Attach to Form 990 or Form 990-EZ.
Go to
www.irs.gov/Form990 for instructions and 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 | |||||
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Total |
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Calendar year (or fiscal year beginning in) ![]() |
(a) 2015 | (b) 2016 | (c) 2017 | (d) 2018 | (e) 2019 | (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) 2015 | (b) 2016 | (c) 2017 | (d) 2018 | (e) 2019 | (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) 2015 | (b) 2016 | (c) 2017 | (d) 2018 | (e) 2019 | (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) 2015 | (b) 2016 | (c) 2017 | (d) 2018 | (e) 2019 | (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) |
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| 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) |
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| 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): |
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| 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 | ||
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2
Amounts paid to perform activity that directly furthers exempt purposes of supported organizations, in excess of income from activity |
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| 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. | ||
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8
Distributions to attentive supported organizations to which the organization is responsive (provide details in Part VI). See instructions |
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| 9 Distributable amount for 2019 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-2019 |
(iii) Distributable Amount for 2019 |
|
|---|---|---|---|---|
| 1 Distributable amount for 2019 from Section C, line 6 | ||||
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2
Underdistributions, if any, for years prior to 2019 (reasonable cause required-- explain in Part VI). See instructions. |
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| 3 Excess distributions carryover, if any, to 2019: | ||||
| a From 2014....... | ||||
| b From 2015....... | ||||
| c From 2016....... | ||||
| d From 2017....... | ||||
| e From 2018....... | ||||
| fTotal of lines 3a through e | ||||
| g Applied to underdistributions of prior years | ||||
| h Applied to 2019 distributable amount | ||||
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i
Carryover from 2014 not applied (see instructions) |
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| j Remainder. Subtract lines 3g, 3h, and 3i from 3f. | ||||
| 4Distributions for 2019 from Section D, line 7: | ||||
| $ | ||||
| a Applied to underdistributions of prior years | ||||
| b Applied to 2019 distributable amount | ||||
| c Remainder. Subtract lines 4a and 4b from 4. | ||||
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5
Remaining underdistributions for years prior to 2019, 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 2019. 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 2020. Add lines 3j and 4c. |
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| 8 Breakdown of line 7: | ||||
| a Excess from 2015..... | ||||
| b Excess from 2016..... | ||||
| c Excess from 2017..... | ||||
| d Excess from 2018..... | ||||
| e Excess from 2019..... | ||||
| Facts And Circumstances Test |
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| Return Reference | Explanation |
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| Software ID: | 19009920 |
| Software Version: | 2019v5.0 |
Attach to Form 990 or 990-EZ.
Go to www.irs.gov/Form990 for the latest information.
| Return Reference | Explanation |
|---|---|
| Form 990, Part III, Line 4d: Other Program Services Description | OTHER PROGRAM SERVICES 4: As part of operating an acute care hospital and providing health care services to the community, other revenue is derived in the following areas:Intercompany Revenue - consists of revenue derived from medical and administrative services provided to the Froedtert and Medical College of Wisconsin Community Physicians, Inc. (CP). Services include laboratory services, medical office building space, dietary services, and housekeeping services. All of these services support the delivery of healthcare to the community.Other Department Operating Revenue - is revenue derived from different services through the process of providing patient care and in the normal operation of a medical facility. Included in this category are items such as baby photo income, gift shop and small stones operations, medical staff application fees, hospice space, and class revenue.Dietary Services - is derived from cafeteria sales, vending machine sales, guest tray sales and employee meals. Dietary services are necessary to support services to patient families while their loved one is receiving care in the Hospital. The revenue from employee meals is a benefit provided by FWBH as an employer and it allows our staff to remain on site for patient care. Miscellaneous Revenue - is revenue derived from different services through the process of providing patient care in the normal operation of a medical facility. Included in this category are items such as recycling revenue, NSF check charges, and taxable dietary sales.Rebates and Discounts - is the result of volume purchases of patient care supplies and the result of using specific vendors or receiving a discount by paying invoices within a specific time period.Corporate Allocated Revenue - revenue passed from FH, a related party. |
| Form 990, Part VI, Line 4: Description of Significant Changes to Organizational Documents | Biannual Review of the Hospital Bylaws for St. Josephs Community Hospital of West Bend, Inc.The changes are as follows: o Section 3.3.2: Language was revised to clarify that the Health System CEO, or her designee, is to serve as an Ex Officio Director; the change was made to align with the changes to the Froedtert Health, Inc. bylaws regarding the Director Designee. o Sections 3.2, 3.3.2: The provision was revised to add the Chief Medical Officer for Froedtert & the Medical College of Wisconsin Community Physicians as an Ex Officio Director on each hospital board. |
