Department of the Treasury Internal Revenue Service
Public Charity Status and Public Support
Complete if the organization is a section 501(c)(3) organization or a section
4947(a)(1) nonexempt charitable trust.
Attach to Form 990 or Form 990-EZ. See separate instructions.
OMB No. 1545-0047
2010
Open to Public Inspection
Name of the organization
United States Pharmacopeial Convention
Employer identification number
13-1656692
Part I
Reason for Public Charity Status
(All organizations must complete this part.) See instructions
The organization is not a private foundation because it is: (For lines 1 through 11, check only one box.)
1
2
3
4
5
section 170(b)(1)(A)(iv). (Complete Part II.)
6
7
8
9
receipts from activities related to its exempt functions—subject to certain exceptions, and (2) no more than 331/3% of
its support from gross investment income and unrelated business taxable income (less section 511 tax) from businesses
acquired by the organization after June 30, 1975. See section 509(a)(2). (Complete Part III.)
10
11
e
By checking this box, I certify that the organization is not controlled directly or indirectly by one or more disqualified persons other than foundation managers and other than one or more publicly supported organizations described in section 509(a)(1) or section 509(a)(2).
f
If the organization received a written determination from the IRS that it is a Type I, Type II or Type III supporting organization, check this box
..................................................
g
Since August 17, 2006, has the organization accepted any gift or contribution from any of the following persons?
(i) a person who directly or indirectly controls, either alone or together with persons described in (ii)
Yes
No
and (iii) below, the governing body of the the supported organization?
................
11g(i)
(ii)
a family member of a person described in (i) above?
......................
11g(ii)
(iii)
a 35% controlled entity of a person described in (i) or (ii) above?
................
11g(iii)
h
Provide the following information about the supported organization(s).
(i) Name of supported organization
(ii) EIN
(iii) Type of organization (described on lines 1- 9 above or IRC section (see instructions))
(iv) Is the organization in col. (i) listed in your governing document?
(v) Did you notify the organization in col. (i) of your support?
(vi) Is the organization in col. (i) organized in the U.S.?
(vii) Amount of support?
Yes
No
Yes
No
Yes
No
Total
For Paperwork Reduction Act Notice, see the Instructions for Form 990.
Cat. No. 11285F
Schedule A (Form 990 or 990-EZ) 2010
Schedule A (Form 990 or 990-EZ) 2010
Page 2
Part II
Support Schedule for Organizations Described in IRC 170(b)(1)(A)(iv) and 170(b)(1)(A)(vi) (Complete only if you checked the box on line 5, 7, or 8 of Part I or if the
organization failed to qualify under Part III. If the organization fails to
qualify under the tests listed below, please complete Part III.)
Section A. Public Support
Calendar year(or fiscal year beginning in)
(a) 2006
(b) 2007
(c) 2008
(d) 2009
(e) 2010
(f) Total
1
Gifts, grants, contributions, and membership fees received. (Do not include any "unusual grants.") ....
2
Tax revenues levied for the organization's benefit and either paid to or expended on its behalf.......
3
The value of services or facilities furnished by a governmental unit to the organization without charge..
4
Total. Add lines 1 through 3..
5
The portion of total contributions by each person (other than a governmental unit or publicly supported organization) included
on line 1 that exceeds 2% of the amount shown on line 11, column (f)..
6
Public Support. Subtract line 5 from line 4.
Section B. Total Support
Calendar year(or fiscal year beginning in)
(a) 2006
(b) 2007
(c) 2008
(d) 2009
(e) 2010
(f) Total
7
Amounts from line 4..
8
Gross income from interest, dividends, payments received on securities loans, rents, royalties and income from similar sources..
9
Net income from unrelated business activities, whether or not the business is regularly carried on..
10
Other income. (Explain in Part IV.) Do not include gain or loss from the sale of capital assets..
11
Total support (Add lines 7 through 10).
12
Gross receipts from related activities, etc. (See instructions.)
..................
12
13
First Five Years
If the Form 990 is for the organization's first, second, third, fourth, or fifth tax year as a 501(c)(3) organization,
check this box and stop here..........................................
Section C. Computation of Public Support Percentage
14
Public Support Percentage for 2010 (line 6 column (f) divided by line 11 column (f))
.........
14
15
Public Support Percentage for 2009 Schedule A, Part II, line 14
...............
15
16a
33 1/3% support test—2010.
