICES; AND IMPLEMENTING CHANGES TO MEDI-CAL THROUGH THE CALIFORNIA ADVANCING AND INNOVATING MEDI-CAL (CALAIM) INITIATIVE. 874956 THE NATIONAL HEALTH LAW PROGRAM ENGAGED IN A NUMBER OF TARGETED PROJECTS TO SUPPORT OUR PRIMARY GOALS. 874956 8083315 1 1 0 1 0 0 0 0 0 0 1 0 0 0 1 1 1 0 0 0 0 0 0 0 1 0 0 1 0 1 0 0 0 0 0 0 0 0 1 0 0 0 0 0 0 0 0 1 21 0 1 56 1 0 0 0 0 0 0 0 0 0 0 X 14 14 0 0 0 0 0 0 0 1 1 0 1 1 1 1 1 1 1 1 1 1 0 CA X RSM US LLP 2022932200 1250 H ST NW 700 WASHINGTON DC 20005 MARC FLEISCHAKER GENERAL COUNSEL 5.00 X 0 0 0 JANE PREYER BOARD MEMBER 5.00 X 0 0 0 ARIAN JUNE BOARD MEMBER 5.00 X 0 0 0 REP HENRY WAXMAN SENIOR ADVISOR TO THE BOARD 5.00 X 0 0 0 ANN KAPPLER CHAIR 5.00 X 0 0 0 SHAMINA SNEED SECRETARY 5.00 X 0 0 0 NICK SMIRENSKY TREASURER 5.00 X 0 0 0 RON L WISOR JR BOARD MEMBER 5.00 X 0 0 0 MICHELE JOHNSON BOARD MEMBER 5.00 X 0 0 0 WILLIAM B SCHULTZ VICE CHAIR 5.00 X 0 0 0 LOURDES A RIVERA BOARD MEMBER 5.00 X 0 0 0 DONALD B VERRILLI JR BOARD MEMBER 5.00 X 0 0 0 LD BRITT BOARD MEMBER 5.00 X 0 0 0 JEANNA CULLINS BOARD MEMBER 5.00 X 0 0 0 STEPHEN WILLIAMS BOARD MEMBER 5.00 X 0 0 0 JOEL FERBER BOARD MEMBER 5.00 X 0 0 0 ELIZABETH TAYLOR EXECUTIVE DIRECTOR 45.00 X 347856 0 9814 JORGE ADRIAN NARANJO CHIEF OPERATING OFFICER 45.00 X 227956 0 48904 KIMBERLY LEWIS MANAGING ATTORNEY 45.00 X 199001 0 32098 MARA YOUDELMAN MANAGING ATTORNEY 45.00 X 211688 0 7360 JANE PERKINS LEGAL DIRECTOR 45.00 X 263514 0 30414 SARAH SOMERS MANAGING ATTORNEY 45.00 X 202545 0 24167 1452560 0 152757 6 0 1 0 RSM LLP 5155 PAYSPHERE CIRCLE CHICAGO IL 606740051 ACCOUNTING & CONSULTING 137870 1 21025 8272699 1792307 8293724 ATTORNEY FEES 541100 633651 633651 CONFERENCE FEES & HONORARIUM 611430 20440 20440 PUBLICATIONS 513120 1315 1315 655406 736784 736784 70190 0 70190 70190 70190 1787405 1785095 4130 2310 -4130 -1820 -1820 0 21025 547 -547 -547 MISCELLANEOUS REVENUE 900099 60 60 60 9753797 653646 0 806427 976243 976243 587413 452952 83810 50651 99581 76786 14208 8587 5491793 4234696 783552 473545 125386 96684 17890 10812 740274 570822 105620 63832 454565 350513 64856 39196 271580 201569 69708 303 204676 151913 52535 228 47982 38332 9642 8 368341 294266 74017 58 94206 67092 21957 5157 34232 19037 13394 1801 349 279 70 39333 29132 8561 1640 PROFESSIONAL SERVICES 306481 227473 78666 342 REPAIRS & MAINTENANCE 125758 93339 32279 140 OFFICE SUPPLIES 85805 78808 6676 321 TELEPHONE & INTERNET SE 36154 28883 7265 6 129782 94496 14309 20977 10219934 8083315 1459015 677604 13050102 2065384 2378362 2431895 192373 312246 62149 45573 12661 12661 4479 0 9577390 20615886 566672 852349 25831527 26323333 1170455 1158221 9569 571177 877496 1751201 2035717 X 15030719 17577246 9049607 6710370 24080326 24287616 25831527 26323333 X -466137 789135 803287 -918995 