| Form 990, Part VI, Line 6: Explanation of Classes of Members or Shareholder | FH is the sole corporate member of FWBH. |
| Form 990, Part VI, Line 7a: How Members or Shareholders Elect Governing Body | FH as the sole corporate member of FWBH has the final approval of election of all board members. |
| Form 990, Part VI, Line 7b: Describe Decisions of Governing Body Approval by Members or Shareholders | FH, as the sole corporate member of FWBH has certain powers and authorities with respect to the operations and management of FWBH as set forth in FWBH bylaws. |
| Form 990, Part VI, Line 11b: Form 990 Review Process | FH accounting staff prepare Form 990 which is reviewed by FH's financial leaders. The 990 is then reviewed by KPMG, FH's outside accounting firm. Next, the 990 is provided to the FH Finance Committee and Board of Directors. Finally, the 990 is filed as required. |
| Form 990, Part VI, Line 12c: Explanation of Monitoring and Enforcement of Conflicts | On an annual basis all officers, directors, trustees, and key employees are required to complete a conflict of interest disclosure document. The data is compiled, and the FH Vice President-Chief Compliance Officer (CCO), the Senior Vice President-General Counsel and/or delegate review all forms and notifications to determine if any conflicts of interest exists in the disclosure documents. If it is determined that a conflict of interest exists, then the person making the disclosure shall be relieved of his/her obligations on behalf of FWBH with respect to the transaction or arrangement that creates the conflict of interest. A report of all conflicts of interest will be made by the CCO at least once annually to the FH Finance Committee of the Board of Directors. |
| Form 990, Part VI, Line 15a: Compensation Review & Approval Process - CEO, Top Management | Compensation of CEO, Executive Directors, and Top Management is paid by FH the parent company and a related organization but a review is performed. In establishing the compensation of the organization's CEO, Executive Directors, and Top Management, independent compensation consultants are utilized, compensation studies are completed to gather comparative data, persons with a conflict of interest regarding the compensation arrangements at issue are not involved in the decision making process, and amounts are reviewed and approved by the Compensation Committee of the FH (the related organization) Board of Directors. In addition, there is contemporaneous documentation and record keeping for deliberations and decisions regarding the compensation arrangements. |
| Form 990, Part VI, Line 15b: Compensation Review and Approval Process for Officers and Key Employees | Compensation of several Officers is paid by a related organization but a review is performed. In establishing the compensation of the organization's Officers, independent compensation consultants are utilized, compensation studies are completed to gather comparative data, persons with a conflict of interest regarding the compensation arrangements at issue are not involved in the decision making process, and amounts are reviewed and approved by the Compensation Committee of the FH (the related organization) Board of Directors. In addition, there is contemporaneous documentation and record keeping for deliberations and decisions regarding the compensation arrangements. |
| Form 990, Part VI, Line 19: Other Organization Documents Publicly Available | FH's quarterly financial information, (which includes the operating results of FWBH), is made available to the public through the Digital Assurance Corporation, Inc. website. Anyone can register to receive ongoing access to and notifications regarding financial statements at the online website. FWBH governing documents and conflict of interest policy is made available to the public through the corporate office upon request. |
| Other Changes In Net Assets Or Fund Balances - Other Decreases | Kraemer Trust Annual Distribution = -$7124 |
| Other Changes In Net Assets Or Fund Balances - Other Decreases | Transfer to Affiliates = -$22472952 |
| Schedule H, Part V, Line 11 - Addressing Significant Needs Cont. | Other Engagement Programs and InitiativesCommunity Engagement proactively addresses the social, cultural and economic determinants that underpin health and seeks to build partnerships with others to find solutions. Froedtert & the Medical College of Wisconsin are committed to making a positive, sustained difference in our community. Community Engagement will strengthen the economic vitality and quality of life of those communities we serve. Froedtert West Bend Hospital Community Engagement programming and health improvement activities are supported through staff resources, budgeted dollars for programming and community partnershipsImpact 4 Life (Alcohol and Other Drug Abuse)Speeding, recklessness and drug or alcohol use are common risk factors among children and teens killed in motor vehicle and transport crashes, according to the Wisconsin Child Death Review Council. Changes in behavior can help prevent death and injury from vehicle crashes, one of the top five causes of preventable death in Wisconsin children. To drive home a powerful message about the consequences of drinking and driving and to help prevent death from drunk driving crashes, Froedtert West Bend Hospital collaborates with the local high schools in the Every 15 Minutes program. The program involves not only a mock crash but multiple scenarios that are videotaped by high school students and presented at a moving and emotional assembly at school the next day. The hospital has been part of the Every 15 Minutes program since 2006, as the receiving