| FORM 990, PART VI, SECTION A, LINE 6 |
THE ORGANIZATION IS A NON-STOCK NOT-FOR-PROFIT CORPORATION WITH ONE CLASS OF MEMBERSHIP. |
| FORM 990, PART VI, SECTION A, LINE 7A |
THE MEMBERS RATIFY THE SELECTION OF THE INDIVIDUALS THAT SERVE ON THE BOARD OF TRUSTEES (GOVERNING BODY) AFTER THOSE INDIVIDUALS HAVE BEEN SELECTED AS A TRUSTEE BY THE BOARD OF TRUSTEES. |
| FORM 990, PART VI, SECTION A, LINE 7B |
YES, THE INDIVIDUALS OF THE TRUSTEES (GOVERNING BODY) AND THE MEMBERS MUST BE APPROVED BY THE MEMBERSHIP BODY. |
| FORM 990, PART VI, SECTION B, LINE 11B |
ONE OR MORE MEMBERS OF SENIOR MANAGEMENT REVIEW THE RETURN. THE RETURN IS ALSO REVIEWED BY HORNE, LLP, THE COMPANY'S TAX ADVISORS. A COPY OF THE RETURN IS THEN PROVIDED TO EACH MEMBER OF THE BOARD OF DIRECTORS ELECTRONICALLY AND COMMENTS ARE SOLICITED FROM THE ENTIRE BOARD. |
| FORM 990, PART VI, SECTION B, LINE 12C |
CONFLICT OF INTEREST POLICY: OFFICERS, DIRECTORS, TRUSTEES, AND KEY EMPLOYEES OF OCHSNER CLINIC FOUNDATION AND ITS SUBSIDIARIES AND AFFILIATES ARE REQUIRED TO COMPLETE A CONFLICT OF INTEREST DISCLOSURE FORM ANNUALLY, WITHIN 40 DAYS OF BECOMING AN EMPLOYEE, OR IF AN INDIVIDUAL HAS A CHANGE IN BUSINESS CIRCUMSTANCES NOT PREVIOUSLY DISCLOSED. THE CONFLICT OF INTEREST TEAM REVIEWS DISCLOSURES AND DETERMINES WHETHER RISK MITIGATION ACTION IS NECESSARY OR IF THE DISCLOSURE NEEDS TO BE REVIEWED BY THE CONFLICT OF INTEREST STEERING COMMITTEE. THE CONFLICT OF INTEREST STEERING COMMITTEE WILL MAKE MITIGATION RECOMMENDATIONS, INCLUDING, BUT NOT LIMITED TO, RECUSAL IN DECISION MAKING, DIVESTITURE AND TERMINATION OF BUSINESS RELATIONSHIPS. OCHSNER CLINIC FOUNDATION REQUIRES ANNUAL CERTIFICATION THAT THE RELATIONSHIPS DISCLOSED DURING A PRECEDING CALENDAR YEAR ARE COMPLETE AND ACCURATE. IN ADDITION, EMPLOYEES THAT DO NOT FALL WITHIN THE SCOPE OF THE CONFLICT OF INTEREST DISCLOSURE POLICY COMPLETE NEW HIRE OR RISK-BASED CONFLICT OF INTEREST TRAINING IN ALIGNMENT WITH THE CONFLICT OF INTEREST POLICY. |
| FORM 990, PART VI, SECTION B, LINE 15 |
THE OFFICERS OF THE ORGANIZATION ARE NOT COMPENSATED BY THE CORPORATION, BUT ARE COMPENSATED BY RELATED ORGANIZATIONS FOR THEIR ROLES AS OFFICERS AND EXECUTIVES OF THE OCHSNER CLINIC FOUNDATION. 15A - PROCESS TO ESTABLISH COMPENSATION OF TOP MANAGEMENT OFFICIAL: ALL CEO AND OFFICER COMPENSATION AND BENEFITS ARRANGEMENTS, INCLUDING SALARY AND BONUS INCENTIVE PLANS, ARE REVIEWED AND APPROVED BY THE EXECUTIVE AND SENIOR PHYSICIAN COMPENSATION COMMITTEE OF THE BOARD OF DIRECTORS (COMPENSATION COMMITTEE). NO SUBSTANTIVE CHANGE TO THE COMPENSATION OR BENEFITS PACKAGES IS MADE UNTIL COMMITTEE APPROVAL IS GRANTED IN ACCORDANCE WITH INTERMEDIATE SANCTIONS GUIDELINES. THE COMPENSATION COMMITTEE IS WITHOUT CONFLICTS OF INTEREST AND USES AN INDEPENDENT EXTERNAL CONSULTANT. APPROPRIATE DATA IS APPLIED TO DETERMINE THE COMPARABILITY OF FAIR MARKET VALUE PAY AND ALL ACTIONS ARE APPROPRIATELY DOCUMENTED. IN ORDER TO MEET THE REQUIREMENTS OF THE IRS INTERMEDIATE SANCTIONS REGULATIONS, THE COMPENSATION COMMITTEE IDENTIFIED THE "DISQUALIFIED INDIVIDUALS" THAT ARE IN A POSITION TO EXERCISE SUBSTANTIAL INFLUENCE OVER THE COMPANY'S OPERATIONS. THESE INDIVIDUALS ARE THE MEMBERS OF THE EXECUTIVE OFFICERS COMMITTEE (EOC), REGIONAL MEDICAL DIRECTORS, PHYSICIAN BOARD MEMBERS AND SECTION HEADS FOR KEY DEPARTMENTS. FOR DISQUALIFIED INDIVIDUALS, THE COMPENSATION REVIEW ALSO INCLUDES THE COST OF BENEFITS SUCH AS THE COMPANY PORTION OF MEDICAL AND DENTAL BENEFITS, MALPRACTICE INSURANCE, PAYMENTS FOR 401K MATCHING AND PENSION PAYMENTS. 