Attach to Form 990 or Form 990-EZ.
Go to
www.irs.gov/Form990 for the latest information.
| (i) Name of supported organization | (ii) EIN | (iii) Type of organization (described on lines 1- 10 above (see instructions)) | (iv) Is the organization listed in your governing document? | (v) Amount of monetary support (see instructions) | (vi) Amount of other support (see instructions) | |
|---|---|---|---|---|---|---|
| Yes | No | |||||
| (A)
MOUNT AUBURN HOSPITAL |
042103606 | 3 | No | 99,428,719 | 0 | |
|
Total 1
|
99,428,719 | 0 | ||||
Calendar year (or fiscal year beginning in) ![]() |
(a) 2014 | (b) 2015 | (c) 2016 | (d) 2017 | (e) 2018 | (f) Total | |
|---|---|---|---|---|---|---|---|
| 1 | Gifts, grants, contributions, and membership fees received. (Do not include any "unusual grant.") .. | ||||||
| 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. | ||||||
Calendar year
(or fiscal year beginning in) ![]() |
(a) 2014 | (b) 2015 | (c) 2016 | (d) 2017 | (e) 2018 | (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. Do not include gain or loss from the sale of capital assets (Explain in Part VI.).. | ||||||
| 11 | Total support. Add lines 7 through 10 | ||||||
Calendar year (or fiscal year beginning in) ![]() |
(a) 2014 | (b) 2015 | (c) 2016 | (d) 2017 | (e) 2018 | (f) Total | |
|---|---|---|---|---|---|---|---|
| 1 | Gifts, grants, contributions, and membership fees received. (Do not include any "unusual grants.") . | ||||||
| 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 | ||||||
| 3 | Gross receipts from activities that are not an unrelated trade or business under section 513 ..... | ||||||
| 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 | ||||||
| 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.) | ||||||
Calendar year (or fiscal year beginning in) ![]() |
(a) 2014 | (b) 2015 | (c) 2016 | (d) 2017 | (e) 2018 | (f) Total | |
|---|---|---|---|---|---|---|---|
| 9 | Amounts from line 6... | ||||||
| 10a | Gross income from interest, dividends, payments received on securities loans, rents, royalties and income from similar sources.. | ||||||
| b | Unrelated business taxable income (less section 511 taxes) from businesses acquired after June 30, 1975. | ||||||
| c | Add lines 10a and 10b. | ||||||
| 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 VI.) .. | ||||||
| 13 | Total support. (Add lines 9, 10c, 11, and 12.).. | ||||||
| Section A - Adjusted Net Income | (A) Prior Year |
(B) Current Year (optional) |
||||
| 1 | Net short-term capital gain | 1 | ||||
| 2 | Recoveries of prior-year distributions | 2 | ||||
| 3 | Other gross income (see instructions) | 3 | ||||
| 4 | Add lines 1 through 3 | 4 | ||||
| 5 | Depreciation and depletion | 5 | ||||
| 6 | Portion of operating expenses paid or incurred for production or collection of gross income or for management, conservation, or maintenance of property held for production of income (see instructions) | 6 | ||||
| 7 | Other expenses (see instructions) | 7 | ||||
| 8 | Adjusted Net Income (subtract lines 5, 6 and 7 from line 4) | 8 | ||||
| Section B - Minimum Asset Amount | (A) Prior Year |
(B) Current Year (optional) |
||||
| 1 | Aggregate fair market value of all non-exempt-use assets (see instructions for short tax year or assets held for part of year): | 1 | ||||
| a | Average monthly value of securities | 1a | ||||
| b | Average monthly cash balances | 1b | ||||
| c | Fair market value of other non-exempt-use assets | 1c | ||||
| d | Total (add lines 1a, 1b, and 1c) | 1d | ||||
| e |
Discount claimed for blockage or other factors (explain in detail in Part VI): |
|||||
| 2 | Acquisition indebtedness applicable to non-exempt use assets | 2 | ||||
| 3 | Subtract line 2 from line 1d | 3 | ||||
| 4 | Cash deemed held for exempt use. Enter 1-1/2% of line 3 (for greater amount, see instructions). | 4 | ||||
| 5 | Net value of non-exempt-use assets (subtract line 4 from line 3) | 5 | ||||
| 6 | Multiply line 5 by .035 | 6 | ||||
| 7 | Recoveries of prior-year distributions | 7 | ||||
| 8 | Minimum Asset Amount (add line 7 to line 6) | 8 | ||||
| Section C - Distributable Amount | Current Year | |||||
| 1 | Adjusted net income for prior year (from Section A, line 8, Column A) | 1 | ||||
| 2 | Enter 85% of line 1 | 2 | ||||
| 3 | Minimum asset amount for prior year (from Section B, line 8, Column A) | 3 | ||||
| 4 | Enter greater of line 2 or line 3 | 4 | ||||
| 5 | Income tax imposed in prior year | 5 | ||||
| 6 | Distributable Amount. Subtract line 5 from line 4, unless subject to emergency temporary reduction (see instructions) | 6 | ||||
| Section D - Distributions | Current Year | |
|---|---|---|
| 1 Amounts paid to supported organizations to accomplish exempt purposes | ||
|
2
Amounts paid to perform activity that directly furthers exempt purposes of supported organizations, in excess of income from activity |
||
| 3 Administrative expenses paid to accomplish exempt purposes of supported organizations | ||
| 4 Amounts paid to acquire exempt-use assets | ||
| 5 Qualified set-aside amounts (prior IRS approval required) | ||
| 6 Other distributions (describe in Part VI). See instructions | ||
| 7Total annual distributions. Add lines 1 through 6. | ||
|
8
Distributions to attentive supported organizations to which the organization is responsive (provide details in Part VI). See instructions |
||
| 9 Distributable amount for 2018 from Section C, line 6 | ||
| 10 Line 8 amount divided by Line 9 amount | ||
| Section E - Distribution Allocations (see instructions) |
(i) Excess Distributions |
(ii) Underdistributions Pre-2018 |
(iii) Distributable Amount for 2018 |
|
|---|---|---|---|---|
|
1
Distributable amount for 2018 from Section C, line 6 |
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|
2
Underdistributions, if any, for years prior to 2018 (reasonable cause required-- explain in Part VI). See instructions. |
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| 3 Excess distributions carryover, if any, to 2018: | ||||
| a From 2013....... | ||||
| b From 2014....... | ||||
| c From 2015....... | ||||
| d From 2016....... | ||||
| e From 2017....... | ||||
| fTotal of lines 3a through e | ||||
| g Applied to underdistributions of prior years | ||||
| h Applied to 2018 distributable amount | ||||
|
i
Carryover from 2013 not applied (see instructions) |
||||
| j Remainder. Subtract lines 3g, 3h, and 3i from 3f. | ||||
| 4Distributions for 2018 from Section D, line 7: | ||||
| $ | ||||
| a Applied to underdistributions of prior years | ||||
| b Applied to 2018 distributable amount | ||||
| c Remainder. Subtract lines 4a and 4b from 4. | ||||
|
5
Remaining underdistributions for years prior to 2018, if any. Subtract lines 3g and 4a from line 2. If the amount is greater than zero, explain in Part VI. See instructions. |
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|
6
Remaining underdistributions for 2018. Subtract lines 3h and 4b from line 1. If the amount is greater than zero, explain in Part VI. See instructions. |
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|
7 Excess distributions carryover to 2019. Add lines 3j and 4c. |
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| 8 Breakdown of line 7: | ||||
| a Excess from 2014...... | ||||
| b Excess from 2015..... | ||||
| c Excess from 2016..... | ||||
| d Excess from 2017..... | ||||
| e Excess from 2018..... | ||||
| Facts And Circumstances Test |
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| Return Reference | Explanation |
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| Software ID: | |
| Software Version: |
Attach to Form 990 or 990-EZ.