hospital for mock crash victims arriving by local EMS ambulance and Flight for Life. The Emergency Care Center provides staffing to treat the mock victims in a realistic way. Physicians, nurses, EMTs, technicians and other staff are involved. Hospital staff are also involved in the planning and communications. In a safe and caring way, the program confronts high school students with the real-life consequences of drug and/or alcohol use while driving and has been positively received by students and community. FY 2020 Outcomes/Progress: No event due to COVIDUnited Way Employee Campaign (Addresses all areas in Implementation Plan)- AmandaFroedtert West Bend Hospital collaborates with the United Way of Washington County to address community needs in the areas of access to health care, creating healthy beginnings and making healthy choices. Froedtert West Bend Hospital hosts an annual workplace giving campaign to support United Way and its affiliated organizations. FY 2020 Outcomes/Progress: 147 hours from staff and leaders to coordinate three week campaign. $10,260 restricted corporate gift to United Way of Washington County Overall dollars raised by staff, leaders and physicians - $650,174Sexual Assault Nurse Examiner (SANE) Available 24 Hours a Day (Access to Care and Navigation)When emergencies take on the even more traumatic element of sexual assault, the specially trained SANE program staff has created a safe haven at FWBH for comprehensive, compassionate care. SANE staff are registered nurses with advanced training in medical-forensic examination and in the psychological and emotional trauma patients experience. They care for victims of all ages, races and populations to provide timely:Emotional support Physical examination and wellness check Collection of medical-forensic evidence Assistance with reporting the crime to police, when requested (mandatory reporting for children) Assistance with concerns about sexually transmitted infection and pregnancy Assistance with safety planning Development of a medical follow-up plan SANE nurses are available to speak to groups and organizations. They are also able to serve as expert witnesses if called to testify at a trial. FY 2020 Outcomes/Progress: SANE nurses screened 17 patients and provided referrals and case management after initial consultation.ACA Insurance Marketplace and Enrollment Assistance (Access to Care and Navigation)Froedtert Health (parent company of Froedtert West Bend Hospital) recognized the need to help individuals navigate the new choices available to them through the Affordable Care Acts Insurance Marketplace and Medicaid reforms. Our overall health network of certified application counselors screened and enrolled over 89,000 in Public Assistance and Marketplace Insurance Plans. In addition, our certified application counselors answered thousands of phone calls and assisted with questions. Froedtert Health also partnered with the Milwaukee Enrollment Network which represented health systems, free clinics, health departments and other non-profit organizations to reach out to people throughout Milwaukee, Washington and Waukesha Counties in securing adequate and affordable health insurance. FY 2020 Outcomes/Progress: Enrollment Assistance for FWBH 1,295 individuals assisted in enrollment with the following programs: T19, Badger Care, Long Term Care, Disability, Emergency T19, Victim of Crime, Charity Care, Marketplace Insurance PlanLeadership Volunteerism/Community Support (Froedtert in Action) (Community Building) As an indication of Froedtert West Bend Hospitals executive teams commitment to the community, hospital leaders volunteer their time to support to local initiatives, not-for-profit organizations and community events that align with the hospitals mission and directly support identified community needs. FY 2020 Outcomes/Progress: More than 16 leaders provided 213 hours of support to local initiatives through volunteering at not-for-profit organizations and community eventsJob Shadow Program (Health Professions Education) Froedtert West Bend Hospital recognizes the value of preparing tomorrows health care today. Each year, Froedtert West Bend Hospital nurses, technicians and other health professionals provide Washington County college and high school students job shadowing experiences in clinical care or ancillary care areas of choice. FY 2020 Outcomes/Progress: Froedtert West Bend Hospital staff provided 2,753 hours of preceptorship time to 50 students in nursing roles Froedtert West Bend Hospital staff provided 1,220 hours of preceptorship time to 62 students in other professional/technical rolesProject SearchProject SEARCH is a nine-month program for young adults that provides training and education for ages 18 and older. The ultimate end goal that Project SEARCH strives for is employment for young adults with physical or cognitive challenges. The cornerstone of the program is total immersion into the business environment. Those selected to participate in the program will learn employable skills in a classroom setting, hands-on job skills and participate in a variety of meaningful rotations and experiences within our organizations environment. They will have the opportunity to complete three rotations lasting 10 weeks each. FY 2020 Outcomes/Progress: 7 interns completed only a rotation and half in FY20 due to COVID 14 staff provided 507 hours to precept and provide hands on learning to the interns and Easterseals staff.Health Care Career Academy (Health Professionals Education) The Healthcare Career Academy provides qualified students entering their junior or senior year at West Bend High Schools with the opportunity to expand their knowledge base as it relates to a wide array of professional healthcare career options. The two-week program allows students to shadow and learn from professionals in various clinical and ancillary departments throughout the hospital. Through observation, hands-on experience and classroom discussion, students are able to expand their awareness and interest in healthcare careers. FY 2020 Outcomes/Progress: Didn't hold due to COVIDFor more information on Froedtert West Bend Hospital Community Benefit programs, please visit http://www.froedtert.com/community-engagement/west-bend-hospital or see attached Report to the Community.Significant Health Needs Not AddressedTobacco Use: Froedtert West Bend Hospital supports the Multi-Jurisdictional Coalitions of Tobacco Free Community Partnership of Washington County and Elevate, Inc. to address this issue. |
