2021-11-15T23:33:06-06:00 2020-12-31 990 2020-01-01 362167779 ADVOCATE HEALTH CARE NETWORK ADVO 4142991862 3075 HIGHLAND PARKWAY STE 600 DOWNERS GROVE IL 60515 RACHEL HALVERSON VP TAX & ACCTG SVCS 4142991862 2021-11-15 RACHEL HALVERSON 999009999 2 AAL1 IAL1 2020 2022-09-23 18:48:47Z JAMES SKOGSBERGH 3075 HIGHLAND PARKWAY STE 600 DOWNERS GROVE IL 60515 191941114 0 9395 X WWW.ADVOCATEHEALTH.COM X 1923 IL THE MISSION OF ADVOCATE HEALTH CARE IS TO SERVE THE HEALTH NEEDS OF INDIVIDUALS, FAMILIES AND COMMUNITIES THROUGH A PHILOSOPHY ROOTED IN OUR FUNDAMENTAL UNDERSTANDING OF HUMAN BEINGS AS CREATED IN THE IMAGE OF GOD. 18 17 0 0 0 0 0 175000000 0 0 32597274 16941114 0 0 32597274 191941114 10000000 109500000 0 0 2913 0 0 0 0 376 75 10003289 109500075 22593985 82441039 499272175 575387886 0 0 499272175 575387886 THE MISSION OF ADVOCATE HEALTH CARE IS TO SERVE THE HEALTH NEEDS OF INDIVIDUALS, FAMILIES AND COMMUNITIES THROUGH A WHOLISTIC PHILOSOPHY ROOTED IN OUR FUNDAMENTAL UNDERSTANDING OF HUMAN BEINGS AS CREATED IN THE IMAGE OF GOD. 0 0 109500075 109500000 ADVOCATE HEALTH CARE NETWORK PROVIDES LEADERSHIP CONTROL AND SUPPORT TO ADVOCATE HEALTH AND HOSPITALS CORPORATION, ADVOCATE HOME HEALTH SERVICES, INC., ADVOCATE CHARITABLE FOUNDATION, ADVOCATE NORTH SIDE HEALTH NETWORK, MERIDIAN HOSPICE, ADVOCATE CONDELL MEDICAL CENTER, ADVOCATE SHERMAN HOSPITAL AND SHERMAN WEST COURT. 109500075 1 1 0 0 0 0 0 0 0 0 0 1 0 0 0 0 0 1 0 0 0 0 0 0 0 0 0 1 0 1 0 0 0 0 0 0 0 0 0 0 0 0 1 1 1 0 0 0 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 X 18 17 1 0 0 0 0 0 1 1 1 0 0 1 1 1 1 1 1 0 0 0 X ADVOCATE AURORA HEALTH 6309296057 3075 HIGHLAND PARKWAY SUITE 600 DOWNERS GROVE IL 60515 CLARENCE NIXON JR PHD DIRECTOR 1.00 1.00 X 0 15500 0 DAVID ANDERSON DIRECTOR 1.00 1.00 X 0 111333 0 GAIL D HASBROUCK DIRECTOR 1.00 1.00 X 0 0 37 JAMES SKOGSBERGH PRESIDENT & CEO, DIRECTOR 1.00 55.00 X X 0 6197416 622527 JOHN TIMMER DIRECTOR 1.00 1.00 X 0 103333 0 LYNN CRUMP-CAINE DIRECTOR 1.00 1.00 X 0 111333 0 MARK HARRIS DIRECTOR 1.00 1.00 X 0 88000 0 MICHELE BAKER RICHARDSON CHAIRPERSON, DIRECTOR 1.00 1.00 X X 0 126333 0 REV DR NATHANIEL EDMOND DIRECTOR 1.00 1.00 X 0 8000 0 REV JUSTO GONZALEZ II DIRECTOR 1.00 1.00 X 0 4000 0 K RICHARD JAKLE VICE CHAIRPERSON OF BOARD, DIRECTOR 1.00 1.00 X X 0 111333 0 RON GREENE DIRECTOR 1.00 1.00 X 0 3000 0 EMELIE ILARDE MD DIRECTOR 1.00 1.00 X 0 8000 0 EDWARD MALYSIAK DIRECTOR 1.00 1.00 X 0 8000 0 BISHOP YEHIEL CURRY DIRECTOR 1.00 0.00 X 0 8000 0 