2023-05-12T13:44:49-05:00 2022-06-30 351178661 BLUE & CO LLC 9200 WORTHINGTON RD STE 200 WESTERVILLE OH 43082 990 2021-07-01 311447726 OHIO STATE UNIVERSITY PHYSICIANS INC OHIO 6147847800 700 ACKERMAN RD 6000 COLUMBUS OH 43202 L ARICK FORREST MD PRESIDENT 6149473700 2023-05-12 1 L ARICK FORREST MD 999009999 ANGELA N CRAWFORD CPA P00573197 6148852583 2023-05-12 3 AAL1 IAL1 2021 2023-04-26 12:10:37Z L ARICK FORREST MD 700 ACKERMAN RD 6000 COLUMBUS OH 43202 729695588 0 X WWW.OSUPHYSICIANS.COM X 2002 OH OHIO STATE UNIVERSITY PHYSICIANS ALONG WITH THE OHIO STATE UNIVERSITY COLLEGE OF MEDICINE RENDER CLINICAL SERVICES IN CONNECTION WITH THEIR TEACHING DUTIES AND PROVIDE MEDICAL CARE TO ALL THOSE WHO SEEK SUCH SERVICES. THE PHYSICIANS SUPPORT ACADEMIC ENRICHMENT TO THE EDUCATIONAL AND RESEARCH PROGRAMS OF THE OHIO STATE UNIVERSITY COLLEGE OF MEDICINE AS WELL AS CHARITY CARE TO SUPPORT THE CLINICAL MISSION OF OSU INCLUDING PROVIDING CARE TO INDIVIDUALS THAT MAY NOT BE ABLE TO AFFORD CARE. ADDITIONALLY THEY SUPPORT PATIENTS THAT ARE A PART OF THE MEDICARE / MEDICAID PROGRAMS BY ACCEPTING PAYMENTS FOR SERVICES THAT ARE LESS THAN COST. 31 0 1721 0 0 0 0 11686052 656851996 714608473 -12928 562842 1918623 2728256 658757691 729585623 15050804 6496702 0 0 524292300 575769641 0 0 0 109748162 132619509 649091266 714885852 9666425 14699771 394073448 461447285 178747936 240163935 215325512 221283350 X THE EXEMPT PURPOSE OF THE ORGANIZATION IS TO ENHANCE, IMPROVE AND SUPPORT THE EDUCATIONAL, RESEARCH, AND CLINICAL PROGRAMS OF THE OHIO STATE UNIVERSITY COLLEGE OF MEDICINE, THE PHYSICIANS WHO RENDER CLINICAL AND RESEARCH SERVICES IN CONNECTION WITH THEIR TEACHING DUTIES AND TO PROVIDE MEDICAL CARE TO ALL THOSE WHO SEEK SUCH SERVICES. PROGRAMS PROVIDE HEALTH CARE AND TEACHING TO THE CENTRAL OHIO AREA AND MULTIPLE CLINICAL LOCATIONS. OTHER SERVICES INCLUDE BILLING AND COLLECTIONS FOR RELATED ENTITIES AND DEPARTMENTS. CARE IS PROVIDED TO PATIENTS REGARDLESS OF THEIR ABILITY TO PAY. A PATIENT IS CLASSIFIED AS CHARITY CARE IN ACCORDANCE WITH FEDERAL GUIDELINES, THE OHIO STATE UNIVERSITY HEALTH SYSTEM AND OHIO STATE UNIVERSITY PHYSICIANS, AND AMOUNTS DETERMINED TO QUALIFY AS CHARITY CARE ARE WRITTEN OFF. 0 0 132557470 6496702 22408278 ACADEMIC ENRICHMENT TO SUPPORT THE EDUCATIONAL AND RESEARCH PROGRAMS OF THE OHIO STATE UNIVERSITY COLLEGE OF MEDICINE. 373133207 167471756 SUPPORT PATIENTS THAT ARE A PART OF THE MEDICARE /MEDICAID PROGRAMS BY ACCEPTING PAYMENTS FOR SERVICES THAT ARE LESS THAN COST. 8269215 CHARITY CARE TO SUPPORT THE CLINICAL MISSION OF OSU INCLUDING PROVIDING CARE TO INDIVIDUALS THAT MAY NOT BE ABLE TO AFFORD CARE. 94481414 527456695 ALL OTHER PROGRAM SERVICES INCLUDING CLINICAL CARE FOR PATIENTS TYPICAL OF AN ACADEMIC PHYSICIAN OFFICE PRACTICE. 