Attach to Form 990 or 990-EZ.
Information about Schedule O (Form 990 or 990-EZ) and its instructions is at| Return Reference | Explanation |
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| Form 990, Part VI, Section A, line 3 | Pursuant to the Plan and Trust Agreement, the employers who have adopted the Plan and become settlors of the Trust have delegated management responsibility over the administration and oversight of the Plan and Trust to the Sponsor and Administrator (HRA Administrator, LLC) and to the corporate trustee (Washington Trust Bank). Pursuant to the Trust Agreement and a trust services agreement between the corporate trustee and the Administrator (on behalf of the Plan), the corporate trustee executes certain directives of the Sponsor and Administrator of the Plan and provides basic investment management services. The Trust has established a Conflicts Committee and an Ethics Committee with the authority to act on behalf of the governing body. To ensure the Trust operates in a manner consistent with its tax-exempt purposes and does not engage in activities that could jeopardize its tax-exempt status, the committees conducts periodic reviews. The periodic reviews include, at a minimum, the following subjects: Whether the contractual arrangements with service providers and the services provided are reasonable, based on competent market and survey information, and the result of arm's length negotiation. Whether contractual arrangements with service providers and arrangements with other organizations conform to written policies, are properly recorded, reflect reasonable investment or payments for goods and services, further tax-exempt purposes, and do not result in inurement, impermissible private benefit or in an excess benefit transaction. Whether any transaction conducted by the Trust during the review period involves or could possibly give rise to a conflict of interest. |
| Form 990, Part VI, Section A, line 7a | Pursuant to the Plan and Trust Agreement, the employers who have adopted the Plan and become settlors of the Trust have delegated management responsibility over the administration and oversight of the Plan and Trust to the Sponsor and Administrator (HRA Administrator, LLC) and to the corporate trustee (Washington Trust Bank). Pursuant to the Trust Agreement and a trust services agreement between the corporate trustee and the Administrator (on behalf of the Plan), the corporate trustee executes certain directives of the Sponsor and Administrator of the Plan and provides basic investment management services. The Adoption Agreement executed by each adopting employer identifies one Employee Representative (one voting member) for each employee group. Each Employee Representative is independent. The Employee Representatives have the authority to act on behalf of the membership with respect to removal and replacement of the Trustee and Sponsor. Pursuant to the Plan and Trust Agreement, a majority of Employee Representatives, acting on behalf of the participants of the Plan, have the authority to remove the corporate trustee and/or veto the removal or appointment of any replacement trustee by the Sponsor, and to veto the recommendation of a replacement Sponsor should a vacancy occur in the Sponsor of the Plan. |
| Form 990, Part VI, Section A, line 7b | Pursuant to the Plan and Trust Agreement, the employers who have adopted the Plan and become settlors of the Trust have delegated management responsibility over the administration and oversight of the Plan and Trust to the Sponsor and Administrator (HRA Administrator, LLC) and to the corporate trustee (Washington Trust Bank). Pursuant to the Trust Agreement and a trust services agreement between the corporate trustee and the Administrator (on behalf of the Plan), the corporate trustee executes certain directives of the Sponsor and Administrator of the Plan and provides basic investment management services. The Adoption Agreement executed by each adopting employer identifies one Employee Representative (one voting member) for each employee group. Each Employee Representative is independent. The Employee Representatives have the authority to act on behalf of the membership with respect to removal and replacement of the Trustee and Sponsor. Pursuant to the Plan and Trust Agreement, a majority of Employee Representatives, acting on behalf of the participants of the Plan, have the authority to remove the corporate trustee and/or veto the removal or appointment of any replacement trustee by the Sponsor, and to veto the recommendation of a replacement Sponsor should a vacancy occur in the Sponsor of the Plan. |
| Form 990, Part VI, Section A, line 8a | The Trust holds the assets of the State of Indiana Health Reimbursement Arrangement "HRA" Account Plan (the Plan) for employees of school corporations and governmental employers within the State of Indiana. Pursuant to the Plan and Trust Agreement, the employers who have adopted the Plan and become settlors of the Trust have delegated management responsibility over the administration and oversight of the Plan and Trust to the Sponsor and Administrator (HRA Administrator, LLC) and to the corporate trustee (Washington Trust Bank). Pursuant to the Trust Agreement and a trust services agreement between the corporate trustee and the Administrator (on behalf of the Plan), the corporate trustee executes certain directives of the Sponsor and Administrator of the Plan and provides basic investment management services. No trustee meetings are held; however, all directives and communications between the trustee and plan sponsor are documented and retained. In addition, any changes in the administration of the Plan, or in policies or procedures of the Plan and all amendments to the Plan are communicated in writing to all participating employers and employee/members. |
| Form 990, Part VI, Section B, line 11 | The Form 990 was prepared under the guidance of the Plan Administrator (HRA Administrator, LLC) by the independent accounting firm SCHOEDEL & SCHOEDEL, Certified Public Accountants, PLLC. Draft copies of the Trust's financial statements and Form 990 were first provided to the Trust's Plan Administrator, consultants and advisors, who reviewed the Form 990 for accuracy and completeness. Any questions, concerns or issues raised by the Plan Administrator, consultants and advisors were addressed and any necessary revisions were made to the Form 990. The final version of the Form 990 was provided to the corporate trustee for final review, approval and filing. |