ULYSSES BURLEY III DIRECTOR 1.00 1.00 X 0 4000 0 DR DAISY VARUGHESE DIRECTOR 1.00 1.00 X 0 4000 0 REV MOLLY CARLSON DIRECTOR 1.00 0.00 X 0 0 0 DOMINIC J NAKIS TREASURER 1.00 55.00 X 0 2001577 222808 JAMES DOHENY ASSISTANT TREASURER 1.00 55.00 X 0 600229 93283 JAMES SLINKMAN ASSISTANT SECRETARY 1.00 55.00 X 0 465570 85939 LESLIE LENZO ASSISTANT TREASURER 1.00 55.00 X 0 906168 103790 MICHAEL GREBE ASSISTANT SECRETARY 1.00 55.00 X 0 1181024 131982 MICHAEL KERNS ASSISTANT SECRETARY 1.00 55.00 X 0 524766 90542 MIKE LAPPIN SECRETARY 1.00 55.00 X 0 1579916 188398 NAN NELSON ASSISTANT TREASURER 1.00 55.00 X 0 815972 95664 SHELLY HART ASSISTANT SECRETARY 1.00 55.00 X 0 757127 113484 STEVE HUSER ASSISTANT TREASURER 1.00 55.00 X 0 476618 81094 GARY STUCK DO FORMER OFFICER 0.00 55.00 X 0 1114031 155668 EARL J BARNES II FORMER OFFICER 0.00 0.00 X 0 291951 37 LEE B SACKS MD FORMER OFFICER 0.00 0.00 X 0 537635 390 SUSAN CAMPBELL FORMER OFFICER 0.00 0.00 X 0 259388 4054 BRUCE D SMITH FORMER OFFICER 0.00 0.00 X 0 122721 37 BARBARA BYRNE MD FORMER OFFICER 0.00 55.00 X 0 1246693 156889 KELLY JO GOLSON FORMER OFFICER 0.00 55.00 X 0 1017777 116904 KEVIN BRADY FORMER OFFICER 0.00 55.00 X 0 1222838 163268 REV KATHIE BENDER SCHWICH FORMER OFFICER 0.00 55.00 X 0 634756 159085 SCOTT POWDER FORMER OFFICER 0.00 55.00 X 0 1115868 153106 VINCENT BUFALINO MD FORMER OFFICER 0.00 55.00 X 0 1270676 158114 WILLIAM P SANTULLI FORMER OFFICER 0.00 55.00 X 0 2706183 293486 0 27761065 3190586 0 1 1 0 0 175000000 175000000 16941114 16941114 191941114 0 0 16941114 109500000 109500000 75 75 109500075 109500075 0 0 3666998 3679689 59800000 53085000 250793950 235011162 184196490 282871163 814737 740872 499272175 575387886 0 0 0 0 X 499272175 575387886 499272175 575387886 499272175 575387886 X 82441039 -6325327 X 0 1 X 1 0 X X 9 ADV HEALTH & HOSP CORP 362169147 3 1 0 0 ADV HOME HLTH SVCS INC 362913108 10 0 0 0 ADV CHARITABLE FOUND 363297360 7 0 9500000 0 ADV NORTH SIDE HLTH NTWK 363196629 3 0 0 0 MERIDIAN HOSPICE 363158667 10 0 0 0 ADV CONDELL MED CTR 262525968 3 0 0 0 ADV SHERMAN HOSPITAL 362167920 3 0 0 0 SHERMAN WEST COURT 363725580 10 0 0 0 EVANGELICAL SERVICES CORP 363208101 10 0 0 0 9 9500000 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 1 1 X 1 1 SCHEDULE A PART VI SUPPLEMENTAL INFO- PART I, LINE 12G PART I, LINE 12G AHCN PROVIDES MANAGEMENT AND OVERSIGHT TO ITS SUPPORTED ORGANIZATIONS THROUGH ITS VARIOUS COMMITTEES. AHCN PROVIDES LEADERSHIP AND CONTROL BY REVIEWING