2022-05-10T07:52:08-05:00 2021-06-30 351178661 BLUE & CO LLC 9200 WORTHINGTON RD STE 200 WESTERVILLE OH 43082 990 2020-07-01 311447726 OHIO STATE UNIVERSITY PHYSICIANS INC OHIO 6147847800 700 ACKERMAN RD STE 6000 NO 6000 COLUMBUS OH 43202 L ARICK FORREST MD PRESIDENT 6149473700 2022-05-09 1 L ARICK FORREST MD 999009999 ANGELA N CRAWFORD CPA P00573197 6148852583 2022-05-09 3 AAL1 IAL1 2020 2022-09-23 18:48:47Z L ARICK FORREST MD 700 ACKERMAN RD STE 6000 NO 6000 COLUMBUS OH 43202 658825437 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. 30 1 1445 0 0 0 0 0 603989617 656851996 934050 -12928 1892666 1918623 606816333 658757691 7917409 15050804 0 0 483038853 524292300 0 0 0 107667062 109748162 598623324 649091266 8193009 9666425 280155333 394073448 74494188 178747936 205661145 215325512 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 119634568 15050804 20578781 ACADEMIC ENRICHMENT TO SUPPORT THE EDUCATIONAL AND RESEARCH PROGRAMS OF THE OHIO STATE UNIVERSITY COLLEGE OF MEDICINE. 336756803 153798722 SUPPORT PATIENTS THAT ARE A PART OF THE MEDICARE /MEDICAID PROGRAMS BY ACCEPTING PAYMENTS FOR SERVICES THAT ARE LESS THAN COST. 7463057 CHARITY CARE TO SUPPORT THE CLINICAL MISSION OF OSU INCLUDING PROVIDING CARE TO INDIVIDUALS THAT MAY NOT BE ABLE TO AFFORD CARE. 85270510 484393116 ALL OTHER PROGRAM SERVICES INCLUDING CLINICAL CARE FOR PATIENTS TYPICAL OF AN ACADEMIC PHYSICIAN OFFICE PRACTICE. 85270510 484393116 549124938 1 0 0 0 0 0 0 0 0 0 1 0 0 1 1 1 0 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 84 0 1 1445 1 0 0 0 0 0 0 0 0 0 0 0 0 X 30 1 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 PAWLIK TIMOTHY SECRETARY/TREASURER 1.00 40.00 X X 0 1089568 112951 LEE CHERYL VICE PRESIDENT 1.00 40.00 X X 0 862479 106882 ADKINS ERIC BOARD MEMBER 1.00 40.00 X 0 356817 81927 BRADFORD CAROL BOARD MEMBER 1.00 40.00 X 0 226802 34791 CATERINO JEFF BOARD MEMBER 1.00 40.00 X 0 554011 111516 CHAKRAVARTI ARNAB BOARD MEMBER 1.00 40.00 X 0 935567 100736 DUNGAN KATHLEEN BOARD MEMBER 1.00 40.00 X 0 226414 56108 EXLINE MATTHEW BOARD MEMBER 1.00 40.00 X 0 373631 62638 FARRAR WILLIAM BOARD MEMBER 1.00 40.00 X 0 1071615 128123 FRANKEL WENDY BOARD MEMBER 1.00 40.00 X 0 568605 101248 FREIMER MIRIAM BOARD MEMBER 1.00 40.00 X 0 331634 77595 GLASSMAN ANDREW BOARD MEMBER 1.00 40.00 X 0 865474 99723 HARTER RONALD BOARD MEMBER 1.00 40.00 X 0 687062 108469 KING MARK BOARD MEMBER 1.00 40.00 X 0 611244 112910 LANDON MARK BOARD MEMBER 1.00 40.00 X 0 745108 105856 LARMORE MARK CFO, MEDICAL CENTER 1.00 40.00 X 0 1124815 118006 LONSER RUSSELL BOARD MEMBER 1.00 40.00 X 0 1226104 124539 MCQUAID DAVID CEO, HEALTH SYSTEM 1.00 40.00 