X 0 1 X 1 0 X 10722725 8513015 11148747 10734416 8293724 49412627 10722725 8513015 11148747 10734416 8293724 49412627 26204491 23208136 227584 241529 194759 206798 809284 1679954 6176 8250 2503 60 16989 51109570 1476015 0.45410 0.50520 X RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED 3031 89734 92765 10931003 11023768 701188 175297 0 0 585281 623682 669503 701188 2579654 3869481 56577 80553 57033 92765 286928 146320 155921 167376 175297 644914 967371 3031 3031 12661 12661 0 0 LEASE LIABILITIES 877496 877496 X 11231058 789135 803834 1592969 9638089 115708 115708 9753797 11023768 803834 803834 10219934 0 10219934 PART X, LINE 2: THE ENTITY EVALUATES UNCERTAIN TAX POSITIONS WHEREBY THE EFFECT OF THE UNCERTAINTY WOULD BE RECORDED IF THE TAX POSITIONS WERE MORE LIKELY THAN NOT TO BE SUSTAINED UPON EXAMINATION. AS OF YEAR-END, THE ENTITY HAD NO UNCERTAIN TAX POSITIONS REQUIRING ACCRUAL OR DISCLOSURE. PART XI, LINE 2D - OTHER ADJUSTMENTS: IN-KIND/PRO BONO SERVICES 803,287. DIRECT FUNDRAISING EVENT EXPENSES 547. PART XI, LINE 4B - OTHER ADJUSTMENTS: INVESTMENT INCOME 115,708. PART XII, LINE 2D - OTHER ADJUSTMENTS: IN-KIND/PRO BONO EXPENSES 803,287. DIRECT FUNDRAISING EVENT EXPENSES 547. 50TH ANNIVERSARY 21025 21025 547 21025 21025 547 547 -547 1 CENTER FOR CIVIL JUSTICE (MI) 436 S SAGINAW ST SUITE 400 FLINT MI 48502 381859780 40000 0 HEALTH LAW PARTNERSHIP CHARLOTTE CENTER FOR LEGAL ADVOCACY INC 1431 ELIZABETH AVE CHARLOTTE NC 28204 561202940 50000 0 HEALTH LAW PARTNERSHIP DISABILITY LAW CENTER (UTAH) 205 N 400 WEST SALT LAKE CITY UT 84103 870326807 50000 0 HEALTH LAW PARTNERSHIP FLORIDA HEALTH JUSTICE PROJECT (FHJP) 3793 IRVINGTON AVENUE MIAMI FL 33133 823397515 40014 0 HEALTH LAW PARTNERSHIP & MEDICAID MONITORING PROJECT INDIANA JUSTICE PROJECT 6101 NORTH KEYSTONE AVENUE INDIANAPOLIS IN 46220 861217450 50000 0 HEALTH LAW PARTNERSHIP LEGAL AID OF ARKANSAS 1200 WEST WALNUT STREET SUITE 3101 ROGERS AR 727563521 710439977 45000 0 HEALTH LAW PARTNERSHIP & MEDICAID MONITORING PROJECT & ADS LEGAL AID SOCIETY OF COLUMBUS 1108 CITY PARK AVE 100 COLUMBUS OH 43206 314416407 50000 0 HEALTH LAW PARTNERSHIP LEGAL COUNCIL FOR HEALTH JUSTICE (LCHJ) 17 N STATE ST 900 CHICAGO IL 60602 363563802 40000 0 HEALTH LAW PARTNERSHIP & MEDICAID MONITORING PROJECT LEGAL SERVICES OF EASTERN MISSOURI (LSEM) 4232 FOREST PARK AVE ST LOUIS MO 63108 430816805 127400 0 HEALTH LAW PARTNERSHIP & MEDICAID MONITORING PROJECT TENNESSEE JUSTICE CENTER 211 7TH AVE N 100 NASHVILLE TN 37219 621630417 70000 0 HEALTH LAW PARTNERSHIP & MEDICAID MONITORING PROJECT THE ARC OF THE UNITED STATES 2000 PENNSYLVANIA AVENUE NW SUITE 500 WASHINGTON DC 20006 135642032 44000 0 ADMIN ADVOCACY NEBRASKA APPLESEED 941 O ST SUITE 920 LINCOLN NE 68508 470798343 40000 0 HEALTH