AND APPROVING STRATEGIC PLANS AND OPERATING BUDGETS OF ITS SUPPORTED ORGANIZATIONS SO THAT THOSE ORGANIZATIONS CAN CARRY OUT THEIR MISSION TO SERVE THE HEALTH NEEDS OF INDIVIDUALS AND COMMUNITIES WITH A HIGH QUALITY, COORDINATED HEALTH CARE DELIVERY SYSTEM. IV, SECTION A, LINE 1: NOT ALL OF THE ORGANIZATIONS SUPPORTED BY AHCN ARE LISTED BY NAME, BUT THEY ARE REFERENCED IN THE ORGANIZATION'S BY-LAWS BY TYPE. THE BY-LAWS STATE THAT AHCN'S PURPOSE IS "TO PROMOTE, SUPPORT, BENEFIT, DEVELOP AND PERFORM THE FUNCTIONS OF ADVOCATE HEALTH AND HOSPITALS CORPORATION, ITS SUCCESSOR(S) AND OTHER ORGANIZATIONS DESCRIBED IN SECTIONS 509(A)(1) OR 509(A)(2) OF THE INTERNAL REVENUE CODE OF 1986, AS AMENDED (THE "CODE") (SUCH CORPORATIONS, THEIR SUCCESSORS AND OTHER ORGANIZATIONS ARE COLLECTIVELY REFERRED TO HEREIN AS THE ORGANIZATIONS"), BY OPERATING AND PROVIDING LEADERSHIP, CONTROL AND SUPPORT IN THE PROVISION OF A HIGH QUALITY, COMPREHENSIVE, COORDINATED HEALTH DELIVERY SYSTEM FOR THE BENEFIT OF THE ORGANIZATIONS." THIS ORGANIZATION HAS A HISTORIC AND CONTINUING RELATIONSHIP WITH 509(A)(1) AND 509(A)(2) ORGANIZATIONS THAT ARE PART OF THE ADVOCATE SYSTEM. PART IV, SECTION D, LINE 3: THE SUBSIDIARY SUPPORTED ORGANIZATIONS HAVE A SIGNIFICANT VOICE IN DIRECTING THE USE OF AHCN'S RESOURCES THROUGH THE BUDGETING AND FINANCIAL PLANNING PROCESS. THE OPERATING AND CAPITAL BUDGETS FOR THE PART IV, SECTION D, LINE 3 CONT. SUBSIDIARIES ARE CREATED AT A SUBSIDIARY LEVEL AND ARE THEN CONSOLIDATED INTO THE SYSTEM BUDGET. THE FINAL SYSTEM BUDGET TAKES INTO ACCOUNT THE NEEDS AND PRIORITIES OF THE VARIOUS SUBSIDIARIES IN CARRYING OUT THEIR HEALTH CARE MINISTRY. THROUGH THIS BUDGETING AND MANAGEMENT PROCESS, AHCN OBTAINS THE INPUT NECESSARY TO APPROPRIATELY ALLOCATE THE SYSTEM'S RESOURCES. THE INVESTMENT POLICY OF THE ORGANIZATION IS STRUCTURED TO ALLOW THE SYSTEM TO INVEST ITS RESOURCES TO PROVIDE THE FUNDS NECESSARY TO FUND THE NEEDS AND PRIORITIES OF THE SYSTEM. PART IV, SECTION E, LINE 3A: AHCN HAS DIRECT RIGHTS TO APPOINT THE BOARD MEMBERS OF 3 OUT OF THE 8 ORGANIZATIONS LISTED AS SUPPORTED ORGANIZATIONS ON SCHEDULE A, PART I, LINE 12G. THESE THREE ORGANIZATIONS ARE THE SOLE CORPORATE MEMBERS OF THE REMAINING LIVE ORGANIZATIONS LISTED AS SUPPORTED ORGANIZATIONS ON SCHEDULE A, PART I, LINE 11G, AND THEREFORE HAVE THE RIGHT TO APPOINT THE BOARD MEMBERS OF THEIR RESPECTIVE SUBSIDIARIES. CONSEQUENTLY, AHCN HAS INDIRECT RIGHTS TO APPOINT THE BOARD MEMBERS OF THESE 5 