94481414 527456695 608441306 1 1 0 0 0 0 0 0 0 0 1 0 0 1 1 1 1 1 0 0 0 0 0 0 0 0 0 1 0 1 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 1 0 0 0 1 131 0 1 1721 1 0 0 0 0 0 0 0 0 0 0 0 0 X 31 0 0 0 0 0 0 0 0 1 1 0 1 1 1 1 1 1 1 1 1 1 0 OH X DEBORAH CHUDZIK 6146851517 700 ACKERMAN RD SUITE 6000 COLUMBUS OH 43202 ADKINS ERIC BOARD MEMBER 1.00 40.00 X 0 395275 91677 ANDERSON JAY BOARD MEMBER 1.00 40.00 X 0 526719 63489 BRADFORD CAROL BOARD MEMBER 1.00 40.00 X 0 1102136 123257 CATERINO JEFF BOARD MEMBER 1.00 40.00 X 0 608580 124786 CHAKRAVARTI ARNAB BOARD MEMBER 1.00 40.00 X 0 972833 102884 DUNGAN KATHLEEN BOARD MEMBER 1.00 40.00 X 0 258832 62197 EXLINE MATTHEW BOARD MEMBER 1.00 40.00 X 0 461242 74829 FARRAR WILLIAM BOARD MEMBER 1.00 40.00 X 0 1046319 128851 FRANKEL WENDY BOARD MEMBER 1.00 40.00 X 0 589272 105257 FREIMER MIRIAM BOARD MEMBER 1.00 40.00 X 0 333571 77852 GLASSMAN ANDREW BOARD MEMBER 1.00 40.00 X 0 912304 113644 HARTER RONALD BOARD MEMBER 1.00 40.00 X 0 647867 105006 KING MARK BOARD MEMBER (THROUGH 12/21) 1.00 40.00 X 0 546643 123135 LANDON MARK BOARD MEMBER 1.00 40.00 X 0 751378 104544 LARMORE MARK CFO, MEDICAL CENTER 1.00 40.00 X 0 1633644 918907 LEE CHERYL VICE PRESIDENT 1.00 40.00 X X 0 904682 110989 LONSER RUSSELL BOARD MEMBER 1.00 40.00 X 0 1403649 141917 LUKE WHITNEY PHYSICIAN 1.00 40.00 X 0 586650 64865 MALLAMPALLI RAMA BOARD MEMBER 1.00 40.00 X 0 739802 102374 MCQUAID DAVID CEO, HEALTH SYSTEM 1.00 40.00 X 0 913878 772282 MOORE AMY BOARD MEMBER 1.00 40.00 X 0 737737 113791 MOROI SAYOKO BOARD MEMBER 1.00 40.00 X 0 585201 78283 NAIR SHALINA BOARD MEMBER 1.00 40.00 X 0 288181 51268 NEEDLEMAN BRADLEY BOARD MEMBER 1.00 40.00 X 0 567254 116005 PANDHARIPANDE PARI BOARD MEMBER 1.00 40.00 X 0 50108 7041 PAPADAKIS MICHAEL BOARD MEMBER 1.00 40.00 X 0 730421 104958 PAWLIK TIMOTHY SECRETARY/TREASURER 1.00 40.00 X X 0 1337151 110429 PAZ HAROLD BOARD MEMBER 1.00 40.00 X 0 1740813 348517 PHAN KINH LUAN BOARD MEMBER 1.00 40.00 X 0 513209 89271 ROCCO JAMES BOARD MEMBER 1.00 40.00 X 0 944245 123934 SEGAL BENJAMIN BOARD MEMBER 1.00 40.00 X 0 615956 113431 THOMAS ANDREW BOARD MEMBER / CMO 1.00 40.00 X 0 788077 95419 CHUDZIK DEBORAH SENIOR DIRECTOR OF FINANCE 40.00 1.00 X 0 168630 43996 FORREST L ARICK PRESIDENT 1.00 40.00 X 0 861298 102351 GOERLITZ RYAN CFO (THROUGH 8/2021) 40.00 1.00 X 0 348039 66849 SHARP KYLE EXECUTIVE DIRECTOR 40.00 1.00 X 0 448217 73483 ELDER JAMES