Go to www.irs.gov/Form990 for the latest information.
| Return Reference | Explanation |
|---|---|
| PART 1, LINE 1 & PART III, LINE 1 | ORGANIZATION'S MISSION: MOUNT AUBURN PROFESSIONAL SERVICES (MAPS) IS A PHYSICIAN GROUP PRACTICE PROVIDING PATIENT CARE AND TEACHING SERVICES IN THE AREAS OF PRIMARY CARE, OBSTETRICS/GYNECOLOGY, EMERGENCY MEDICINE AND OTHER SPECIALTIES IMPROVING THE HEALTH ITS PATIENTS AND THE PATIENTS OF ITS SOLE MEMBER, MOUNT AUBURN HOSPITAL AND IMPROVING THE HEALTH OF THE COMMUNITIES SERVED. ON MARCH 1, 2019, THE CAREGROUP SYSTEM OF AFFILIATES INCLUDING MOUNT AUBURN HOSPITAL, BETH ISRAEL DEACONESS MEDICAL CENTER, BETH ISRAEL DEACONESS MILTON, BETH ISRAEL DEACONESS NEEDHAM AND BETH ISRAEL DEACONESS PLYMOUTH AND NEW ENGLAND BAPTIST HOSPITAL, THE LAHEY HEALTH SYSTEM INCLUDING THE LAHEY CLINIC AND LAHEY CLINIC HOSPITAL D/B/A LAHEY HOSPITAL AND MEDICAL CENTER, WINCHESTER HOSPITAL, NORTHEAST HOSPITAL CORPORATION D/B/A BEVERLY HOSPITAL, ADDISON GILBERT HOSPITAL AND BAYRIDGE HOSPITAL, ANNA JAQUES HOSPITAL AS WELL AS ENTITIES FOR WHICH THESE LISTED ORGANIZATIONS SERVE AS SOLE MEMBER AND ADDITIONAL AFFILIATES CAME TOGETHER TO FORM BETH ISRAEL LAHEY HEALTH (BILH). PRIOR TO MARCH 1, 2019, THE MOUNT AUBURN HOSPITAL, MOUNT AUBURN PROFESSIONAL SERVICES AND CAREGROUP PARMENTER HOME CARE AND HOSPICE WERE ALL PART OF THE CAREGROUP SYSTEM. BILH IS AN INTEGRATED HEALTH CARE SYSTEM COMMITTED TO EXPANDING ACCESS TO EXTRAORDINARY PATIENT CARE ACROSS EASTERN MASSACHUSETTS AND ADVANCING THE SCIENCE AND PRACTICE OF MEDICINE THROUGH GROUNDBREAKING RESEARCH AND EDUCATION. THE BILH SYSTEM IS COMPRISED OF ACADEMIC AND TEACHING HOSPITALS, A PREMIER ORTHOPEDICS HOSPITAL, PRIMARY CARE AND SPECIALTY CARE PROVIDERS, AMBULATORY SURGERY CENTERS, URGENT CARE CENTERS, COMMUNITY HOSPITALS, HOMECARE SERVICES, OUTPATIENT BEHAVIORAL HEALTH CENTERS AND ADDICTION TREATMENT PROGRAMS. BILH'S COMMUNITY OF CLINICIANS, CAREGIVERS AND STAFF INCLUDES APPROXIMATELY 4,000 PHYSICIANS AND 35,000 EMPLOYEES. |
| PART III, LINE 4A - PRIMARY CARE | AS A SUPPORT ORGANIZATION TO MOUNT AUBURN HOSPITAL (MAH OR HOSPITAL), A HOSPITAL EXEMPT FROM INCOME TAX UNDER SECTION 501(C)(3) OF THE INTERNAL REVENUE CODE (IRC) OF 1986 AS AMENDED, DURING THE FISCAL PERIOD COVERED BY THIS RETURN, MOUNT AUBURN PROFESSIONAL SERVICES (MAPS) PROVIDED DIRECT PATIENT CARE SERVICES THROUGH MORE THAN 203,000 PATIENT ENCOUNTERS WITH A VARIETY OF MEDICAL ISSUES IN THE AREA OF PRIMARY CARE. IN ADDITION, MAPS PROVIDED APPROXIMATELY $22,000 OF FREE PRIMARY CARE TO PATIENTS IN NEED, WHICH IS IN DIRECT FURTHERANCE OF MAPS' EXEMPT PURPOSE OF FURTHERING THE EXEMPT FUNCTIONS OF MAH. MAPS ALSO PROVIDED SUPPORT TO THE MEDICAL EDUCATION AND CLINICAL PROGRAMS OF MAH WHICH IS IN DIRECT FURTHERANCE OF ITS SUPPORT OF MAH'S EXEMPT FUNCTION. |
| FORM 990, PART III, LINE 4B - SPECIALTY CARE | AS A SUPPORT ORGANIZATION TO MOUNT AUBURN HOSPITAL (MAH OR HOSPITAL), A HOSPITAL EXEMPT FROM INCOME TAX UNDER SECTION 501(C)(3) OF THE INTERNAL REVENUE CODE (IRC) OF 1986 AS AMENDED, DURING THE FISCAL PERIOD COVERED BY THIS RETURN, MOUNT AUBURN PROFESSIONAL SERVICES (MAPS) PROVIDED DIRECT PATIENT CARE SERVICES THROUGH MORE THAN 118,000 PATIENT ENCOUNTERS IN VARIOUS SPECIALTY AREAS INCLUDING EMERGENCY MEDICINE, VASCULAR MEDICINE, NEUROLOGY, RHEUMATOLOGY AND CARDIAC SURGERY. IN ADDITION, MAPS PROVIDED APPROXIMATELY $99,000 OF FREE SPECIALTY CARE TO PATIENTS IN NEED, ALL OF WHICH IS IN DIRECT FURTHERANCE OF MAPS' EXEMPT PURPOSE OF FURTHERING THE EXEMPT FUNCTIONS OF MAH. MAPS ALSO PROVIDED SUPPORT TO THE MEDICAL EDUCATION AND CLINICAL PROGRAMS OF MAH WHICH IS IN DIRECT FURTHERANCE OF ITS SUPPORT OF MAH'S EXEMPT FUNCTION. |