ORGANIZATIONS. PART IV, SECTION E, LINE 3B: THROUGH ITS VARIOUS COMMITTEES, AHCN EXERCISES A SUBSTANTIAL DEGREE OF DIRECTION OVER THE POLICIES, PROGRAMS AND ACTIVITIES OF ITS SUPPORTED ORGANIZATIONS. FOR EXAMPLE, THE PLANNING COMMITTEE APPROVES STRATEGIC PLANS AND DIRECTIONS FOR EACH SUPPORTED ORGANIZATION, THE FINANCE COMMITTEE REVIEWS AND APPROVES BUDGET AND PROCESS FOR EACH SUPPORTED ORGANIZATION, AND THE COMPENSATION COMMITTEE APPROVES ALL EXECUTIVE COMPENSATION FOR EACH SUPPORTED ORGANIZATION. IN ADDITION, THE ORGANIZATION HAS CENTRAL CONFLICT OF INTEREST AND WHISTLEBLOWER POLICIES AND PROCEDURES. RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED 0 0 INVESTMENT IN ESC 282871163 F 282871163 1 ADVOCATE CHARITABLE FOUNDATION 3075 HIGHLAND PARKWAY DOWNERS GROVE IL 60515 363297360 501(C)(3) 9500000 SUPPORT EXEMPT MISSION ADVOCATE HEALTH & HOSPITALS CORP 3075 HIGHLAND PARKWAY DOWNERS GROVE IL 60515 362169147 501(C)(3) 100000000 SUPPORT EXEMPT MISSION 2 0 X 0 0 X X X X X 1 1 0 0 0 0 0 0 0 JAMES SKOGSBERGH PRESIDENT & CEO, DIRECTOR 0 1607310 0 4480597 0 109509 0 593225 0 29302 0 6819943 0 535447 WILLIAM P SANTULLI FORMER OFFICER 0 1066673 0 1571597 0 67913 0 258437 0 35049 0 2999669 0 319972 DOMINIC J NAKIS TREASURER 0 788017 0 1151310 0 62250 0 194724 0 28084 0 2224385 0 245312 MIKE LAPPIN SECRETARY 0 721806 0 816406 0 41704 0 170220 0 18178 0 1768314 0 292557 VINCENT BUFALINO MD FORMER OFFICER 0 581376 0 639567 0 49733 0 130623 0 27491 0 1428790 0 166903 BARBARA BYRNE MD FORMER OFFICER 0 595892 0 612362 0 38439 0 131197 0 25692 0 1403582 0 160695 KEVIN BRADY FORMER OFFICER 0 557513 0 627062 0 38263 0 126912 0 36356 0 1386106 0 164039 MICHAEL GREBE ASSISTANT SECRETARY 0 540499 0 598967 0 41558 0 131982 0 0 0 1313006 0 180815 GARY STUCK DO FORMER OFFICER 0 589740 0 479142 0 45149 0 126146 0 29522 0 1269699 0 78873 SCOTT POWDER FORMER OFFICER 0 512679 0 571005 0 32184 0 117756 0 35350 0 1268974 0 150299 KELLY JO GOLSON FORMER OFFICER 0 474925 0 502705 0 40147 0 108254 0 8650 0 1134681 0 132890 LESLIE LENZO ASSISTANT TREASURER 0 579502 0 264550 0 62116 0 92380 0 11410 0 1009958 0 80332 NAN NELSON ASSISTANT TREASURER 0 482832 0 295537 0 37603 0 95664 0 0 0 911636 0 145573 SHELLY HART ASSISTANT SECRETARY 0 503641 0 221328 0 32158 0 95306 0 18178 0 870611 0 91432 REV KATHIE BENDER SCHWICH FORMER OFFICER 0 249839 0 348701 0 36216 0 70263 0 88822 0 793841 0 86952 JAMES DOHENY ASSISTANT TREASURER 0 399917 0 174832 0 25480 0 67207 0 26076 0 693512 