| Schedule H, Part V, Line 11 - Addressing Significant Needs Identified | Heroin Task ForceThe Washington County Heroin Task Force was launched in February 2014 in response to the rising problem of prescription pain medication and heroin abuse in Washington County. Labeled a nationwide crisis and epidemic, reports from professionals in the community made it clear that we were far from immune. Confronting prescription drug and heroin abuse was essential to protecting the public health and safety of all our residents, including the youth. The task force was convened to understand and address the local problem in a strategic yet timely manner. Froedtert West Bend Hospital, along with other community members including, law enforcement, elected officials, county agencies and community members came together in a collaborative manner to immediately begin to identify and understand common problems and applicable resources. The Task Force identified four specific target areas: prevention, treatment, advocacy and law enforcement/courts. Elevate Community Resource Center: http://elevateyou.org/ Froedtert Staff Community Resource Center: http://intranet.froedtert.com/community-resourcesHidden in Plain Sight Traveling Bedroom (Awareness and Prevention Program of Opioid and Drug Use) FY 2020 Outcomes/Progress: 285 people toured the bedroom at 5 different sights/events in FY20Peers 4 Peers TrainingSpecial training for Washington County High School Students to become aware of tools and resources to help teens in need of help/assistance with AODA issues.FY2020 Outcomes/Progress: 130 youth trained in FY20 Froedtert West Bend Hospital Healthy Community Fund Grant Program Restricted annual grant program dedicated to helping non-profit organizations in Washington County support community programs or projects throughout Washington County, Wisconsin, that will positively affect the health and wellness of those living and working within this area. CHNA Area of Focus: Identified Community Health Needs in Washington County (Mental Health, AODA, Chronic Disease, Nutrition, Obesity, Transportation, Dental, Access to Care and Navigation of Community Resources)CHNA Community Health Need/Rationale: Lack of funding for non-profit organizations serving vulnerable populations in Washington County Sustainable funding for evidence-based programs/services focused on prevention, treatment and care managementGoal: Support non-profit organizations and resources that will promote healthy lifestyle choices as well as provide support for programs and services committed to the promotion of health and wellness in Washington CountyObjective: Increase self-management in high risk populations by addressing social determinants in health Expand health resources to assist, support, and navigate through community based clinical services and insurance coverageFroedtert West Bend Hospital Available Resources: Community Engagement leadership/staff St. Josephs Community FoundationFroedtert West Bend Hospital Collaborative Partners: Healthy Community Fund Committee Members - Leads Health Community Fund that provides funding to address priority health needs Washington County Non-Profit organizations - Partner with non-profits to address priority health needsFY 2020 Outcomes/Progress:In Fiscal Year 2020, Froedtert West Bend Hospital awarded $244,385 to eight Washington County Non-profits that are positively impacting 2,861 lives throughout the county. Below is a summary of awards and area of focus:Albrecht Free Clinic Smiles for a Lifetime (Access to Care/Navigation) The Albrecht Free Clinic provides medical, behavioral and dental services for eligible individuals who are underinsured, uninsured or otherwise unable to afford and access medical care. Healthy oral hygiene and dental care has been identified by the Albrecht Free Clinic as a major emerging community health need of local communities. Funds will support three types of dental care: emergency care, basic restorative and oral hygiene and education. This support will allow the clinic to address dental health for the uninsured and underinsured children and adults in Washington County. Amount awarded: $83,000People Served: 299Interfaith Caregivers of Washington County Senior Transportation Program (Access to Care/Navigation) Interfaith Caregivers helps Washington County residents over the age of 60 with assistance to live safely in their own home. Support is provided to enable seniors to live and thrive in their homes and community by providing transportation to medical appointments, pharmacies, grocery stores/food pantries and exercise and wellness programs. When transportation barriers for seniors are removed, a seniors access to healthcare and other vital services such as nutrition and wellness improve. Transportation expenses include volunteer recruitment and background checks, auto supplies, fuel, insurance, licensing, repairs/maintenance and software to track assisted rides. As the population of Washington County ages, providing support for these services is important so they do not increase to a point where the health of seniors is in jeopardy. Amount awarded: $23,250People Served: 1,715Youth and Family Project Crossroads Youth Program Outreach (Mental Health/Access to Services) The Youth and Family Project is a community based, human service, nonprofit agency founded in 1975. The agencys mission is to provide support, guidance and