| FORM 990, PART III, LINE 4C - OBSTETRICS AND GYNECOLOGY | AS A SUPPORT ORGANIZATION TO MOUNT AUBURN HOSPITAL (MAH OR HOSPITAL), A HOSPITAL EXEMPT FROM INCOME TAX UNDER SECTION 501(C)(3) OF THE INTERNAL REVENUE CODE (IRC) OF 1986 AS AMENDED, DURING THE FISCAL PERIOD COVERED BY THIS RETURN, MOUNT AUBURN PROFESSIONAL SERVICES (MAPS) PROVIDED DIRECT PATIENT CARE SERVICES THROUGH APPROXIMATELY 49,000 PATIENT ENCOUNTERS IN THE AREA OF OBSTETRICS/GYNECOLOGY. IN ADDITION, MAPS PROVIDED APPROXIMATELY $26,000 OF FREE OBSTETRICS/GYNECOLOGY CARE TO PATIENTS IN NEED, WHICH IS IN DIRECT FURTHERANCE OF MAPS' EXEMPT PURPOSE OF FURTHERING THE EXEMPT FUNCTIONS OF MAH. MAPS ALSO PROVIDED SUPPORT TO THE MEDICAL EDUCATION AND CLINICAL PROGRAMS OF MAH WHICH IS IN DIRECT FURTHERANCE OF ITS SUPPORT OF MAH'S EXEMPT FUNCTION. |
| FORM 990, PART IV, QUESTION 12A | AUDITED FINANCIAL STATEMENTS THE BOSTON, MA OFFICE OF KPMG ISSUED AN UNQUALIFIED OPINION ON THE CONSOLIDATED AUDITED FINANCIAL STATEMENTS OF THE BETH ISRAEL LAHEY HEALTH, INC. AND AFFILIATES FOR FISCAL PERIOD ENDED SEPTEMBER 30, 2019. THESE STATEMENTS WERE PREPARED IN ACCORDANCE WITH GENERALLY ACCEPTED ACCOUNTING PRINCIPLES (GAAP) AND INCLUDED THE ACCOUNTS OF THE BETH ISRAEL LAHEY HEALTH, INC. (BILH), AND THE ENTITIES FOR WHICH BETH ISRAEL LAHEY HEALTH, INC. (BILH) SERVED AS SOLE MEMBER DURING THE FISCAL PERIOD COVERED BY THIS FILING, (BETH ISRAEL DEACONESS MEDICAL CENTER (BIDMC), MOUNT AUBURN HOSPITAL (MAH), NEW ENGLAND BAPTIST HOSPITAL (NEBH), BETH ISRAEL DEACONESS HOSPITAL MILTON, INC. (MILTON), BETH ISRAEL DEACONESS HOSPITAL NEEDHAM, INC. (NEEDHAM), BETH ISRAEL DEACONESS HOSPITAL PLYMOUTH, INC. (PLYMOUTH), LAHEY CLINIC FOUNDATION, LAHEY HEALTH SHARED SERVICES, WINCHESTER HOSPITAL (WINCHESTER), NORTHEAST HOSPITAL CORPORATION (NHC), NORTHEAST BEHAVIORAL HEALTH CORPORATION (NBHC) AND ANNA JAQUES HOSPITAL). EACH OF THESE AFFILIATES MAY IN TURN SERVE AS MEMBER OF ADDITIONAL ENTITIES WITHIN THE NETWORK OF AFFILIATES, AND WHOSE ACCOUNTS ARE INCLUDED IN THE BILH AUDITED FINANCIAL STATEMENTS. THE FINANCIAL STATEMENTS ALSO INCLUDE THE ACCOUNTS OF HARVARD MEDICAL FACULTY PHYSICIANS AT BETH ISRAEL DEACONESS MEDICAL CENTER, INC. (HMFP), THE DEDICATED PHYSICIAN PRACTICE OF BETH ISRAEL DEACONESS MEDICAL CENTER AND AN ENTITY INTEGRALLY RELATED TO HELPING BIDMC ACCOMPLISH ITS CHARITABLE PURPOSES, AS WELL AS ALL ENTITIES FOR WHICH THESE ENTITIES SERVE AS MEMBER. |
| FORM 990, PART IV, LINE 24A | TAX-EXEMPT DEBT AS DESCRIBED IN THIS FORM 990, FOR THE PERIOD COVERED BY THIS FILING, BETH ISRAEL LAHEY HEALTH, INC. WAS AN ENTITY EXEMPT FROM INCOME TAX UNDER SECTION 501(C)(3) OF THE INTERNAL REVENUE CODE OF 1986, AS AMENDED AND SERVED AS A SUPPORT ORGANIZATION OF AND SOLE MEMBER OF MOUNT AUBURN PROFESSIONAL SERVICES. DURING THIS SAME PERIOD MOUNT AUBURN PROFESSIONAL SERVICES WAS A MEMBER OF THE BETH ISRAEL LAHEY HEALTH, INC. OBLIGATED GROUP AND ITS TAX EXEMPT BOND FINANCING WASS ISSUED THROUGH BETH ISRAEL LAHEY HEALTH, INC. THE SCHEDULE K AS INCLUDED IN THIS FORM 990 INCLUDES ALL OF THE BETH ISRAEL LAHEY HEALTH, INC. OBLIGATED GROUP OUTSTANDING DEBT FOR BONDS ISSUED AFTER DECEMBER 31, 2002 ONLY A PORTION OF WHICH IS ALLOCABLE TO AND REPORTED ON MOUNT AUBURN PROFESSIONAL SERVICES'S BALANCE SHEET. |