15B - PROCESS TO ESTABLISH COMPENSATION OF OTHER OFFICERS OR KEY EMPLOYEES: PT VI LN 15A DESCRIBES THE COMPENSATION PROCESS FOR MANY OF THE OFFICERS, KEY EMPLOYEES, AND SR PHYSICIAN BOARD MEMBERS. A DIFFERENT REVIEW PROCESS IS USED FOR PHYSICIANS. ANNUALLY, THE PHYSICIAN COMPENSATION DEPARTMENT REVIEWS THE COMPENSATION OF EACH EMPLOYED PHYSICIAN. THIS REVIEW INCLUDES A COMPARISON OF PHYSICIAN SALARIES AGAINST NATIONAL SURVEY DATA FOR THEIR SPECIALTY. THE PHYSICIAN COMPENSATION DEPARTMENT COMPILES THE COMPENSATION DATA FOR EACH PHYSICIAN INCLUDING BASE SALARY, STIPENDS, ON-CALL PAY, ETC. EACH PHYSICIAN'S COMPENSATION AS WELL AS THE TOTAL WORK RELATIVE VALUE UNITS (RVUS) ARE COMPARED TO THE SURVEY DATA. COMPENSATION FOR OTHER NON-OFFICER AND NON-PHYSICIAN KEY EMPLOYEES IS REVIEWED BY SENIOR EXECUTIVES WHO TAKE MARKET VALUE RESEARCH INTO CONSIDERATION WHEN DETERMINING COMPENSATION LEVELS. MANAGEMENT JOBS ARE ASSIGNED TO PAY RANGES WHERE THE MIDPOINT IS ALIGNED TO THE 50TH PERCENTILE OF SALARY SURVEY DATA. UPON HIRE, MANAGEMENT SALARIES ARE BASED UPON APPLICABLE SKILLS AND EXPERIENCE RELEVANT TO THE JOB AND PAY RANGE. MERIT INCREASES ARE AWARDED ANNUALLY THEREAFTER BASED UPON PERFORMANCE. OFF-CYCLE ADJUSTMENTS MAY BE PROVIDED DUE TO MARKET MOVEMENT TO ENSURE ALIGNMENT WITH THE COMPETITIVE MARKET. |
| FORM 990, PART VI, SECTION C, LINE 19 |
REQUIRED DOCUMENTS AVAILABLE TO THE PUBLIC: ALL GOVERNING DOCUMENTS, FINANCIAL STATEMENTS, AND FORMS 990 AND 990-T ARE AVAILABLE UPON WRITTEN REQUEST TO THE CHIEF FINANCIAL OFFICER OF OCHSNER CLINIC FOUNDATION. THE CONFLICT OF INTEREST POLICY IS AVAILABLE UPON WRITTEN REQUEST TO THE AUDIT SERVICES DEPARTMENT OF OCHSNER CLINIC FOUNDATION. |
| FORM 990, PART VII, SECTION A, LINE 1A, COLUMN (B) - ADDITIONAL COMP: |
COMPENSATION FROM INTEGRATED HEALTH SYSTEM EACH OF THE OFFICERS/DIRECTORS LISTED IN PART VII AND SCHEDULE J HOLD POSITIONS WITH RELATED 501(C)(3) ORGANIZATIONS. FOR EACH OF THESE INDIVIDUALS, THE COMPENSATION LISTED IS RECEIVED FROM THE RELATED ORGANIZATION. THE AMOUNT OF TIME SHOWN FOR EACH AS "AVERAGE HOURS PER WEEK" IN PART VII, SECTION A, LINE 1A, COLUMN (B), CONSISTS PRIMARILY OF EACH OFFICER'S TIME SPENT ON THE OFFICER'S ROLE WITH THE ORGANIZATION. THE REMAINDER OF EACH OFFICER'S TIME IS SPENT FULFILLING RESPONSIBILITIES THROUGH THEIR ROLES WITH THE RELATED ORGANIZATION AND/OR IS MORE EVENLY DISTRIBUTED ACROSS ALL ORGANIZATIONS IN THE INTEGRATED HEALTH SYSTEM. |
| FORM 990, PART VI, LINE 14 - WRITTEN DOCUMENTATION RETENTION & DESTRUCTION: |
THERE ARE DOCUMENT RETENTION POLICIES FOR VARIOUS DEPARTMENTS, THOUGH A SINGLE DOCUMENT RETENTION POLICY APPLICABLE TO THE SYSTEM AS A WHOLE DOES NOT EXIST. |
| FORM 990, PART XII, LINE 2C |
THE ORGANIZATION IS A SUBSIDIARY OF OCHSNER CLINIC FOUNDATION (TIN# 72-0502505), AND IS THUS INCLUDED IN THE CONSOLIDATED FINANCIAL STATEMENTS OF OCHSNER CLINIC FOUNDATION. OCHSNER CLINIC FOUNDATION'S FINANCIAL STATEMENTS ARE AUDITED BY AN INDEPENDENT ACCOUNTANT. IN ADDITION, OCHSNER CLINIC FOUNDATION HAS A COMMITTEE FOR OVERSIGHT OF THE AUDIT, REVIEW, OR COMPILATION OF ITS FINANCIAL STATEMENTS AND SELECTION OF AN INDEPENDENT ACCOUNTANT. |