| Form 990, Part VI, Section A, line 3 |
The Trust has contracted with a third-party administrator (Benefit Solutions, Inc.) to provide bookkeeping and administrative services. |
| Form 990, Part VI, Section A, line 7a |
Under the rules of the Trust, a supermajority of the employers can hold an election to remove and replace the Trustee. |
| Form 990, Part VI, Section A, line 8b |
The Trust has no committees with authority to act on behalf of the governing body. |
| Form 990, Part VI, Section B, line 11 |
The Form 990 was prepared under the guidance of the Trustee 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 consultants and advisors, who reviewed the Form 990 for accuracy and completeness. Any questions, concerns or issues raised by the consultants and advisors were addressed and any necessary revisions were made to the Form 990. The revised Form 990 was then provided to the Trustee for his review and approval. Any additional questions, concerns or issues raised by the Trustee were addressed and any necessary revisions were made to the Form 990. The final version of the Form 990 was reviewed, approved and filed by the Trustee. |
| Form 990, Part VI, Section B, line 12c |
In connection with any actual or possible conflict of interest, an interested person must disclose the existence of the financial interest and be given the opportunity to disclose all material facts to the Trustee while he is considering the proposed transaction or arrangement. After disclosure of the financial interest and all material facts, and after any discussion with the interested person, the interested person is excluded from the meeting while the determination of a conflict of interest is discussed and action taken. The Trustee will decide if a conflict of interest exists. If it is determined that a conflict of interest exists the following steps will be taken: a) the Trustee will, if appropriate, appoint a disinterested person to investigate alternatives to the proposed transaction or arrangement, b) after exercising due diligence, the Trustee will determine whether the Trust can obtain with reasonable efforts a more advantageous transaction or arrangement from a person or entity that would not give rise to a conflict of interest, c) if a more advantageous transaction or arrangement is not reasonably possible under circumstances not producing a conflict of interest, the Trustee will determine whether the transaction or arrangement is in the Trust's best interest, for its own benefit, and whether it is fair and reasonable. In conformity with the above determination he will make his decision as to whether to enter into the transaction or arrangement. The Trustee will not approve a transaction or arrangement that would result in a prohibited transaction or fiduciary self-dealing under ERISA. If a prohibited transaction would result from the transaction or arrangement, the Trustee, may, in his discretion, permit the interested person to attempt to obtain a prohibited transaction exemption from the U.S. Department of Labor. If the Trustee has reasonable cause to believe that an interested person has failed to disclose actual or possible conflicts of interest, he 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. If, after hearing the intererested person's response and after making further investigation as warranted by the circumstances, the Trustee determines the interested person has failed to disclose an actual or possible conflict of interest, he will take appropriate disciplinary and corrective action. If a transaction or arrangement with an interested person results in a prohibited transaction or fiduciary self-dealing under ERISA, the Trustee will take appropriate action under law. The minutes of the Trustee will contain: a) the names of the persons who disclosed or otherwise were found to have a financial interest in connection with an actual or possible conflict of interest, the nature of the financial interest, any action taken to determine whether a conflict of interest was present, and the Trustee's decision as to whether a conflict of interest in fact existed, and b) the names of the persons who were present for discussions and the action relating to the transaction or arrangement, the content of the discussion, including any alternatives to the proposed transaction or arrangement, and a record of any action taken in connection with the proceedings. The compensation of the Trustee, whether direct or indirect, from the Trust for his services must be approved by the participating employers in their Master Applications. The Trustee shall provide no other services that are compensated or have any other transactions or arrangements with the Trust. No fiduciary or other person who provides services to or otherwise does business with the Trust and who receives compensation, directly or indirectly, from the Trust, either individually or collectively, is prohibited from providing information to the Trustee regarding compensation. The Trustee, other fiduciary or any other person who provides services to or otherwise does business with the Trust sign a statement which affirms such person: a) has received a copy of the conflicts of interest policy, b) has read and understands the policy, c) has agreed to comply with the policy, and d) understands the Trust is a voluntary employee beneficiary association under section 501(c)(9) and in order to maintain its federal tax exemption it must engage primarily in activities which accomplish one or more of its tax-exempt purposes and that it is subject to ERISA's prohibited transaction and fiduciary self-dealing rules. 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, periodic reviews are conducted. The periodic reviews include, at a minimum, the following subjects: a) whether compensation arrangements and benefits are reasonable, based on competent survey information and the result of arm's length bargaining, and b) whether contracts and other arrangements for services conform to the Trust's written policies, are properly recorded, reflect reasonable investment or payments for goods and services, further the purposes of the Trust and do not result in inurement, impermissible private benefit or in an excess benefit transaction. When conducting the periodic reviews as discussed above, the Trustee may, but need not, use outside experts. If outside experts are used, their use will not relieve the Trustee of his responsibility for ensuring periodic reviews are conducted. |
| Form 990, Part VI, Section B, line 15a |
The Trustees compensation has been determined by evaluating the compensation packages of similar revenue sized not-for-profit tax-exempt health care organizations. The Trust purchases from the Economic Research Institute its Nonprofit Comparables Assessor which displays all tax-exempt Form 990s that report executive compensation for the current calendar year. From this data the amount of the Trustee's compensation is targeted to be between the 70th and 80th percentile for senior executives of similarly sized reported organizations. This was determined to be reasonable given the size of the Trust, the number of insured, the level of responsibility, and the fact that he pays all of his own taxes, benefits and other expenses of acting as Trustee. The formula for determining the Trustees compensation is reported to the participating employers as part of each employers copy of the governing trust agreement which is distributed when an employer first joins the Trust and any time that there is a change. The exact dollar amount of compensation is reported to the U.S. Department of Labor on Form 5500 and is available online or upon request by participants and employers. At each renewal, the participating employers approve the arrangements with the Trustee when they renew, or they can elect to take their business elsewhere in a very competitive insurance market or, under the rules of the Trust, a super majority of the employers can hold an election to remove and replace the Trustee. |
| Form 990, Part VI, Section C, line 19 |
The Trust's governing documents, conflict of interest policy, financial statements and Form 990 are available to the general public upon written request sent to Benefit Solutions, Inc. at: P.O. Box 6, Mukilteo, WA 98275. |
Attach to Form 990 or 990-EZ.