| FORM 990, PART IV, QUESTION 24B | INVESTMENT OF TAX-EXEMPT BOND PROCEEDS BEYOND THE TEMPORARY PERIOD EXCEPTION PROCEEDS IN THE PROJECT FUND WERE UNEXPECTEDLY HELD BEYOND THE THREE-YEAR TEMPORARY PERIOD, BUT WERE YIELD RESTRICTED IN COMPLIANCE WITH FEDERAL TAX REQUIREMENTS. |
| PART V, QUESTION 7G | CONTRIBUTIONS OF INTELLECTUAL PROPERTY MOUNT AUBURN PROFESSIONAL SERVICES DID NOT RECEIVE ANY CONTRIBUTIONS OF INTELLECTUAL PROPERTY AND AS SUCH, WAS NOT REQUIRED TO FILE FORM 8899. |
| PART V QUESTION 7H | CONTRIBUTIONS OF CARS, BOATS, AIRPLANES AND OTHER VEHICLES MOUNT AUBURN PROFESSIONAL SERVICES DID NOT RECEIVE ANY CONTRIBUTIONS OF CARS, BOATS, AIRPLANES OR OTHER VEHICLES AND AS SUCH, WAS NOT REQUIRED TO FILE FORM 1098-C. |
| FORM 990, PART VI, SECTION A, LINE 2 | FOR THE PERIOD COVERED BY THIS FILING, BETH ISRAEL LAHEY HEALTH, INC. SERVED AS THE SOLE MEMBER OF BETH ISRAEL DEACONESS MEDICAL CENTER, INC. (BIDMC), MOUNT AUBURN HOSPITAL (MAH), NEW ENGLAND BAPTIST HOSPITAL (NEBH), BETH ISRAEL DEACONESS HOSPITAL MILTON, INC. (MILTON), BETH ISRAEL DEACONESS HOSPITAL NEEDHAM, INC. (NEEDHAM), BETH ISRAEL DEACONESS HOSPITAL PLYMOUTH, INC. (PLYMOUTH), LAHEY HEALTH SHARED SERVICES, LAHEY CLINIC FOUNDATION, WINCHESTER HOSPITAL (WINCHESTER), NORTHEAST HOSPITAL CORPORATION (NHC), NORTHEAST BEHAVIORAL CORPORATION (NBC), AND ANNA JAQUES HOSPITAL. THE LAHEY CLINIC FOUNDATION IN TURN SERVES AS SOLE MEMBER TO LAHEY CLINIC INC, AND LAHEY CLINIC HOSPITAL DBA LAHEY HOSPITAL AND MEDICAL CENTER (LHMC). ADDITIONAL ENTITIES LISTED HERE MAY ALSO IN TURN SERVE AS MEMBER TO OTHER NETWORK AFFILIATES. TWO OR MORE OF THE PERSONS LISTED IN THIS FORM 990 PART VII HAVE A BUSINESS RELATIONSHIP WITH EACH OTHER BY VIRTUE OF SITTING ON ONE OR MORE BOARDS OF DIRECTORS/TRUSTEES OR BY SERVING IN AN EMPLOYMENT RELATIONSHIP WITH ONE OR MORE ENTITIES WITHIN THE NETWORK OF AFFILIATED ORGANIZATIONS. ADDITIONAL DETAIL IS PROVIDED IN THE EXPLANATORY NOTES TO THIS FORM 990 SCHEDULE J. |
| FORM 990, PART VI, SECTION A, LINE 4 | MOUNT AUBURN PROFESSIONAL SERVICES MADE CHANGES TO ITS BYLAWS DURING THE FISCAL PERIOD ENDED SEPTEMBER 30, 2019 AS PART OF THE CREATION OF THE BETH ISRAEL LAHEY HEALTH (BILH), AN INTEGRATED HEALTH CARE SYSTEM PROVIDING PATIENT CARE INFORMED BY WORLD-CLASS RESEARCH AND EDUCATION. BETH ISRAEL LAHEY HEALTH, INC. BECAME THE SOLE MEMBER OF MOUNT AUBURN PROFESSIONAL SERVICES'S MEMBER. CHANGES TO THE BYLAWS AFFECT: - FREQUENCY OF MEETINGS - MINIMUM & MAXIMUM NUMBER OF TRUSTEES - EX-OFFICIO TRUSTEES - APPOINTMENT, REAPPOINTMENT AND REMOVAL OF TRUSTEES - COMMITTEES - OFFICERS - TERMS AND TERM LIMITS |
| FORM 990, PART VI, SECTION A, LINE 6 | EXPLANATION OF CLASSES OF MEMBERS OR SHAREHOLDER MOUNT AUBURN HOSPITAL INC. (MAH) IS A REGIONAL TEACHING HOSPITAL CLOSELY AFFILIATED WITH THE HARVARD MEDICAL SCHOOL WITH A MISSION TO IMPROVE THE HEALTH OF THE RESIDENTS OF CAMBRIDGE, MASSACHUSETTS AND THE SURROUNDING COMMUNITIES. MAH IS DEDICATED TO DELIVERING HIGH QUALITY HEALTHCARE SERVICES IN A PERSONABLE, CONVENIENT, AND COMPASSIONATE MANNER, WITH RESPECT FOR THE DIGNITY OF PATIENTS AND THEIR FAMILIES. MAH IS A HOSPITAL EXEMPT FROM INCOME TAX UNDER SECTION 501(C)(3) OF THE INTERNAL REVENUE CODE (IRC) AS AMENDED, AND ACTING THROUGH ITS BOARD OF TRUSTEES, IS THE SOLE MEMBER OF MOUNT AUBURN PROFESSIONAL SERVICES. |
| FORM 990, PART VI, SECTION A, LINE 7A | THE MEMBER HAS THE AUTHORITY TO ELECT THE GOVERNING BODY. |