BRADLEY PHYSICIAN 1.00 40.00 X 0 1404757 143365 MOKADAM NAHUSH BOARD MEMBER 1.00 40.00 X 0 914412 114164 PREVEDELLO DANIEL PHYSICIAN 1.00 40.00 X 0 1133877 122031 TANDON AMIT PHYSICIAN 1.00 40.00 X 0 1186583 95660 WHISTON BRYAN PHYSICIAN 1.00 40.00 X 0 1095658 110429 0 31795100 5737417 0 0 1 0 VISION RADIOLOGY PLLC 2825 OAK LAWN AVE 192749 DALLAS TX 75219 CONSULTING SERVICES 1282425 TAFT STETTINIUS & HOLLISTER LLP 65 EAST STATE ST SUITE 1000 COLUMBUS OH 43215 LEGAL SERVICES 763865 MILL RUN INVESTORS LLC 101 OLD SHORT HILLS RD STE PH1 WEST ORANGE NJ 07052 RENTAL SPACE 605034 NATIONWIDE CHILDRENS HOSPITAL INC 700 CHILDRENS DR COLUMBUS OH 43205 LABORATORY SERVICES 519006 DELL MARKETING LP 1 DELL WAY ROUND ROCK TX 78682 PROFESSIONAL AND EDUCATIONAL DEVELOPMENT 497187 25 11686052 11686052 NET PATIENT CARE REVENUE 900099 451205765 451205765 MEDICAL CENTER REVENUE 900099 118155264 118155264 CONTRACT REVENUE 900099 99924908 99924908 SALARY RECOVERY 900099 20987900 20987900 MISCELLANEOUS PROGRAM REVENUE 900099 13251571 13251571 11083065 11083065 714608473 672807 672807 2728256 0 2728256 2728256 2728256 109965 -109965 -109965 -109965 729585623 717336729 0 562842 6496702 6496702 30998955 26039122 4959833 443262315 372340345 70921970 3633250 3051930 581320 96511580 81069727 15441853 1363541 1145374 218167 592571 497760 94811 994478 835362 159116 35974909 30218924 5755985 143637 120655 22982 3009007 2527566 481441 345156 289931 55225 8523438 7159688 1363750 1652343 1387968 264375 987369 829390 157979 3339296 2805009 534287 16760318 14078667 2681651 9934877 8345297 1589580 792241 665482 126759 SUPPLIES 17588793 17588793 BAD DEBT - PATIENT 13842289 13842289 OTHER EXP 6459128 5425666 1033462 INCENTIVES 5284586 5284586 6395073 6395073 714885852 608441306 106444546 0 237247207 151452824 0 81916013 50834952 44905461 5083980 1203251 1197238 2746255 2983403 149822615 51411559 24753465 98411056 0 77288318 75497310 394073448 461447285 11978907 61145195 5417894 10754074 9635766 672554 275186 155342401 163689894 178747936 240163935 X 215325512 221283350 215325512 221283350 394073448 461447285 X 14699771 -8899326 157393 X X 0 1 X 1 0 X X X 1 THE OHIO STATE UNIVERSITY 316025986 5 1 6496702 0 1 6496702 0 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 1 1 X PART IV, SECTION D, LINE 3: THE UNIVERSITY APPOINTS A VOTING MAJORITY OF THE BOARD OF THE MEDICAL PRACTICE GROUP FOR PHYSICIAN FACULTY MEMBERS IN THE COLLEGES OF MEDICINE AND PUBLIC HEALTH. RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED 2090595 2090595 18554663 9211820 9342843 9292914 4820306 4472608 24112083 15348279 