| Form 990, Part VI, Section B, line 12c | In addition to the delegation of management and oversight to the Trustee and the Sponsor/Administrator, as described in the explanation for Part VI, Section A, line 1 of Form 990, the Trust has established a Conflicts Policy and a Conflicts Committee. An interested party is under a continuing obligation to disclose any potential conflict of interest to the Conflicts Committee as soon as it is known or reasonably should be known. In addition, if any member of the Conflicts Committee has reasonable cause to believe an individual has failed to disclose an actual or possible conflict of interest, they will inform the interested person of the basis for such belief and afford the interested person an opportunity to explain the alleged failure to disclose. In summary, the interested person is given the opportunity to disclose all material facts to the Conflicts Committee when considering the proposed transaction or arrangement. Based on all material facts, the Conflicts Committee conducts a hearing to determine if a conflict of interest exists and what, if any, actions are required to eliminate or mitigate the conflict of interest. To ensure the Trust operates in a manner consistent with its tax-exempt purposes and does not engage in activities that could jeopardize its tax-exempt status, the Conflicts Committee conducts periodic reviews. The periodic reviews include, at a minimum, the following subjects: Whether the contractual arrangements with service providers and the services provided are reasonable, based on competent market and survey information, and the result of arm's length negotiation. Whether contractual arrangements with service providers and arrangements with other organizations conform to written policies, are properly recorded, reflect reasonable investment or payments for goods and services, further tax-exempt purposes, and do not result in inurement, impermissible private benefit or in an excess benefit transaction. Whether any transaction conducted by the Trust during the review period involves or could possibly give rise to a conflict of interest. Form 990, Part VI, Section B, Line 15: The governance structure of the Plan and Trust does not include a CEO, Executive Director, top management official, or other key employee. However, the Conflicts Committee periodically reviews all contractual arrangements with service providers to the Plan and Trust to determine whether compensation and services provided are reasonable based upon competent market and survey information. |
| Form 990, Part VI, Section C, line 19 | The Trust's governing documents, conflict of interest policy, other policies and procedures, and financial statements are available to all adopting employers and employee/participants of the Plan upon written request by contacting the Trust at 906 West 2nd Avenue, Suite 400; Spokane, WA 99201. |
| Form 990, Part VI, Section A, line 1: | Pursuant to the Plan and Trust Agreement, the employers who have adopted the Plan and become settlors of the Trust have established the Plan and Trust in order to provide benefits and payments consisting of "life, sick, accident, or other welfare benefits", as that phrase is defined by Section 501(c)(9) of the Internal Revenue Code. Pursuant to the Plan and the Trust Agreement, participation in the Plan and Trust consists of individuals (i) who become entitled to participate by reason of current or former employment with one of the adopting employers, (ii)for whom a contribution has been made by the employer, (iii) who have otherwise also met all eligibility requirements, and (iv) who have negotiated for the right to participate in the plan pursuant to a collective bargaining agreement. Pursuant to the Plan and Trust Agreement, the employers who have adopted the Plan and become settlors of the Trust have delegated management responsibility over the administration and oversight of the Plan and Trust to the Sponsor and Administrator (HRA Administrator, LLC) and to the corporate trustee (Washington Trust Bank). Pursuant to the Trust Agreement and a trust services agreement between the corporate trustee and the Administrator (on behalf of the Plan), the corporate trustee executes certain directives of the Sponsor and Administrator of the Plan and provides basic investment management services. The Adoption Agreement executed by each adopting employer identifies one Employee Representative (one voting member) for each employee group. Each Employee Representative is independent. The Employee Representatives have the authority to act on behalf of the membership with respect to removal and replacement of the Trustee and Sponsor. Pursuant to the Plan and Trust Agreement, a majority of Employee Representatives, acting on behalf of the participants of the Plan, have the authority to remove the corporate trustee and/or veto the removal or appointment of any replacement trustee by the Sponsor, and to veto the recommendation of a replacement Sponsor should a vacancy occur in the Sponsor of the Plan. |
| Part VI, Section A, line 6: | Pursuant to the Plan and Trust Agreement, the Employers who have adopted the Plan and become settlors of the Trust have established the Plan and Trust in order to provide benefits and payments consisting of "life, sick, accident, or other welfare benefits", as that phrase is defined by Section 501(c)(9) of the Internal Revenue Code. Pursuant to the Plan and the Trust Agreement, membership in the Plan and Trust consists of individuals (i) who become entitled to participate by reason of current or former employment with one of the adopting employers, (ii) for whom a contribution has been made by the employer, (iii) who have otherwise also met all eligibility requirements, and (iv) who have negotiated for the right to participate in the plan pursuant to a collective bargaining agreement. |
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