LAW PARTNERSHIP COLORADO CENTER OF LAW & POLICY 789 N SHERMAN ST STE 300 DENVER CO 80203 841264154 45000 0 HEALTH LAW PARTNERSHIP COMMUNITY LEGAL AID SOCIETY INC 100 WEST 10TH STREET WILMINGTON DE 19801 516000158 45000 0 HEALTH LAW PARTNERSHIP DISABILITY RIGHTS CONNECTICUT 864 WETHERSFIELD AVENUE HARTFORD CT 06114 813156636 45000 0 HEALTH LAW PARTNERSHIP MOUNTAIN STATE JUSTICE 1217 QUARRIER STREET CHARLESTON WV 25301 550748332 40000 0 HEALTH LAW PARTNERSHIP NATIONAL CENTER FOR LESBIAN RIGHTS 870 MARKET STREET SUITE 370 SAN FRANCISCO CA 94102 943086885 10000 0 ADMIN ADVOCACY ALABAMA DISABILITIES ADVOCACY PROGRAM UNIVERSITY OF ALABAMA BOX 870136 TUSCALOOSA AL 35487 636001138 45000 0 ADS MISSISSIPPI CENTER FOR JUSTICE 5 OLD RIVER PLACE SUITE 203 JACKSON MS 39202 134203234 45000 0 HEALTH LAW PARTNERSHIP OREGON LAW CENTER 522 SW 5TH AVE STE 812 PORTLAND OR 97204 931194564 50000 0 HEALTH LAW PARTNERSHIP SCHEDULE I, PART II ONE OF THE GRANTORS DISCLOSED ON SCHEDULE I RELFECTS PRIOR PERIOD ADJUSTMENTS TO TRUE-UP GRANTS ACCROSS ALL DONORS, WITH ADJUSTMENTS APPLIED TO FLORIDA HEALTH JUSTICE PROJECT (FHJP) FOR REPORTING PURPOSES. THE TOTAL GRANTS TO FHJP FOR 2023 AMOUNT TO $142,400; HOWEVER, THE ADJUSTED AMOUNT OF $40,014 REPRESENTS CUMULATIVE ADJUSTMENTS NECESSARY TO RECONCILE PAST DISCREPANCIES FOR ALL GRANTORS. THIS IS A FINAL TRUE-UP, AND NO FURTHER ADJUSTMENTS WILL BE MADE GOING FORWARD. X X X 0 0 0 0 0 0 0 0 0 ELIZABETH TAYLOR EXECUTIVE DIRECTOR 347856 0 0 0 0 0 8265 0 1549 0 357670 0 0 0 JANE PERKINS LEGAL DIRECTOR 263514 0 0 0 0 0 7905 0 22509 0 293928 0 0 0 JORGE ADRIAN NARANJO CHIEF OPERATING OFFICER 227956 0 0 0 0 0 7187 0 41717 0 276860 0 0 0 KIMBERLY LEWIS MANAGING ATTORNEY 199001 0 0 0 0 0 5826 0 26272 0 231099 0 0 0 SARAH SOMERS MANAGING ATTORNEY 202545 0 0 0 0 0 6096 0 18071 0 226712 0 0 0 MARA YOUDELMAN MANAGING ATTORNEY 211688 0 0 0 0 0 5946 0 1414 0 219048 0 0 0 X 2 1792307 MARKET PRICE 0 0 0 FORM 990, PART VI, SECTION B, LINE 11B 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, THE FINANCE COMMITTEE WILL APPROVE THE REVIEW VIA EMAIL TO THE COO. 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. FORM 990, PART VI, SECTION B, LINE 12C 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. FORM 990, PART VI, SECTION B, LINE 15 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. FORM 990, PART VI, SECTION C, LINE 19 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 THE FOLLOWING DOCUMENTS OF THE ORGANIZATION WILL BE AVAILABLE ONLINE AT HEALTHLAW.ORG: - PUBLIC INSPECTION COPY OF THE FORM 990 FOR THE PREVIOUS THREE YEARS - AUDITED FINANCIAL STATEMENTS 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. FORM 990, PART XI, LINE 9: IN-KIND/PRO BONO SERVICES -803,287. INVESTMENT INCOME -115,708.