8763804 95772360 22031154 73741206 98411056 DUE FROM AFFILIATES 65554626 NOTES RECEIVABLE - DUE FROM OTHERS 9942684 75497310 DUE TO AFFILIATES 148123067 OBLIGATIONS - PENSION 1142095 CAPITAL LEASE OBLIGATIONS 14424732 163689894 X 697009000 -8899326 -8899326 705908326 23677297 23677297 729585623 691208000 0 691208000 23677852 23677852 714885852 PART X, LINE 2: OSUP IS A NOT-FOR-PROFIT ORGANIZATION THAT IS EXEMPT FROM INCOME TAXES UNDER SECTION 501(A) AS AN ORGANIZATION DESCRIBED IN SECTION 501(C)(3) OF THE INTERNAL REVENUE CODE (THE CODE), EXCEPT FOR TAXES ON INCOME DETERMINED TO BE UNRELATED BUSINESS TAXABLE INCOME. OSUP ASSESSES UNCERTAIN TAX POSITIONS AND HAS DETERMINED THERE WERE NO SUCH POSITIONS THAT HAVE A MATERIAL EFFECT ON THE FINANCIAL STATEMENTS. PART XI, LINE 4B - OTHER ADJUSTMENTS: OTHER TAX DIFFERENCES 23,677,297. PART XII, LINE 4B - OTHER ADJUSTMENTS: OTHER TAX DIFFERENCES 23,677,852. 0 THE OHIO STATE UNIVERSITY 1960 KENNY ROAD COLUMBUS OH 432101016 316025986 115 6496702 0 ACADEMIC ENRICHMENT 1 0 PART I, LINE 2: GRANTS MADE BY THE ORGANIZATION ARE EXCLUSIVELY GIVEN TO THE VARIOUS MEDICAL DEPARTMENTS AT THE OHIO STATE UNIVERSITY, A RELATED SECTION 115 ORGANIZATION. X X X 0 0 0 0 0 0 0 0 0 LARMORE MARK CFO, MEDICAL CENTER 0 1134930 0 388125 0 110589 0 897637 0 21270 0 2552551 0 0 PAZ HAROLD BOARD MEMBER 0 999670 0 507500 0 233643 0 332140 0 16377 0 2089330 0 0 MCQUAID DAVID CEO, HEALTH SYSTEM 0 395523 0 327103 0 191252 0 757750 0 14532 0 1686160 0 0 ELDER JAMES BRADLEY PHYSICIAN 0 591427 0 777841 0 35489 0 116768 0 26597 0 1548122 0 0 LONSER RUSSELL BOARD MEMBER 0 1028427 0 279361 0 95861 0 116506 0 25411 0 1545566 0 0 PAWLIK TIMOTHY SECRETARY/TREASURER 0 852227 0 329493 0 155431 0 83491 0 26938 0 1447580 0 0 TANDON AMIT PHYSICIAN 0 558538 0 589181 0 38864 0 66854 0 28806 0 1282243 0 0 PREVEDELLO DANIEL PHYSICIAN 0 709327 0 355406 0 69144 0 93965 0 28066 0 1255908 0 0 BRADFORD CAROL BOARD MEMBER 0 785260 0 206910 0 109966 0 93114 0 30143 0 1225393 0 0 WHISTON BRYAN PHYSICIAN 0 707720 0 310619 0 77319 0 83491 0 26938 0 1206087 0 0 FARRAR WILLIAM BOARD MEMBER 0 788855 0 193481 0 63983 0 109572 0 19279 0 1175170 0 0 CHAKRAVARTI ARNAB BOARD MEMBER 0 702847 0 203102 0 66884 0 69549 0 33335 0 1075717 0 0 ROCCO JAMES BOARD MEMBER 0 619960 0 227453 0 96832 0 83896 0 40038 0 1068179 0 0 MOKADAM NAHUSH BOARD MEMBER 0 741943 0 97500 0 74969 0 83491 0 30673 0 1028576 0 0 GLASSMAN ANDREW BOARD MEMBER 0 682655 0 152234 0 77415 0 90647 0 22997 0 1025948 0 0 LEE CHERYL VICE PRESIDENT 0 665442 0 178120 0 61120 0 83896 0 27093 0 1015671 0 0 FORREST L ARICK