If the organization did not check the box on line 13, and line 14 is 33 1/3% or more, check this box
and stop here. The organization qualifies as a publicly supported organization
......................
b
33 1/3% support test—2009.
If the organization did not check the box on line 13 or 16a, and line 15 is 33 1/3% or more, check this
box and stop here. The organization qualifies as a publicly supported organization
.....................
17a
10%-facts-and-circumstances test—2010.
If the organization did not check a box on line 13, 16a, or 16b and line 14
is 10% or more, and if the organization meets the "facts and circumstances" test, check this box and stop here. Explain
in Part IV how the organization meets the "facts and circumstances" test. The organization qualifies as a publicly supported
organization
..................................................
b
10%-facts-and-circumstances test—2009.
If the organization did not check a box on line 13, 16a, 16b, or 17a and line
15 is 10% or more, and if the organization meets the "facts and circumstances" test, check this box and stop here.
Explain in Part IV how the organization meets the "facts and circumstances" test. The organization qualifies as a publicly supported organization
..............................................
18
Private Foundation
If the organization did not check a box on line 13, 16a, 16b, 17a or 17b, check this box and see
instructions
...................................................
Schedule A (Form 990 or 990-EZ) 2010
Schedule A (Form 990 or 990-EZ) 2010
Page 3
Part III
Support Schedule for Organizations Described in IRC 509(a)(2) (Complete only if you checked the box on line 9 of Part I or if the organization
failed to qualify under Part II. If the organization fails to qualify under
the tests listed below, please complete Part II.)
Section A. Public Support
Calendar year(or fiscal year beginning in)
(a) 2006
(b) 2007
(c) 2008
(d) 2009
(e) 2010
(f) Total
1
Gifts, grants, contributions, and membership fees received. (Do not include any "unusual grants.") .
11,772,541
26,931,741
52,825,043
37,060,996
11,476,249
140,066,570
2
Gross receipts from admissions, merchandise sold or services performed, or facilities furnished in any activity that is related to the organization's tax-exempt purpose......
90,362,415
103,539,671
111,335,523
117,254,467
133,976,191
556,468,267
3
Gross receipts from activities that are not an unrelated trade or business under section 513..
31,125
31,125
4
Tax revenues levied for the organization's benefit and either paid to or expended on its behalf...
5
The value of services or facilities furnished by a governmental unit to the organization without charge..
6
Total. Add lines 1 through 5.
102,134,956
130,471,412
164,160,566
154,315,463
145,483,565
696,565,962
7a
Amounts included on lines 1, 2, and 3 received from disqualified persons...
b
Amounts included on lines 2 and 3 received from other than disqualified persons that exceed the greater of $5,000 or 1% of the amount on line 13 for the year.
c
Add lines 7a and 7b..
8
Public Support (Subtract line 7c from line 6.)
696,565,962
Section B. Total Support
Calendar year (or fiscal year beginning in)
(a) 2006
(b) 2007
(c) 2008
(d) 2009
(e) 2010
(f) Total
9
Amounts from line 6...
102,134,956
130,471,412
164,160,566
154,315,463
145,483,565
696,565,962
10a
Gross income from interest, dividends, payments received on securities loans, rents, royalties and income from similar sources..
2,592,887
3,131,158
1,515,718
3,104,918
3,271,009
13,615,690
b
Unrelated business taxable income (less section 511 taxes) from businesses acquired after June 30, 1975.
c
Add lines 10a and 10b.
2,592,887
3,131,158
1,515,718
3,104,918
3,271,009
13,615,690
11
Net income from unrelated business activities not included in line 10b, whether or not the business is regularly carried on.
12
Other income. Do not include gain or loss from the sale of capital assets (Explain in Part IV.)
999,894
325,812
54,123
1,379,829
13
Total support (Add lines 9, 10c, 11 and 12.).
105,727,737
133,928,382
165,730,407
157,420,381
148,754,574
711,561,481
14
First Five Years
If the Form 990 is for the organization's first, second, third, fourth, or fifth tax year as a 501(c)(3) organization,
check this box and stop here.............................................
Section C. Computation of Public Support Percentage
15
Public Support Percentage for 2010 (line 8 column (f) divided by line 13 column (f))
.........
15
97.893 %
16
Public support percentage from 2009 Schedule A, Part III, line 15
...............
16
97.765 %
Section D. Computation of Investment Income Percentage
17
Investment income percentage for 2010 (line 10c column (f) divided by line 13 column (f))
......