understanding to help people in need realize their individual goals of independence and personal well-being and for them to achieve a safe, stable living environment. The Youth and Family Project partnered with the Family Center of Washington County to offer the Crossroads Youth Program. This program will address issues associated with childhood trauma and provide a continuum of services to children facing difficult life events: peer support and individual counseling. Amount awarded: $25,000 People Served: 111Elevate, Inc. Elevate U (Alcohol and Other Drug Abuse) Elevate focuses on strengthening individuals and communities and to provide educational programming, awareness and prevention programs and assistance and supportive services aimed at reducing the risk for behavioral health issues and other high risk behaviors. The best way to combat this issue is through early awareness and evidence based preventions. Funds will be used to support Elevate U targeting youth (ages 12 17) early in their trajectory of substance abuse, truancy, and/or delinquency and gets them back-on-track toward reaching their full potential. Through this initiative, Elevates professional staff will provide evidence-based early intervention support in both individual and group settings. Amount Awarded: $30,450 People Served: 88Casa Guadalupe Education Center Healthy Latinos, Healthy Futures (Access to Care/Chronic Disease Prevention & Management) Casa Guadalupe is currently the only bilingual and bi-cultural community based non-profit organization serving Spanish speaking residents in Washington County. Latinos living in Washington County are the most likely group to not have a regular source of health care, resulting in low health literacy which affects the overall health of the community. Funds will support health seminars and programs, outreach initiatives and transportation needs to promote education about health screenings, diabetes prevention, active lifestyles and nutrition for adults and families. Amount awarded: $19,135People Served: 192Friends Inc. Friends and Kettle Moraine Counseling Mental Wellness (Mental Health/Alcohol and Other Drug Abuse) Friends of Abused Families has provided 40 years of service to Washington County and empowers and provides safety to those affected by domestic and sexual violence through support services and prevention education. The funds will be used to create a pilot project in partnership with Kettle Moraine Counseling to help survivors of domestic violence and/or sexual assault improve their mental wellbeing and live a drug free life. Services provided include mental health/substance abuse assessments, transportation costs, childcare, and rent assistance. Amount awarded: $21,750 People Served: 16Boys and Girls Clubs of Washington County - Healthy Minds Initiative (Mental Wellness)The Boys & Girls Clubs of Washington County enables all youth to realize their full potential as caring, productive and responsible citizens through providing positive social, educations, and recreational experiences. The funds awarded will be used to support their Healthy Minds Initiative which includes a Zen Den, partnership with PSG for behavioral health referrals, mental health staff training and educational programming.Amount awarded: $16,000People Served: 364NAMI - Recovery Center Programs (Mental Health)NAMI Washington County provides advocacy, education, support, and public awareness so that individuals and families affected by mental illness can build better lives. All of NAMI's programs centers around creating a stigma-free community through illness experience recovery, |
| Schedule H, Part V, Line 12 - Continued | In its FY18 Implementation Strategy, the Hospital explained how it planned to address most of the significant health needs identified in its FY18 CHNA report. However, it did not explain why it did not plan to address one of those significant health needs: tobacco use. In its amended FY18 Implementation Strategy (approved on August 25, 2020 and posted on its website on August 26, 2020), the Hospital corrected this deficiency for each of the three affected years by explaining that it does not intend to address tobacco use because it supports a community coalition that addresses this issue. 6. The CHNA report must include [a]n evaluation of the impact of any actions that were taken, since the hospital facility finished conducting its immediately preceding CHNA, to address the significant health needs identified in the hospital facility's prior CHNA(s) (Treas. Reg. 1.501(r)-3(b)(6)(i)(F)):As part of the 501(r) compliance review and analysis described above, the Hospital realized that although its Implementation Strategy contained an evaluation of actions taken to address significant health needs, this evaluation was not included in the Hospitals FY18 CHNA report, per se. The Hospital amended its FY18 CHNA report to correct this deficiency for each of the three affected years by including Appendix G, which describes the actions taken by the Hospital to address the significant health needs identified through its prior CHNA, as well as the impact / outcomes of those actions. Further, the amended FY18 CHNA report specifically identifies the significant health needs in Appendix G as being those identified in the Hospitals prior CHNA report. Cause of the FailureThe above-described failure was caused by a good-faith misinterpretation of certain elements of the highly technical and complex 501(r) regulations and requirements during a transition period in which Hospital staff became familiar with those requirements and how to implement them.Hospital Facility Where the Failure OccurredThe above-described failure occurred with respect to the Hospitals facility located at 3200 Pleasant Valley Road, West Bend, Wisconsin.Date(s) of the Failure and DiscoveryThe above-described failure occurred beginning July 1, 2017, which is the first day of the Hospitals fiscal year in which it was required to have, but