X 0 1227967 134732 MALLAMPALLI RAMA BOARD MEMBER 1.00 40.00 X 0 699749 95519 MOORE AMY BOARD MEMBER 1.00 40.00 X 0 736687 113991 MOROI SAYOKO BOARD MEMBER 1.00 40.00 X 0 515352 78423 MYSIW W JERRY BOARD MEMBER 1.00 40.00 X 0 453664 85166 NAIR SHALINA TERM BEGAN 321 BOARD MEMBER 1.00 40.00 X 0 228972 40839 NEEDLEMAN BRADLEY BOARD MEMBER 1.00 40.00 X 0 568373 118253 OLAYIWOLA JACQUELINE NWANDO BOARD MEMBER- TERM ENDED 3/21 1.00 40.00 X 0 465710 84137 PAPADAKIS MICHAEL BOARD MEMBER 1.00 40.00 X 0 876285 111560 PAZ HAROLD BOARD MEMBER 1.00 40.00 X 0 2322468 201874 PHAN KINH LUAN BOARD MEMBER 1.00 40.00 X 0 504121 84995 ROCCO JAMES BOARD MEMBER 1.00 40.00 X 0 925793 117552 THOMAS ANDREW BOARD MEMBER / CMO 1.00 40.00 X 0 729586 93290 SEGAL BENJAMIN BOARD MEMBER 1.00 40.00 X 0 609901 103083 FORREST L ARICK PRESIDENT 1.00 40.00 X 0 830377 100199 SHARP KYLE EXECUTIVE DIRECTOR 40.00 1.00 X 0 427267 79293 GOERLITZ RYAN CFO 40.00 1.00 X 0 323071 55231 PREVEDELLO DANIEL PHYSICIAN 1.00 40.00 X 0 998897 107203 ELDER JAMES BRADLEY PHYSICIAN 1.00 40.00 X 0 1208130 123967 TANDON AMIT PHYSICIAN 1.00 40.00 X 0 979612 93508 WASHBURN KEN PHYSICIAN 1.00 40.00 X 0 1003335 108333 WHITSON BRYAN PHYSICIAN 1.00 40.00 X 0 1207461 106429 0 29699728 3881595 78 0 1 0 TAFT STETTINIUS & HOLLISTER LLP 65 EAST STATE ST SUITE 1000 COLUMBUS OH 43215 LEGAL SERVICES 650661 MEDSPEED LLC 140 INDUSTRIAL DR ELMHURST IL 60126 MEDICAL COURIER SERVICE 376535 CENTERPOINT CONSTRUCTION SERVICES LLC TWO MIRANOVA PLACE STE 900 COLUMBUS OH 43215 CONSTRUCTION 345978 SELLERS DORSEY & ASSOCIATES LLC 1635 MARKET STREET SUITE 301 PHILADELPHIA PA 19103 CONSULTING 239826 REDI-CLEAN ENTERPRISES LLC PO BOX 1205 HILLARD OH 43026 CLEANING SERVICE 195173 10 NET PATIENT CARE REVENUE 900099 435468484 435468484 MEDICAL CENTER REVENUE 900099 101373967 101373967 CONTRACT REVENUE 900099 87008822 87008822 MEDICAL & TECHNICAL DIRECTION 900099 15203929 15203929 SALARY RECOVERY 900099 12128849 12128849 5667945 5667945 656851996 54818 54818 1901527 0 1901527 1901527 1901527 67746 -67746 -67746 -67746 MISCELLANEOUS 900099 17096 17096 17096 658757691 658770619 0 -12928 15050804 15050804 27644447 23221335 4423112 402498270 338098547 64399723 6672920 5605253 1067667 86296627 72489167 13807460 1180036 991230 188806 943798 792790 151008 758481 637124 121357 32640093 27417678 5222415 329870 277091 52779 19044605 15997468 3047137 2702727 2270291 432436 10110145 8492522 1617623 393181 330272 62909 603508 506947 96561 300270 252227 48043 18228964 15312330 2916634 3121546 2622099 499447 568469 477514 90955 OTHER EXP 10751595 9031339 1720256 BAD DEBT - PATIENT 9250910 9250910 649091266 