17
1.913 %
18
Investment income percentage from 2009 Schedule A, Part III, line 17
.............
18
1.873 %
19a
33 1/3% support tests—2010.
If the organization did not check the box on line 14, and line 15 is more than 33 1/3% and line 17 is not more than 33 1/3%, check this box and stop here. The organization qualifies as a publicly supported organization
..........
b
33 1/3% support tests—2009.
If the organization did not check a box on line 14 or line 19a, and line 16 is more than 33 1/3% and line 18 is not more than 33 1/3%, check this box and stop here. The organization qualifies as a publicly supported organization
....
20
Private Foundation
If the organization did not check a box on line 14, 19a or 19b, check this box and see instructions
.....
Schedule A (Form 990 or 990-EZ) 2010
Schedule A (Form 990 or 990-EZ) 2010
Page 4
Part IV
Supplemental Information.
Supplemental Information. Complete this part to provide the explanation required by Part II, line 10; Part II, line 17a or 17b; or Part III, line 12. Also complete this part for any additional information. (See instructions).
Facts And Circumstances Test
Explanation
Schedule A (Form 990 or 990-EZ) 2010
Additional Data
Software ID:
Software Version:
-
TIN:
SCHEDULE O (Form 990 or 990-EZ)
Department of the Treasury Internal Revenue Service
Supplemental Information to Form 990 or 990-EZ
Complete to provide information for responses to specific questions on
Form 990 or to provide any additional information.
Attach to Form 990 or 990-EZ.
OMB No. 1545-0047
2010
Open to Public Inspection
Name of the organization
United States Pharmacopeial Convention
Employer identification number
13-1656692
Identifier
Return Reference
Explanation
Form 990, Part III, Line 4a
Compendial Programs USP establishes internationally recognized public standards (both documentary standards and the physical reference materials that support the application and use of these documentary standards) to help assure good quality medicines, dietary supplements, food ingredients, and related products used to maintain health and treat disease. These standards are developed using an open, public process with input from a wide array of scientists and healthcare professionals. Prescription and over the counter medicines available in the United States must, by federal law, meet USPs public standards, where such standards exist. Many other countries require the use of high-quality standards such as USPs to assure the quality of medicines, food ingredients, and related products. USP disseminates its standards to pharmaceutical manufacturers, pharmacists, food manufacturers, and other users through its USP-NF, Food Chemicals Codex (FCC), and other compendia and publications, official USP reference standard materials, and pharmacopeial education courses. These standards are shared with other countries around the world via their drug regulatory agencies and companies. Increasingly, those organizations are receiving assistance from USP in understanding how they can improve the quality of medicines provided to their citizens by using USP standards. Volunteer experts from those countries are active participants in USP's standards-setting bodies. In addition, USP develops standards that are vital to ensuring and improving patient safety in a variety of settings related to the appropriate use of medicines. Health care clinicians rely on these standards in their labeling, storage, distribution, and use of drugs and patients rely on these standards to help ensure that they are receiving the proper doses of the right medications.
Form 990, Part III, Line 4b
Allied Compendial Programs USP conducts verification programs for pharmaceutical ingredients, and for dietary supplement ingredients and products. These programs involve independent testing and review to verify the identity, strength, quality and purity of ingredients and products for manufacturers who choose to participate. They help to improve the quality of medicines and dietary supplements that are manufactured and then provided to patients and consumers through the global supply chain. USP conducts educational classes and programs for chemists, scientists, and healthcare practitioners in the United States and around the world. USP seeks to improve the effective use of its standards that affect best practices in manufacturing and regulation of pharmaceuticals, dietary supplements, and food ingredients.
Form 990, Part III, Line 4c
Non Compendial Programs - USP uses its knowledge base to provide information that supports the health care community in the research and development of patient safety initiatives, and serves as the secretariat for a major group of other non-profit organizations that join to coordinate patient safety/medical error efforts. USP develops authoritative, unbiased information relating to various aspects of drug quality and use and disseminates this information to practitioners, pharmacists, and others who make decisions about health care around the world. Under federal law, one of USPs health care information initiatives is the development of a drug classification system that Medicare prescription drug benefit plans may use to develop their formularies. Drug quality and information. USP participates in a cooperative agreement with the US Agency for International Development (USAID). This agreement advances drug quality and the appropriate use of drugs in some of the poorest parts of the world. This is accomplished through continuing education for healthcare professionals, access to current evidence based drug information, and providing technical leadership for regional and international cooperation.