did not have, a CHNA and Implementation Strategy that complied with the final 501(r) regulations. The failure was discovered with the assistance of legal counsel primarily during February and March 2020 upon review of the Hospitals compliance with section 501(r) and the regulations thereunder. The failure continued until August 26, 2020, when a corrected CHNA and Implementation Strategy had been approved by the Hospitals board and published on the Hospitals website.Number of OccurrencesEach above-described error occurred once with respect to the FY18 CHNA and Implementation Strategy, and continued until the Hospital corrected all such errors in its fiscal year ending June 30, 2021.Financial Assistance PolicyOverviewThe Hospital also determined that Froedterts Financial Assistance Policy (FAP), which applied to and served as the Hospitals FAP, contained certain errors and omissions under section 501(r)(4). Froedterts OGC has worked with its outside counsel, its tax advisors, and Froedterts Patient Financial Services team to correct those errors and omissions through amendments to the FAP, which the Hospitals Board of Directors adopted on April 16, 2021, and which were posted on the Hospitals web site on April 23, 2021. Description of the Failure and CorrectionsThese errors or omissions which together constitute a failure, since corrected, are as follows: The telephone number of the office that provides information about and assistance in completing the FAP was not included in the Plain Language Summary (PLS) of the FAP, as required by Treas. Reg. 1.501(r)-(1)(b)(24)(v). The Hospitals Board of Directors adopted an amended FAP on April 16, 2021 that includes this information. As of early 2020, the FAP was only translated into Spanish. Based on the most recent census data for Milwaukee County, this may have not been sufficient to satisfy the 501(r) requirement that the FAP, FAP application form, and PLS of the FAP must be translated into the language spoken by each [limited English proficient] language group that constitutes the lesser of 1,000 individuals or 5 percent of the community served by the facility or population likely to be affected or encountered by the hospital facility. (emphasis added; see Treas. Reg. 1.501(r)-4(b)(5)(ii)) Froedterts OGC worked with the Patient Financial Services team to determine for which limited English proficient populations the FAP, PLS, and FAP application needed to be translated into their primary language, then to translate those documents into Hmong, Arabic and Russian, which the Hospital posted on its web site on or about July 28, 2020. The FAP previously stated that Froedtert Health had final authority or responsibility for determining that the hospital facility has made reasonable efforts to determine whether an individual is FAP-eligible and may therefore engage in extraordinary collection actions (ECAs) against the individual, rather than specifying the office or department with responsibility for making this determination, as required by Treas. Reg. 1.501(r)-4(b)(4)(i)(C). Froedterts OGC worked with the Patient Financial Services team to amend the FAP. That amended FAP was adopted by the Hospitals Board of Directors on April 16, 2021, and now provides that Patient Financial Services has the final authority for determining that the hospital facility has made reasonable efforts to determine whether an individual is FAP-eligible before engaging in ECAs against that individual. While the FAP references the Billing and Collections Policy, it does not provide a link to the URL at which the FAP can be accessed on the website, or otherwise explain how to obtain that Policy on a web site, as required by Treas. Reg. 1.501(r)-4(b)(6)(i). Froedterts OGC worked with the Patient Financial Services team to amend the FAP to include this link. That amended FAP was adopted by the Hospitals Board of Directors on April 16, 2021. The list of providers attached as Exhibit A to the FAP did not state that it included all providers (other than the hospital facility itself) delivering emergency or other medically necessary care in the hospital facility, rather than only those providers not covered under the FAP, as required by Treas. Reg. 1.501(r)-4(b)(1)(iii)(F). Froedterts OGC worked with the Patient Financial Services team to amend both the FAP and Exhibit A to include a new paragraph stating that Exhibit A contains a complete list of all providers who render emergency or other medically necessary care at a Froedtert Health hospital, and that none of those providers services are covered by the FAP. That amended FAP and Exhibit A were adopted by the Hospitals Board of Directors on April 16, 2021. The FAP application stated that it must be completed and returned to the Hospital within ten days, and that failure to do so may result in a denial of the application. The Hospital understands that this may have been inconsistent with the definition of application period in Treas. Reg. 1.501(r)-1(b)(3). However, notwithstanding the language in the FAP application, the Hospital has at all times accepted and processed, and continues to accept and process, completed FAP applications within the application period, as defined in section 1.501(r)-1(b)(3). The FAP did not apply to medically necessary care received outside of the patients insurance network, when similar care can be rendered within the patients network (i.e., not unique to [the Hospital]), which may have been inconsistent with the requirement that financial assistance policies apply to all emergency and other medically necessary care provided by the hospital facility pursuant to Treas. Reg. 1.501(r)-4(b)(1)(i). The Hospital has since amended the FAP, through approval of its Board of Directors on April 16, 2021, to eliminate this restriction. Neither the FAP nor any other policy of the Hospital included the emergency medical care policy language described in Treas. Reg. 1.501(r)-4(c)(1)-(2), which would prohibit the Hospital from engaging in actions that discourage individuals from seeking emergency medical care. The Hospital has since amended the FAP, through approval of its Board of Directors, on April 16, 2021, to incorporate the required language.Note that Froedtert and the Hospital have not been able to identify any individuals who have been adversely affected by any of the foregoing FAP-related errors or omissions.Cause of the FailureThe above-described failure with respect to the FAP was caused by a good-faith misinterpretation of certain elements of the highly technical and complex 501(r) regulations and requirements during a transition period in which Hospital staff be |