| FORM 990, PART VI, SECTION A, LINE 7B | THE MEMBER OF MOUNT AUBURN PROFESSIONAL SERVICES HAS THE FOLLOWING RIGHTS, AS DESIGNATED IN MOUNT AUBURN PROFESSIONAL SERVICES'S BYLAWS: - ESTABLISHMENT OR MODIFICATION OF COMPENSATION OF OR REMOVAL OF THE CHIEF EXECUTIVE OFFICER, IF ANY, OR PRESIDENT OF THE CORPORATION; - ENTERING INTO OF CONTRACTS WHICH BIND THE CORPORATION AND WHICH ARE MANAGED CARE CONTRACTS, EXCLUSIVE CONTRACTS, AGREEMENTS-NOT-TO-COMPETE OR USE SIMILAR ARRANGEMENTS, CONTRACTS FOR MANAGEMENT SERVICES OR OTHER MULTI-YEAR SERVICE CONTRACTS WITH POTENTIALLY SIGNIFICANT MULTI-YEAR BUDGETARY IMPACT; - ADOPTION OF A MISSION STATEMENT AND STRATEGIC, FINANCIAL AND OPERATIONAL PLAN FOR THE CORPORATION; - ADOPTION OF AN ANNUAL OPERATING BUDGET AND ALL CAPITAL BUDGETS; THE BORROWING OF, OR INCIDENCE OF DEBT IN, ANY AMOUNT OTHER THAN (I) FOR PURPOSE OF SECURING WORKING CAPITAL FROM A LENDER WHICH SHALL HAVE BEEN APPROVED BY THE MEMBER AND PURSUANT TO THEN EXISTING AND PROVISIONS RELATING TO SUCH BORROWING WHICH SHALL HAVE BEEN APPROVED BY THE MEMBER, AND (II) DEBT INCURRED IN THE ORDINARY COURSE OF BUSINESS WHICH IS ANTICIPATED IN AND CONSISTENT WITH THE ANNUAL OPERATING BUDGET OR A CAPITAL BUDGET WHICH SHALL HAVE BEEN APPROVED BY THE MEMBER FOR THE YEAR IN WHICH INCURRED; - ANY VOLUNTARY DISSOLUTION, MERGER OR CONSOLIDATION OF THE CORPORATION, THE SALE OR TRANSFER OF ALL OR SUBSTANTIALLY ALL OF THE CORPORATION'S ASSETS, THE CREATION, ACQUISITION OR DISPOSAL OF ANY SUBSIDIARY OR AFFILIATED CORPORATION OR THE ADDITION OR ELIMINATION OF ANY CLINICAL DEPARTMENT OR PROGRAM, WHICH DEPARTMENT OR PROGRAM COULD REASONABLY BE ANTICIPATED WOULD MATERIALLY AFFECT THE FINANCIAL STATUS OF THE CORPORATION, OR ITS ABILITY TO CONDUCT ITS BUSINESS, OR THE ENTERING INTO OF ANY JOINT VENTURE OR OTHER PARTNERSHIP ARRANGEMENTS BY THE ENTITY; AND, - INITIATION OF ANY BANKRUPTCY OR INSOLVENCY ACTION ON BEHALF OF THE CORPORATION OR ANY SUBSIDIARY THEREOF. |
| FORM 990, PART VI, SECTION B, LINE 11B | AS NOTED IN VARIOUS DISCLOSURES THROUGHOUT THIS FILING, EFFECTIVE MARCH 1, 2019, BETH ISRAEL LAHEY HEALTH, INC. (BILH) BECAME THE SOLE MEMBER OF MOUNT AUBURN HOSPITAL, WHICH IS AN AFFILIATE OF MOUNT AUBURN PROFESSIONAL SERVICES. THIS FORM 990 IS REVIEWED BY THE CHIEF FINANCIAL OFFICER OF MOUNT AUBURN HOSPITAL, THE TAX DIRECTOR OF BILH AND DELOITTE TAX, LLP. A COPY OF THE COMPLETE RETURN IS THEN PROVIDED TO EACH MEMBER OF THE MOUNT AUBURN PROFESSIONAL SERVICES BOARD PRIOR TO SUBMISSION TO THE INTERNAL REVENUE SERVICE. |
| FORM 990, PART VI, SECTION B, LINE 12C | MOUNT AUBURN HOSPITAL (MAH) MAINTAINS A COMPREHENSIVE CONFLICT OF INTEREST POLICY APPLICABLE TO MAH, MOUNT AUBURN PROFESSIONAL SERVICES (MAPS) AND CAREGROUP PARMENTER HOME CARE & HOSPICE (CPHCH), FOR WHICH MAH SERVED AS SOLE MEMBER DURING THE FISCAL YEAR ENDED SEPTEMBER 30, 2019. PURSUANT TO THAT POLICY, ALL OFFICERS, TRUSTEES AND KEY EMPLOYEES OF BOTH ENTITIES ARE ASKED TO COMPLETE AN ANNUAL CONFLICT DISCLOSURE STATEMENT WHICH IS DESIGNED TO REQUIRE DISCLOSURE OF ANY BUSINESS RELATIONSHIPS MAINTAINED BY OFFICERS, TRUSTEES OR KEY EMPLOYEES AND THEIR FAMILY MEMBERS WHICH MAY RESULT IN A CONFLICT OF INTEREST. IN ADDITION, ANY INDIVIDUAL WHO COMMENCES A TERM AS AN OFFICER, DIRECTOR/TRUSTEE OR KEY EMPLOYEE IS REQUIRED TO COMPLETE THE ANNUAL CONFLICT DISCLOSURE AT THE TIME SUCH POSITION COMMENCES. FOR THE PERIOD COVERED BY THIS FILING, ALL ANNUAL DISCLOSURES WERE REVIEWED BY THE MAH OFFICE OF GENERAL COUNSEL FOR DETERMINATION OF ANY POTENTIAL OR ACTUAL CONFLICT AND ANY ACTIVITY THAT REQUIRES ACTION UNDER THE CONFLICT OF INTEREST POLICY IS SUBJECT TO ONGOING REVIEW AND ACTION THROUGH THE GENERAL COUNSEL'S OFFICE. PURSUANT TO THE CONFLICT OF INTEREST POLICY, CERTAIN ACTIVITIES WHICH COULD CREATE CONFLICTS OF