Form 990, Part V, Line 4B
India, China, Brazil
Form 990, Part VI, Section A, Line 6
The members of USP are accredited delegates representing educational institutions, professional and scientific organizations, and designated divisions of the federal government.
Form 990, Part VI, Section A, Line 7A and 7b
The members of USP elect the members of the board of trustees.
Form 990, Part VI, Section B, Line 11A
The draft form 990 was reviewed by our Chief Operating officer for accuracy. Once approved by the Chief Operating Officer, the form 990 was provided to our Audit committee for review and approval. A copy of the form 990 was also provided to the board.
Form 990, Part VI, Section B, Line 12C
USP's conflict of interest policy is reflected in its bylaws and in its code of ethics. This policy is implemented with respect to our employees and volunteers (members of the board of trustees and the council of experts and expert committees, USP's standard setting bodies) through specific provisions in the employee handbook, the rules of business practice for the board of trustees, and the rules and procedures of the council of experts. All trustees, members of the council of experts and expert committees, and employees in director level or above positions or positions where they work with expert committees are required to submit and keep current a disclosure statement identifying any conflict of interest. For USP's volunteers, a conflict of interest is defined broadly under the bylaws to include a financial interest in a company or any other relationship or interest that could interfere with the individual's ability to exercise independent judgment. Trustees, experts and employees are required to recuse themselves from any matter in which they have a potential conflict, and employees may also be required to divest themselves of interests that present a potential conflict. At each meeting of the board and all expert committees, the chair reminds members of the conflict of interest rules. The identification and resolution of conflicts of interest is handled as follows for USP employees and volunteers: Employees: Disclosure statements are collected annually by the legal department from employees at the director level and above and employees who work directly with USP's expert committees. If an employee discloses that he or she has a financial interest above the specified threshold, the general counsel reviews the interest with the CEO. If the CEO determines that the interest is an isolated one and one that would be difficult to divest (e.g., a retirement plan from a former employer, or a spouse's employment), the employee is allowed to retain the interest but must recuse himself/herself in any situation where there is a potential conflict. In other cases, such as where there are multiple interests above the threshold, the CEO may ask the employee to divest. Members of the Board of Trustees: Disclosure statements are collected by the secretary, and the board members have an obligation to update them as necessary to keep them current. If a board member has a potential conflict, then in accordance with the bylaws he or she must recuse himself/herself from any final deliberation and vote in the matter. Council of Experts and Expert Committee Members: Disclosure statements are collected by the executive secretariat, and members have an obligation to update them as necessary to keep them current. The chair of each expert committee, working with staff (scientific liaison/executive secretariat/secretary), has responsibility for resolving conflict issues.
Form 990, Part VI, Section B, Lines 15A & 15B
The total compensation package will be established, reviewed, and approved in a manner that qualifies for the rebuttable presumption of reasonableness and will be reviewed periodically to ensure that it continues to be aligned with USP's strategic direction and financial limits and continues to be both reasonable and competitive for an organization with the size and impact of USP. Compensation policies including salary administration and external benchmarking are reviewed by the Operations Committee. Continuity policies including employment contracts and employee retention are reviewed by the Executive Committee.
Form 990, Part VI, Section C, Line 19
USP makes these documents available to the public to the extent required by law.
Form 990, Part VII, Section B, Line 1
Independent Contractors
Name & Address Description of Services Compensation Sutherland Asbill Legal $435,881 & Brennan LLP 1275 Pennslyvania Ave., NW Washington, DC 20004 Grant Thornton LLP Audit and Tax Services $358,976 2010 Corporate Ridge McLean, VA 22102 Steptoe & Johnson LLP Legal $159,536 1330 Connecticut Ave., NW Washington, DC 20036 Wolfgang Puck Catering & Events Catering $142,732 555 Pennslyvania Ave, NW Washington, DC 20001 Harles E Cone Management Consulting $132,330 201 Parkridge Ave. Chapel Hill, NC 27517
Form 990, Part XI, Line 5
Other Changes in Net Assets or Fund Balances: Holding Companies Net Assets 1,036,400 Unrealized Gains 5,569,048 Unrealized Losses (195,201) Prior Period Adjustment 107,794 ----------- $ 6,608,041
Form 990, Part XII, Line 2B
The financial statements of the organization were audited by independent accountants and a consolidated report was prepared in accordance with US GAAP.
For Paperwork Reduction Act Notice, see the Instructions for Form 990 or 990-EZ.