| Schedule H, Part V, Line 12 - Continued | Number of OccurrencesEach above-described failure was ongoing during the periods described above.Practices and procedures to promote 501(r) compliance and prevent recurrence of failures Through the review and correction process described above, each of the Hospital and Froedtert has taken proactive steps to meet the requirements of Sections 501(r) and the regulations, and to minimize the likelihood of 501(r) errors or omissions recurring. These steps include: Froedterts OGC reviewed the deficiencies and met on several occasions with the internal departments responsible for the CHNA/IS, FAP, and patient billing and collections, including the Community Engagement team and Patient Financial Services team, to identify and correct 501(r) errors. Froedtert discussed the deficiencies with outside legal counsel and tax advisors, who reviewed 501(r) policies and practices, identified errors and omissions, and recommended corrections to bring the Hospital into full 501(r) compliance. The Community Engagement team then revised the CHNA report and related Implementation Strategy to correct each of the identified 501(r) deficiencies. The amended FY18 CHNA report and related Implementation Strategy were then approved by the Hospital's Board of Directors and posted to the hospital's website. Froedtert's Office of General Counsel and Compliance Department will be working with outside consultants to develop necessary education sessions that will be required of the Hospitals Community Engagement team, Patient Financial Services team, and other applicable departments and teams. This education will be intended to improve those departments and teams' understanding of the applicable 501(r) regulations and their application to (i) development and preparation of CHNA reports and implementation strategies, (ii) the administration of and adherence to the Hospitals FAP, and (iii) the Hospitals billing and collections practices. The applicable Froedtert departments are in the process of drafting or amending policies and procedures to assure consistent compliance with, and management of processes designed to promote compliance with, the 501(r)(3) regulations. |
| Schedule H, Part VI, Line 12a - Disclosures of Section 501(r) | St. Josephs Community Hospital of West Bend, Inc. Schedule H Disclosures of Section 501(r)-Related Failure and Corrections:FY18 Community Health Needs Assessment:OverviewIn early 2020, St. Josephs Community Hospital of West Bend, Inc. (the Hospital), determined that its FY18 Community Health Needs Assessment (CHNA) and Implementation Strategy (which were intended to cover FY18-FY20) did not comply with certain of the technical requirements of section 501(r) of the Internal Revenue Code and the Treasury Regulations thereunder. The failures were discovered in connection with a review conducted by outside counsel to the Hospital and Froedtert Health, Inc. (Froedtert), the parent corporation of the Hospital. As described herein, the deficiencies were due to reasonable cause and were promptly corrected upon discovery.Froedtert is a member of the Milwaukee Health Care Partnership (Partnership). Through this Partnership, Froedtert worked with several other local health systems and the Washington Ozaukee County health department to collaborate and fund the joint data collection, stakeholder interviews, focus groups and other information systems that contributed to the CHNA for the Hospital and the region in 2016-2017, and that the Hospital used in developing its Implementation Strategy. The Partnership worked with the Center for Urban Population Health to develop a FY18 CHNA Data Report and its components (e.g., Community Survey, Key Informant Interview Report, Secondary Data Report). Froedterts Community Engagement team used this information, along with the Hospitals overall service area, market share and patient demographic data, to prepare the Hospitals FY18 CHNA report and Implementation Strategy, which the Hospitals Board of Directors approved on May 23, 2017, and which was posted to the Hospitals website on May 24, 2017. The Hospital believed that these steps brought the Hospital into compliance with the CHNA requirements of section 501(r) for the Hospitals fiscal year ended June 30, 2018, through its fiscal year ended June 30, 2020. Subsequent review determined that neither the FY18 CHNA report nor the Implementation Strategy was in full compliance with certain of the technical and complex elements required by the 501(r) regulations, as the Community Engagement team did not fully understand or did not appropriately interpret all of the applicable requirements during a transition period in which team members became familiar with those requirements and how to implement them. Since its discovery of these errors, Froedtert has worked with its internal Office of General Counsel (OGC), Community Engagement team, Compliance Department, and Finance Department, as well as its outside legal counsel (Quarles & Brady), and its outside tax advisor (Ernst & Young LLP), to identify specific Section 501(r)-related errors or omissions, with each party conducting an independent review of the Hospitals CHNA reports, Implementation Strategies, and related practices. Based on these parties reviews and findings, Froedtert