PRESIDENT 0 622359 0 190557 0 48382 0 81618 0 20733 0 963649 0 0 THOMAS ANDREW BOARD MEMBER / CMO 0 648211 0 103837 0 36029 0 67382 0 28037 0 883496 0 0 LANDON MARK BOARD MEMBER 0 501334 0 153329 0 96715 0 86197 0 18347 0 855922 0 0 MOORE AMY BOARD MEMBER 0 558501 0 143100 0 36136 0 83896 0 29895 0 851528 0 0 MALLAMPALLI RAMA BOARD MEMBER 0 489355 0 144019 0 106428 0 72686 0 29688 0 842176 0 0 PAPADAKIS MICHAEL BOARD MEMBER 0 576906 0 122002 0 31513 0 76286 0 28672 0 835379 0 0 HARTER RONALD BOARD MEMBER 0 503860 0 88575 0 55432 0 75659 0 29347 0 752873 0 0 CATERINO JEFF BOARD MEMBER 0 425848 0 135216 0 47516 0 89664 0 35122 0 733366 0 0 SEGAL BENJAMIN BOARD MEMBER 0 437725 0 124999 0 53232 0 90167 0 23264 0 729387 0 0 FRANKEL WENDY BOARD MEMBER 0 399319 0 107751 0 82202 0 74125 0 31132 0 694529 0 0 NEEDLEMAN BRADLEY BOARD MEMBER 0 513972 0 19207 0 34075 0 81647 0 34358 0 683259 0 0 KING MARK BOARD MEMBER (THROUGH 12/21) 0 329214 0 85792 0 131637 0 83942 0 39193 0 669778 0 0 MOROI SAYOKO BOARD MEMBER 0 428232 0 114669 0 42300 0 70149 0 8134 0 663484 0 0 LUKE WHITNEY PHYSICIAN 0 413978 0 79177 0 93495 0 55369 0 9496 0 651515 0 0 PHAN KINH LUAN BOARD MEMBER 0 336026 0 108680 0 68503 0 63553 0 25718 0 602480 0 0 ANDERSON JAY BOARD MEMBER 0 470184 0 0 0 56535 0 50177 0 13312 0 590208 0 0 EXLINE MATTHEW BOARD MEMBER 0 382245 0 57799 0 21198 0 46407 0 28422 0 536071 0 0 SHARP KYLE EXECUTIVE DIRECTOR 0 305605 0 98680 0 43932 0 60200 0 13283 0 521700 0 0 ADKINS ERIC BOARD MEMBER 0 251141 0 40914 0 103220 0 59973 0 31704 0 486952 0 0 GOERLITZ RYAN CFO (THROUGH 8/2021) 0 254380 0 66037 0 27622 0 38082 0 28767 0 414888 0 0 FREIMER MIRIAM BOARD MEMBER 0 217157 0 43742 0 72672 0 49178 0 28674 0 411423 0 0 NAIR SHALINA BOARD MEMBER 0 161551 0 3179 0 123451 0 40766 0 10502 0 339449 0 0 DUNGAN KATHLEEN BOARD MEMBER 0 205193 0 10728 0 42911 0 32243 0 29954 0 321029 0 0 CHUDZIK DEBORAH SENIOR DIRECTOR OF FINANCE 0 141438 0 27192 0 0 0 25792 0 18204 0 212626 0 0 A COUNTY OF FRANKLIN OHIO 316400067 2013-05-01 15381000 REFINANCE ORIGINAL FINANCE BUILDING PROJECTS AND INFORMATION SYSTEMS 0 0 0 A 1118308 15381000 86000 15381000 2013 1 0 1 1 A 0 0 0 0 0 0 0 A 0 0 0 0 0 0 0 0 1 A 1 FORM 990, PART VI, SECTION B, LINE 11B THE PROCESS OF REVIEWING THE FORM 990 ENTAILS A DETAILED REVIEW BY THE ORGANIZATION'S ACCOUNTING DEPARTMENT AND CHIEF FINANCIAL OFFICER. THE GOVERNING BODY DISCUSSES THE DOCUMENT AT THE FINANCE COMMITTEE OF THE BOARD AS IT IS ULTIMATELY FILED WITH THE IRS. FORM 990, PART VI, SECTION B, LINE 12C THE BOARD OF DIRECTORS, OFFICERS AND STAFF OF OHIO STATE UNIVERSITY