549124938 99966328 0 169008631 237247207 13852058 0 40889392 50834952 771223 1203251 2498085 2746255 61907897 37154432 25576485 24753465 27559459 77288318 280155333 394073448 9998333 11978907 11339685 10754074 836656 672554 52319514 155342401 74494188 178747936 X 205661145 215325512 205661145 215325512 280155333 394073448 9666425 -2058 0 X X 0 1 X 1 0 X X X 1 THE OHIO STATE UNIVERSITY 316025986 5 1 137863532 0 1 137863532 0 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 0 X 2090595 2090595 18553217 8755472 9797745 9292914 4046559 5246355 31971171 24352401 7618770 24753465 DUE FROM AFFILIATES 70513621 OTHER ASSETS 26990 NOTES RECEIVABLE - DUE FROM OTHERS 6747707 77288318 DUE TO AFFILIATES 132276036 OBLIGATIONS - PENSION 1073593 OTHER CURRENT LIABILITIES 11801430 MEDICARE ADVANCE PAYMENT PROGRAM 10191342 155342401 X PART X, LINE 2: OSUP IS A NOT-FOR-PROFIT CORPORATION AND HAS BEEN RECOGNIZED AS TAX EXEMPT PURSUANT TO SECTION 501(C)(3) OF THE INTERNAL REVENUE CODE. UNDER A NOW DISREGARDED LEGAL ENTITY NAME, OSUP OBTAINED ITS DETERMINATION LETTER ON OCTOBER 21, 1996, IN WHICH THE INTERNAL REVENUE SERVICE STATED THAT THE ORGANIZATION WAS IN COMPLIANCE WITH APPLICABLE REQUIREMENTS OF THE INTERNAL REVENUE CODE. OSUP MANAGEMENT AND LEGAL COUNSEL BELIEVE THAT THE ORGANIZATION IS CURRENTLY DESIGNED AND BEING OPERATED IN COMPLIANCE WITH THE APPLICABLE REQUIREMENTS OF THE INTERNAL REVENUE CODE. OSUP HAS DETERMINED NO PROVISION FOR INCOME TAXES IS NECESSARY NOR HAS BEEN INCLUDED IN THE ACCOMPANYING CONSOLIDATED FINANCIAL STATEMENTS. ANY UNRELATED BUSINESS INCOME IS TAXABLE. 0 THE OHIO STATE UNIVERSITY 1960 KENNY ROAD COLUMBUS OH 432101016 316025986 115 15050804 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 PAZ HAROLD BOARD MEMBER 0 1347727 0 788000 0 186741 0 182746 0 19128 0 2524342 0 0 MCQUAID DAVID CEO, HEALTH SYSTEM 0 853862 0 284438 0 89667 0 108017 0 26715 0 1362699 0 0 LONSER RUSSELL BOARD MEMBER 0 937163 0 194275 0 94666 0 101492 0 23047 0 1350643 0 0 ELDER JAMES BRADLEY PHYSICIAN 0 734189 0 439057 0 34884 0 100968 0 22999 0 1332097 0 0 WHITSON BRYAN PHYSICIAN 0 681914 0 450473 0 75074 0 83086 0 23343 0 1313890 0 0 LARMORE MARK CFO, MEDICAL CENTER 0 770304 0 259530 0 94981 0 99382 0 18624 0 1242821 0 0 PAWLIK TIMOTHY SECRETARY/TREASURER 0 806836 0 214032 0 68700 0 83086 0 29865 0 1202519 0 0 FARRAR WILLIAM BOARD MEMBER 0 781332 0 227475 0 62808 0 110238 0 17885 0 1199738 0 0 WASHBURN KEN PHYSICIAN 0 696911 0 210320 0 96104 0 83086 0 25247 0 1111668 0 0 PREVEDELLO DANIEL PHYSICIAN 0 717646 0 226541 0 54710 0 84204 0 22999 0 1106100 0 0 TANDON AMIT PHYSICIAN 0 833112 0 107243 0 39257 0 67057 0 