and the Hospital have worked to correct the 501(r) errors and omissions. For instance, the Hospital amended its FY18 CHNA report and Implementation Strategy to conform with the 501(r) regulations, and both corrected documents were approved by the Hospitals Board of Directors (its governing body under the Hospitals governing documents and Wisconsin state law) on August 25, 2020, then posted to the Hospitals website on August 26, 2020. In this manner, the Hospital corrected the deficiencies in the manner set forth in Revenue Procedure 2015-21 for each of the fiscal years ended June 30, 2018, June 30, 2019, and June 30, 2020.Description of the Failure and CorrectionsThe errors and omissions that together constitute a failure were identified and corrected as follows: 1. The CHNA must be conducted in the current taxable year or in either of the two immediately preceding taxable years (Treas. Reg. 1.501(r)-3(a)):The Hospital historically has begun each community health needs assessment in advance of the next three-year CHNA implementation cycle. This has allowed the Hospital to put the Implementation Strategy into action for the first day of the first fiscal year that begins the three-year CHNA cycle, thereby affording the Hospital three full years to implement and operationalize programs, partnerships and investments to meet the most significant community health needs of the diverse communities the Hospital serves. The practice, however, has led to an unintentional and unexpected compliance issue with respect to timing. The Hospitals FY18 CHNA and Implementation Strategy (to cover FY18-FY20) should have been conducted during the Hospitals fiscal year ended June 30, 2018. The Hospitals Board of Directors approved the CHNA report and Implementation Strategy on May 23, 2017, and posted those documents on its web page on May 24, 2017. The Hospital subsequently determined, in consultation with its advisors, that each did not include certain elements required by the 501(r) regulations. Accordingly, the Hospital had not fully conducted a FY18 CHNA. The Hospitals Community Engagement team then worked with the OGC and outside legal counsel throughout 2020 to revise the FY18 CHNA report and Implementation Strategy as set forth below and to conform with the 501(r) regulations. The Hospitals Board of Directors adopted both amended documents on August 25, 2020. Upon the Hospitals posting these documents to its website on August 26, 2020, it satisfied the requirements of Treas. Reg. 1.501(r)-3(a), as explained below. 2. The CHNA report must include a definition of the community served by the facility (Treas. Reg. 1.501(r)-3(b)(6)(i)(A)):As part of the 501(r) compliance review described above, the Hospital concluded that its FY18 CHNA had not sufficiently defined the community served by its hospital facility or described how it determined its community, as required under Treas. Reg. 1.501(r)-3(b)(6)(i)(A). The Hospitals Community Engagement team amended the FY18 CHNA report to identify the Hospitals community as Washington County, and to describe how it identified Washington County as its community: based on its annual review and analysis of hospital discharges and market share, because it derives 87.5% of discharges from Washington County, and because it engages in all programs, activities, and partnerships that are described in the FY18 CHNA in Washington County. The amended FY18 CHNA report adopted by the Hospitals Board of Directors on August 25, 2020 corrected this deficiency for each of the Hospitals fiscal years ended June 30, 2018, June 30, 2019, and June 30, 2020. 3. The CHNA report must include [a] description of how the hospital facility solicited and took into account input received from persons who represent the broad interests of the community it serves (Treas. Reg. 1.501(r)-3(b)(6)(i)(C)):As part of the 501(r) compliance review described above, the Hospital concluded that it had not sufficiently described in its FY18 CHNA report its efforts to solicit and take into account input from persons who represent the broad interests of the community it serves, over what time period such efforts were conducted, or from which specific members of medically underserved, low-income, and minority populations or their representatives the Hospital solicited input. The Hospitals Community Engagement team amended the FY18 CHNA report to correct these errors. In particular, the Hospital included a new section describing how it solicited input on the significant health needs in its community, including interviews with key informants and with members of low-income, minority and underserved populations. The Hospital added to the FY18 CHNA report the time frame during which it solicited this community input. It also added a new Appendix E describing key informant organizations from which input was solicited, and described how some of these organizations represent medically underserved, low-income, and minority populations in its community. The Hospital also added a new section to the report that specifically describes how it solicited and took into account written comments on its most recently conducted CHNA and most recently adopted Implementation Strategy, along with describing how feedback and public comments on the FY18 CHNA report can be provided, electronically or by phone. The amended FY18 CHNA report adopted by the Hospitals Board of Directors on August 25, 2020, corrected this deficiency for each of the fiscal years ended June 30, 2018, June 30, 2019, and June 30, 2020. 4. The CHNA report must include [a] description of resources potentially available to address [the significant health] needs identified through the CHNA (Treas. Reg. 1.501(r)-3(b)(6)(i)(E))):As part of the 501(r) compliance review and analysis described above, the Hospital realized that although its FY18 Implementation Strategy referenced resources available for certain Hospital program |
| Software ID: | 19009920 |
| Software Version: | 2019v5.0 |