PHYSICIANS, INC. ("OSUP") DEAL WITH A VARIETY OF ISSUES INVOLVING OSUP'S CLINICAL SERVICES AND RELATED BUSINESS ACTIVITIES. OSUP IS WELL SERVED BY THE FACT THAT MANY OF ITS EMPLOYEES WHO ARE INVOLVED IN POLICY DEVELOPMENT AND IMPLEMENTATION, OR OTHERWISE MAY HAVE A ROLE IN BUSINESS OR CLINICAL DECISION-MAKING FOR OSUP, HAVE DIVERSE INTERESTS AND ARE INVOLVED IN A NUMBER OF PROFESSIONAL AND BUSINESS ACTIVITIES OUTSIDE THE ORGANIZATION. THIS INTEREST AND INVOLVEMENT ENHANCE THE EXPERTISE, WHICH THESE INDIVIDUALS BRING TO THE VARIOUS ROLES THEY FILL IN REPRESENTING OSUP. ON OCCASION, SITUATIONS MAY EXIST IN WHICH AN INDIVIDUAL SERVING OSUP IN AN ELECTED OR APPOINTED POSITION OR AS AN EMPLOYEE, HAS SOME OUTSIDE INTEREST IN AN ENTITY DOING BUSINESS WITH OSUP OR COMPETING WITH OSUP WHICH WOULD CONSTITUTE A CONFLICT OF INTEREST OR WHICH COULD BE PERCEIVED AS CONSTITUTING A CONFLICT OF INTEREST. GENERALLY, A CONFLICT OF INTEREST COULD BE SAID TO EXIST WHEN INDIVIDUALS HAVE MATERIAL INTERESTS OUTSIDE OSUP WHICH COULD INFLUENCE THEM OR COULD BE PERCEIVED AS INFLUENCING THEM TO ACT CONTRARY TO THE INTERESTS OF OSUP AND FOR THEIR OWN PERSONAL BENEFIT. THE PURPOSE OF THE CONFLICT OF INTEREST POLICY IS TO PROTECT BOTH THE INDIVIDUAL EMPLOYEE AND OSUP, AS A CORPORATION, WHEN OSUP IS CONTEMPLATING ENTERING INTO A BUSINESS TRANSACTION OR OTHER ARRANGEMENT THAT MIGHT BENEFIT THE PRIVATE INTEREST OF A MEMBER OF THE BOARD OF DIRECTORS, AN OFFICER, OR A MEMBER OF THE STAFF OF OSUP. THIS POLICY APPLIES TO THE MEMBERS OF THE BOARD OF DIRECTORS, TRUSTEES, EMPLOYED PHYSICIANS, INDEPENDENT CONTRACTORS AND STAFF OF OSUP (EACH, AN "ASSOCIATE"). IT IS EACH ASSOCIATE'S OBLIGATION TO DISCLOSE ANY ACTUAL OR PERCEIVED CONFLICT OF INTEREST ON A WRITTEN DISCLOSURE STATEMENT ATTACHED TO THIS POLICY. IF ASSOCIATES ARE UNSURE AS TO WHETHER THEIR ACTIVITIES ARE A CONFLICT OF INTEREST, THEY ARE ADVISED TO ERR ON THE SIDE OF CAUTION AND DISCLOSE THE POTENTIAL FOR SUCH. IF THE INDIVIDUAL IS UNWILLING TO DISCLOSE THE DETAILS GIVING RISE TO THE CONFLICT OF INTEREST, HE OR SHE SHOULD DISCLOSE THE FACT OF THE CONFLICT AND WITHDRAW FROM THE SITUATION CONCERNED. ASSOCIATES REVIEW THE OSUP CONFLICT OF INTEREST POLICY AND COMPLETE THE ATTACHED "CONFLICT OF INTEREST DISCLOSURE STATEMENT" FOR OSUP. THIS PROCESS IS COMPLETED, INITIALLY UPON EMPLOYMENT AND ANNUALLY, AND ALSO WHEN A POTENTIAL CONFLICT OF INTEREST SITUATION ARISES. NOTIFICATION OF A POTENTIAL -ACTUAL OR PERCEIVED- CONFLICT OF INTEREST INVOLVING AN OSUP ASSOCIATE OR ANOTHER ASSOCIATE KNOWN TO THE OSUP ASSOCIATE SHOULD BE REPORTED TO THE INDIVIDUAL'S