INTEREST ARE PROHIBITED WHILE OTHER TYPES OF RELATIONSHIPS ARE PERMITTED, SUBJECT TO COMPLIANCE WITH A PLAN TO REQUIRE DISCLOSURE AND RECUSAL, INCLUDING APPROPRIATE DOCUMENTATION IN THE MINUTES. AS PREVIOUSLY NOTED, EFFECTIVE MARCH 1, 2019, BETH ISRAEL LAHEY HEALTH (BILH) BECAME THE SOLE MEMBER OF MAH. IN ADDITION TO THE CONFLICT OF INTEREST PROCESS OUTLINED ABOVE, THE BILH TAX DEPARTMENT ISSUED A TAX QUESTIONNAIRE TO ALL CURRENT AND FORMER MEMBERS OF THE BOARD OF TRUSTEES AS WELL AS CURRENT AND FORMER OFFICERS AND KEY EMPLOYEES. THE TAX QUESTIONNAIRE PROCESS WAS DESIGNED TO GATHER THE INFORMATION NECESSARY FOR MAH TO COMPLETELY AND ACCURATELY PROCESS AND COMPLETE FORM 990 SCHEDULE L, TRANSACTIONS WITH INTERESTED PERSONS AND FORM 990, PART VI, QUESTION 2, FAMILY AND BUSINESS RELATIONSHIPS BETWEEN OFFICERS, DIRECTORS/TRUSTEES AND KEY EMPLOYEES. |
| FORM 990, PART VI, SECTION B, LINE 15B | AS NOTED THROUGHOUT THIS FILING, MOUNT AUBURN HOSPITAL, MOUNT AUBURN PROFESSIONAL SERVICES AND CAREGROUP PARMENTER HOME CARE AND HOSPICE (MAH, MAPS AND CPHCH RESPECTIVELY) BECAME MEMBERS OF THE BETH ISRAEL LAHEY HEALTH NETWORK OF AFFILIATES WITH BILH SERVING AS MAH'S SOLE MEMBER EFFECTIVE MARCH 1, 2019. MAH CONTINUED TO SERVE AS THE SOLE MEMBER OF BOTH MAPS AND CPHCH FOR THE REMAINDER OF THE PERIOD COVERED BY THIS FILING. PRIOR TO MARCH 1, 2019 MAH MAINTAINED A COMPENSATION COMMITTEE (THE "COMMITTEE") COMPRISED OF MEMBERS OF THE HOSPITAL'S BOARD OF TRUSTEES. MAH'S THEN CEO ALSO ATTENDED COMMITTEE MEETINGS, OTHER THAN WITH RESPECT TO THE CEO'S COMPENSATION, WITHOUT VOTING RIGHTS. ALL OTHER MEMBERS OF THE COMMITTEE WERE INDEPENDENT. AS REQUIRED BY THIS FORM 990 FOR THE FISCAL YEAR ENDED SEPTEMBER 30, 2019, COMPENSATION REPORTED HEREIN IS CALENDAR YEAR 2018 COMPENSATION. AS SUCH, COMPENSATION REPORTED IN THIS FORM 990 FOR MAH, MAPS AND CPHCH OFFICERS, TRUSTEES AND KEY EMPLOYEES WAS SET BY THE MAH COMPENSATION COMMITTEE AND GUIDED BY THE COMMITTEE'S OBLIGATIONS AS OUTLINED BELOW. THE COMMITTEE OPERATED TO FULFILL THE FOLLOWING RESPONSIBILITIES: - TO REVIEW AND APPROVE THE TOTAL COMPENSATION OF EACH MEMBER OF THE HOSPITAL'S SENIOR MANAGEMENT TEAM SO AS TO ENSURE THAT SUCH COMPENSATION REMAINS COMPETITIVE IN THE MARKETPLACE, REPRESENTS GOOD VALUE TO THE HOSPITAL FOR THE QUALITY AND QUANTITY OF SERVICES PROVIDED AND CONSTITUTES REASONABLE TOTAL COMPENSATION TO THE EMPLOYEE IN LIGHT OF THE EMPLOYEE'S POSITION, RESPONSIBILITIES, QUALIFICATIONS AND PERFORMANCE IN ACCORDANCE WITH INTERNAL AND EXTERNAL REASONABLE COMPENSATION STANDARDS APPLICABLE TO THIS TAX EXEMPT HOSPITAL; - TO RECOMMEND TO THE BOARD OF TRUSTEES THE TERMS AND CONDITIONS OF ANY EMPLOYMENT AGREEMENTS BETWEEN THE HOSPITAL AND ITS PRESIDENT/CHIEF EXECUTIVE OFFICER INCLUDING BASE SALARIES, INCENTIVE COMPENSATION, SUPPLEMENTAL EMPLOYEE RETIREMENT PLANS, BENEFITS AND OTHER LAWFUL METHODS OF REASONABLE COMPENSATION; - TO RECOMMEND TO THE BOARD OF TRUSTEES FOR THE BOARD'S APPROVAL THE TERMS AND CONDITIONS OF ANY SUPPLEMENTAL EMPLOYEE RETIREMENT PLANS FOR HOSPITAL EXECUTIVES; - TO REVIEW AND APPROVE THOSE PORTIONS OF THE FEDERAL FORM 990 AND THE MASSACHUSETTS FORM PC, OR THEIR EQUIVALENTS, PERTAINING TO THE COMPENSATION OF HOSPITAL EMPLOYEES PRIOR TO THE HOSPITAL'S FILING OF SUCH FORMS WITH THE REGULATORY AUTHORITIES; - AS DETERMINED TO BE ADVISABLE BY THE COMMITTEE FROM TIME TO TIME, TO ENGAGE OUTSIDE COMPENSATION CONSULTANTS AND LEGAL AND OTHER ADVISORS TO PROVIDE TO THE COMMITTEE APPROPRIATE AND RELIABLE COMPARABLE COMPENSATION DATA FOR SIMILARLY