26451 0 1073120 0 0 ROCCO JAMES BOARD MEMBER 0 622691 0 209228 0 93874 0 83491 0 34061 0 1043345 0 0 CHAKRAVARTI ARNAB BOARD MEMBER 0 667189 0 202954 0 65424 0 69144 0 31592 0 1036303 0 0 PAPADAKIS MICHAEL BOARD MEMBER 0 573401 0 272002 0 30882 0 87661 0 23899 0 987845 0 0 LEE CHERYL VICE PRESIDENT 0 629553 0 171865 0 61061 0 83491 0 23391 0 969361 0 0 GLASSMAN ANDREW BOARD MEMBER 0 647667 0 141692 0 76115 0 83520 0 16203 0 965197 0 0 FORREST L ARICK PRESIDENT 0 619920 0 162251 0 48206 0 82784 0 17415 0 930576 0 0 LANDON MARK BOARD MEMBER 0 495770 0 153797 0 95541 0 85341 0 20515 0 850964 0 0 MOORE AMY BOARD MEMBER 0 535989 0 126360 0 74338 0 105616 0 8375 0 850678 0 0 THOMAS ANDREW BOARD MEMBER / CMO 0 590786 0 104029 0 34771 0 63149 0 30141 0 822876 0 0 HARTER RONALD BOARD MEMBER 0 488980 0 133644 0 64438 0 82602 0 25867 0 795531 0 0 MALLAMPALLI RAMA BOARD MEMBER 0 486041 0 113280 0 100428 0 69170 0 26349 0 795268 0 0 KING MARK BOARD MEMBER 0 488141 0 65198 0 57905 0 79836 0 33074 0 724154 0 0 SEGAL BENJAMIN BOARD MEMBER 0 430513 0 123676 0 55712 0 88851 0 14232 0 712984 0 0 NEEDLEMAN BRADLEY BOARD MEMBER 0 504041 0 24045 0 40287 0 88059 0 30194 0 686626 0 0 FRANKEL WENDY BOARD MEMBER 0 395594 0 92034 0 80977 0 73720 0 27528 0 669853 0 0 CATERINO JEFF BOARD MEMBER 0 434491 0 81958 0 37562 0 82074 0 29442 0 665527 0 0 MOROI SAYOKO BOARD MEMBER 0 386904 0 51670 0 76778 0 71626 0 6797 0 593775 0 0 PHAN KINH LUAN BOARD MEMBER 0 332932 0 102280 0 68909 0 62722 0 22273 0 589116 0 0 OLAYIWOLA JACQUELINE NWANDO BOARD MEMBER- TERM ENDED 3/21 0 292661 0 120177 0 52872 0 61168 0 22969 0 549847 0 0 MYSIW W JERRY BOARD MEMBER 0 315639 0 73876 0 64149 0 58331 0 26835 0 538830 0 0 SHARP KYLE EXECUTIVE DIRECTOR 0 299878 0 84022 0 43367 0 59500 0 19793 0 506560 0 0 ADKINS ERIC BOARD MEMBER 0 284733 0 8437 0 63647 0 54308 0 27619 0 438744 0 0 EXLINE MATTHEW BOARD MEMBER 0 328078 0 35979 0 9574 0 37687 0 24951 0 436269 0 0 FREIMER MIRIAM BOARD MEMBER 0 215121 0 43796 0 72717 0 49002 0 28593 0 409229 0 0 GOERLITZ RYAN CFO 0 234684 0 61409 0 26978 0 30562 0 24669 0 378302 0 0 DUNGAN KATHLEEN BOARD MEMBER 0 180424 0 4981 0 41009 0 28864 0 27244 0 282522 0 0 NAIR SHALINA TERM BEGAN 321 BOARD MEMBER 0 195904 0 0 0 33068 0 32408 0 8431 0 269811 0 0 BRADFORD CAROL BOARD MEMBER 0 186589 0 0 0 40213 0 30800 0 3991 0 261593 0 0 A COUNTY OF FRANKLIN OHIO 316400067 2013-05-01 15381000 REFINANCE ORIGINAL FINANCE BUILDING PROJECTS AND INFORMATION SYSTEMS 0 0 0 A 585611 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 XII, LINE 2C THE PROCESS HAS NOT CHANGED FROM THE PRIOR YEAR. 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