DIRECT SUPERVISOR. ALL DISCLOSURE STATEMENTS SHOULD INCLUDE THE COMPANY/INDIVIDUALS INVOLVED, THE NATURE AND EXTENT OF WORK/RELATIONSHIP AND AN EXPLANATION OF THE POTENTIAL CONFLICT. OCCASIONALLY, INFORMATION BEING DISCLOSED COULD BE SENSITIVE IN NATURE AND SHOULD BE HANDLED WITH TACT AND A REASONABLE EFFORT MADE TO KEEP IT CONFIDENTIAL. THIRD PARTIES MAY RAISE CONCERN OF POSSIBLE CONFLICTS OF INTEREST, IF THERE ARE REASONABLE AND SUBSTANTIAL GROUNDS FOR SUCH A CONFLICT TO EXIST. THE SERIOUS NATURE OF THIRD PARTY DISCLOSURES MUST BE EMPHASIZED TO AVOID FRIVOLOUS OR MISCHIEVOUS ALLEGATIONS. THE NOTIFICATION SHOULD BE TAKEN TO THE PERSON WITH RESPONSIBILITY FOR THE ISSUE OR AREA (USUALLY THE DIRECT SUPERVISOR). ASSOCIATES WHO REFUSE TO TAKE THE NECESSARY STEPS TO RESOLVE THE CONFLICT IN ACCORDANCE WITH THIS POLICY MAY BE SUBJECT TO DISCIPLINARY ACTION UP TO AND INCLUDING TERMINATION OF EMPLOYMENT. DEPENDING ON THE SEVERITY OF CONFLICT, LEGAL ACTION MAY BE NECESSARY. THE RESPONSE TO A DISCLOSURE OF A CONFLICT OF INTEREST SHOULD BE APPROPRIATE TO THE CIRCUMSTANCES. NOT ALL RELATIONSHIPS DESCRIBED IN A DISCLOSURE STATEMENT CONSTITUTE AN ACTUAL CONFLICT OF INTEREST. ADDITIONALLY, THE EXISTENCE OF A CONFLICT OR A POTENTIAL CONFLICT DOES NOT NECESSARILY IMPLY THAT THE ACTIVITY OR RELATIONSHIP SHOULD CEASE. THE DIRECTOR OF COMPLIANCE AND RISK MANAGMENT AND THE GOVERNANCE AND ETHICS COMMITTEE OF THE OSUP BOARD MONITOR OUR COMPLIANCE PROGRAM. THE PRESIDENT OF THE BOARD OF OSUP CHAIRS THE GOVERNANCE AND ETHICS COMMITTEE. THESE COMMITTEE'S ARE RESPONSIBLE FOR REVIEWING ANY POTENTIAL CONFLICT TO DETERMINE IF ONE EXISTS. IF A CONFLICT OF INTEREST IS FOUND TO EXIST, THE ACTION OR DECISION BEING AFFECTED SHOULD BE REVIEWED AND THE DECISION DOCUMENTED IN WRITING BY THE PRACTICE ADMINISTRATOR/COO IN COLLABORATION WITH THE OSUP HUMAN RESOURCES DEPARTMENT. ALL DOCUMENTATION SHOULD BE MAINTAINED IN THE ASSOCIATE'S PERSONNEL FILE AND DEPARTMENT FILE. IF THE INDIVIDUAL CONCERNED DOES NOT AGREE WITH THE DECISION HE OR SHE MAY APPEAL THE DECISION TO THE NEXT LEVEL OF MANAGEMENT AS NECESSARY. FORM 990, PART VI, SECTION B, LINE 15 ALL SALARIED POSITIONS WITHIN OSUP ARE REVIEWED ANNUALLY WITH BENCHMARK DATA FROM THE ASSOCIATION OF ACADEMIC MEDICAL CENTER'S DATA TO INSURE REASONABLENESS. FORM 990, PART VI, SECTION C, LINE 19 THE ORGANIZATION MAKES ITS DOCUMENTS AVAILABLE THROUGH ITS LEGAL COUNSEL FORM 990, PART XI, LINE 9: ADOPTION OF GASB NO. 87 157,393. FORM 990, PART XII, LINE 2C THE PROCESS HAS NOT CHANGED FROM THE PRIOR YEAR. 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