SITUATED EMPLOYEES OF NATIONAL, REGIONAL AND LOCAL PEER INSTITUTIONS AND OTHER EXPERT ADVICE TO ASSIST THE COMMITTEE IN FULFILLING ITS RESPONSIBILITIES; - TO WORK WITH THE HOSPITAL'S MANAGEMENT AND AUDITORS TO RESOLVE, OR TO RECOMMEND TO THE BOARD OF TRUSTEES RESOLUTION OF, ANY ISSUES OF CONCERN PERTAINING TO THE COMPENSATION OF HOSPITAL EMPLOYEES THAT MAY ARISE DURING THE COURSE OF THE HOSPITAL'S INDEPENDENT AUDIT OR MAY BE PRESENTED IN THE INDEPENDENT AUDITOR'S MANAGEMENT LETTER TO THE HOSPITAL; - TO REVIEW AND APPROVE EMPLOYEE BENEFITS PROGRAMS INCLUDING WELFARE, FRINGE AND RETIREMENT PLANS AND PROGRAMS, AND ANY MATERIAL AMENDMENTS THERETO; - TO ADOPT SUCH POLICIES AND PROCEDURES AS THE COMMITTEE MAY DETERMINE FROM TIME TO TIME TO BE NECESSARY OR USEFUL TO ENSURE THAT THE HOSPITAL PAYS REASONABLE AND COMPETITIVE COMPENSATION TO ITS MANAGEMENT TEAM WHILE PRESERVING THE TAX EXEMPT STATUS OF THE HOSPITAL; AND - TO REVIEW AND REASSESS THE COMMITTEE'S CHARTER FROM TIME TO TIME AND TO RECOMMEND ANY PROPOSED CHANGES TO THE HOSPITAL'S BOARD OF TRUSTEES FOR ITS CONSIDERATION AND APPROVAL. THE COMMITTEE MET PERIODICALLY DURING THE CALENDAR YEAR 2018 AND THE PORTION OF THE FISCAL YEAR PRIOR TO MARCH 1, 2019 TO REVIEW AND APPROVE INDIVIDUAL PERFORMANCE GOALS FOR MANAGEMENT AND THE CEO, TO REVIEW PERFORMANCE AGAINST SUCH GOALS, TO APPROVE INCENTIVE COMPENSATION PAYMENTS TO MANAGEMENT, TO RECOMMEND COMPENSATION PAYMENTS TO THE CEO FOR APPROVAL BY THE TRUSTEES AND TO APPROVE SALARY ADJUSTMENTS FOR THE NEXT YEAR. FURTHER, THE COMMITTEE ADDRESSED AS REQUIRED ANY CHANGES IN INDIVIDUAL OR GROUP COMPENSATION ARRANGEMENTS AT SUCH MEETINGS. THE COMMITTEE UNDERSTOOD THAT ONE OF ITS CORE RESPONSIBILITIES WAS TO ENSURE THAT THE TOTAL COMPENSATION PROVIDED TO THESE INDIVIDUALS WAS FAIR AND REASONABLE USING CURRENT AND CREDIBLE MARKET PRACTICE INFORMATION AND THAT ALL ARRANGEMENTS COMPLY WITH APPLICABLE LEGAL AND REGULATORY GUIDELINES. THE COMPENSATION COMMITTEE HISTORICALLY RELIED UPON GUIDANCE OUTLINED IN WRITTEN COMPENSATION SURVEYS/STUDIES PRODUCED UNDER AN ARRANGEMENT WITH AN INDEPENDENT COMPENSATION CONSULTING FIRM THAT ASSESSED EXECUTIVE COMPENSATION AND BENEFITS OF ORGANIZATIONS SIMILAR TO MAH. THE COMMITTEE HISTORICALLY HAD A FULL STUDY CONDUCTED BY SUCH FIRM BIENNIALLY WITH AN UPDATED STUDY IN THE OTHER YEARS. THIS SURVEY HAS FORMED THE BASIS FOR THE COMMITTEE FULFILLING ITS RESPONSIBILITY IN THIS REGARD. FOR THE PERIODS COVERED IN THIS FORM 990, THE COMMITTEE MET TO REVIEW THE COMPENSATION OF EACH OF THE INDIVIDUALS DESCRIBED ABOVE. TOOLS UTILIZED FOR THIS REVIEW INCLUDED THE COMPENSATION STUDY PREPARED BY THE INDEPENDENT COMPENSATION CONSULTING FIRM CONTRACTED BY THE COMMITTEE. FURTHER, PERFORMANCE OF EACH INDIVIDUAL WAS MEASURED AGAINST PREVIOUSLY APPROVED GOALS AND OBJECTIVES IN DETERMINING INCENTIVE COMPENSATION PAYMENTS. AFTER DISCUSSION AND ANALYSIS, THE COMPENSATION COMMITTEE VOTED TO APPROVE THE COMPENSATION ARRANGEMENTS OF ALL INDIVIDUALS DESCRIBED ABOVE EXCEPT FOR THE CEO. WHEN THE CEO WAS NOT PRESENT, THE COMPENSATION COMMITTEE DISCUSSED THE COMPENSATION OF THE CEO AND THE PERFORMANCE OF THE CEO AGAINST PREVIOUSLY APPROVED GOALS AND OBJECTIVES. WITH THE INPUT OF THE COMPENSATION STUDY, THE COMMITTEE VOTED TO RECOMMEND FOR APPROVAL BY THE BOARD OF TRUSTEES THE COMPENSATION ARRANGEMENT OF THE CEO. AT A SUBSEQUENT EXECUTIVE SESSION OF THE HOSPITAL'S BOARD OF TRUSTEES, FROM WHICH ALL TRUSTEES IN THE EMPLOY OF THE HOSPITAL WERE EXCUSED, THE CHAIR OF THE COMPENSATION COMMITTEE MADE A FULL REPORT OF THE COMMITTEE'S ANALYSIS OF CEO COMPENSATION TO THE INDEPENDENT TRUSTEES AND AFTER DISCUSSION RECOMMENDED THAT THE TRUSTEES APPROVE THE THEN CEO'S COMPENSATION. THE TRUSTEES VOTED AND APPROVED THE COMPENSATION. ALL DELIBERATIONS WERE CONTEMPORANEOUSLY DOCUMENTED IN MINUTES. THE COMPENSATION OF THE MAH CEO WAS THEN ALSO REPORTED TO THE CAREGROUP EXECUTIVE COMMITTEE. CAREGROUP SERVED AS THE SOLE MEMBER OF MAH PRIOR TO MARCH 1, 2019. |
| FORM 990, PART VI, SECTION C, LINE 19 | MOUNT AUBURN PROFESSIONAL SERVICES'S GOVERNING DOCUMENTS, CONFLICT OF INTEREST POLICY AND FINANCIAL STATEMENTS ARE AVAILABLE TO THE GENERAL PUBLIC UPON REQUEST AT THE FOLLOWING LOCATION: BETH ISRAEL LAHEY HEALTH TAX DEPARTMENT 109 BROOKLINE AVENUE, SUITE 300 BOSTON, MA 02215 |
| FORM 990, PART XI, LINE 9: | TRANSFER FROM AFFILIATES 19,313,888. ROUNDING 16. |
| PART XII QUESTION 2B AND 2C | FINANCIAL STATEMENTS AND COMMITTEE OVERSIGHT ON MARCH 1, 2019, LAHEY HEALTH SYSTEM INCLUDING THE LAHEY CLINIC AND LAHEY CLINIC HOSPITAL D/B/A LAHEY HOSPITAL AND MEDICAL CENTER, WINCHESTER HOSPITAL, NORTHEAST HOSPITAL CORPORATION D/B/A BEVERLY HOSPITAL, ADDISON GILBERT HOSPITAL AND BAYRIDGE HOSPITAL, THE BETH ISRAEL DEACONESS SYSTEM INCLUDING BETH ISRAEL DEACONESS MEDICAL CENTER, BETH ISRAEL DEACONESS MILTON, BETH ISRAEL DEACONESS NEEDHAM AND BETH ISRAEL DEACONESS PLYMOUTH, MOUNT AUBURN HOSPITAL, NEW ENGLAND BAPTIST HOSPITAL, ANNA JAQUES HOSPITAL AS WELL AS ENTITIES FOR WHICH THESE LISTED ORGANIZATIONS SERVE AS SOLE MEMBER AND ADDITIONAL AFFILIATES CAME TOGETHER TO FORM BETH ISRAEL LAHEY HEALTH (BILH). AS A NEWLY CREATED HEALTHCARE SYSTEM, BILH ENGAGED KPMG TO PERFORM A FINANCIAL AUDIT OF THE SYSTEM. THE BOSTON, MA OFFICE OF KPMG ISSUED AN UNQUALIFIED OPINION ON THE CONSOLIDATED AUDITED FINANCIAL STATEMENTS OF THE BETH ISRAEL LAHEY HEALTH, INC. AND AFFILIATES FOR FISCAL PERIOD ENDED SEPTEMBER 30, 2019. THESE STATEMENTS WERE PREPARED IN ACCORDANCE WITH GENERALLY ACCEPTED ACCOUNTING PRINCIPLES (GAAP) AND INCLUDED THE ACCOUNTS OF THE BETH ISRAEL LAHEY HEALTH, INC. AND ITS AFFILIATES. |
| SCHEDULE C: LOBBYING ACTIVITIES | MOUNT AUBURN PROFESSIONAL SERVICES DOES NOT ENGAGE IN ANY DIRECT LOBBYING EFFORTS. HOWEVER, VARIOUS AFFILIATES OF MOUNT AUBURN PROFESSIONAL SERVICES, MAY HAVE ENGAGED IN SOME LOBBYING EFFORTS ON BEHALF OF THEMSELVES AND OTHER AFFILIATED NETWORK ENTITIES. TOTAL LOBBYING EXPENDITURES WERE MINIMAL AND NOT SUBSTANTIAL BASED ON REVENUES. |
| SCHEDULE L PART IV - BUSINESS TRANSACTIONS INVOLVING INTERESTED PERSONS | VARIOUS CURRENT AND FORMER OFFICERS, DIRECTORS/TRUSTEES AND KEY EMPLOYEES OF MOUNT AUBURN PROFESSIONAL SERVICES (MAPS) MAY ALSO HOLD POSITIONS WITH OTHER ENTITIES WHICH MAKE CHARITABLE CONTRIBUTIONS TO MAPS. SUCH CONTRIBUTIONS HAVE NOT BEEN INCLUDED IN THE DISCLOSURES ABOVE. MAPS MAINTAINS AN ACCOUNTABLE BUSINESS EXPENSE REIMBURSEMENT PLAN. FROM TIME TO TIME, MAPS MAY REIMBURSE ITS OFFICERS, DIRECTORS/TRUSTEES AND/OR KEY EMPLOYEES FOR EXPENSES THEY INCURRED AND WHICH ARE PROPERLY ORDINARY AND NECESSARY BUSINESS EXPENSES OF THE REPORTING ENTITY. THE POLICIES AND PROCEDURES REQUIRED BY THE ACCOUNTABLE BUSINESS PLAN MUST BE FOLLOWED IN ORDER TO RECEIVE REIMBURSEMENT FOR SUCH EXPENSES AND IT IS POSSIBLE THAT ONE OR MORE INDIVIDUALS RECEIVED NON-TAXABLE REIMBURSEMENTS WHICH TOTALED $10,000 OR MORE DURING THE FISCAL PERIOD COVERED BY THIS FILING. ALL OF THE ABOVE TRANSACTIONS WERE AT ARMS-LENGTH AND IN ACCORDANCE WITH THE MAPS CONFLICT OF INTEREST POLICY. |
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