0 55763 MICHAEL KERNS ASSISTANT SECRETARY 0 348133 0 151530 0 25103 0 59895 0 30647 0 615308 0 47983 STEVE HUSER ASSISTANT TREASURER 0 322068 0 126492 0 28058 0 68729 0 12365 0 557712 0 50708 JAMES SLINKMAN ASSISTANT SECRETARY 0 311772 0 135726 0 18072 0 54796 0 31143 0 551509 0 43451 LEE B SACKS MD FORMER OFFICER 0 0 0 358179 0 179456 0 0 0 390 0 538025 0 0 EARL J BARNES II FORMER OFFICER 0 0 0 175605 0 116346 0 0 0 37 0 291988 0 0 SUSAN CAMPBELL FORMER OFFICER 0 0 0 122952 0 136436 0 0 0 4054 0 263442 0 0 BRUCE D SMITH FORMER OFFICER 0 0 0 122721 0 0 0 0 0 37 0 122758 0 0 SCHEDULE J, PART I, LINE 4A EARL J. BARNES II, FORMER ASSISTANT SECRETARY, RECEIVED A SEVERANCE PAYMENT IN THE AMOUNT OF $116,346. SUSAN CAMPBELL, FORMER DIRECTOR, RECEIVED A SEVERANCE PAYMENT IN THE AMOUNT OF $137,500. LEE B. SACKS, FORMER CHIEF MEDICAL OFFICER, RECEIVED A SEVERANCE PAYMENT IN THE AMOUNT OF $179,809. THESE PAYMENTS HAVE ALL BEEN REPORTED IN SCHEDULE J, PART II, COLUMN (B)(III). FORM 990, PART VI, SECTION A, LINE 1 THE ORGANIZATION'S BYLAWS PROVIDE THAT THE EXECUTIVE COMMITTEE HAS AUTHORITY TO ACT ON BEHALF OF THE BOARD. THE EXECUTIVE COMMITTEE IS ACCOUNTABLE AS A BODY TO THE BOARD OF DIRECTORS. THE EXECUTIVE COMMITTEE SHALL HAVE NINE MEMBERS, CONSISTING OF THE CHAIRPERSON, THE VICE CHAIRPERSON, THE PRESIDENT, THE CHAIRPERSONS OF THE FINANCE, PLANNING, HEALTH OUTCOMES AND MISSION AND SPIRITUAL CARE COMMITTEES, AND TWO OTHER DIRECTORS. THE PAST CHAIRPERSON OF THE BOARD OF DIRECTORS MAY SERVE AS AN EX-OFFICIO MEMBER OF THE COMMITTEE, WITH VOTE. EACH OF THE EXECUTIVE COMMITTEE'S MEMBERS IS ON THE BOARD. THE SCOPE OF THE EXECUTIVE COMMITTEE'S AUTHORITY INCLUDES: (A) NOMINATE CANDIDATES FOR ELECTION AS THE CHAIRPERSON AND VICE CHAIRPERSON OF THE BOARD; (B) BE RESPONSIBLE FOR PLANNING EDUCATIONAL PROGRAMS FOR THE BOARD OF DIRECTORS; (C) CONDUCT AN EVALUATION OF THE MEMBERS OF THE BOARD OF DIRECTORS; (D) HAVE SUCH AUTHORITY AS SHALL BE DELEGATED BY THE BOARD OF DIRECTORS; AND (E) ACT ON BEHALF OF THE BOARD OF DIRECTORS BETWEEN MEETINGS. FORM 990, PART VI, SECTION A, LINE 2 AS JAMES DAN, M.D., VINCENT BUFALINO, M.D., LEE SACKS, M.D, GAIL HASBROUCK, EARL BARNES II, JAMES DOHENY, SCOTT POWDER, WILLIAM SANTULLI AND DOMINIC NAKIS ARE EITHER DIRECTORS OR OFFICERS OF WHOLLY OWNED ADVOCATE ENTITIES, THEY ARE DEEMED TO HAVE A BUSINESS RELATIONSHIP PURSUANT TO THE INSTRUCTIONS FOR FORM 990. FORM 990, PART VI, SECTION A, LINE 7B ANY PROPOSED AMENDMENT TO CERTAIN SECTIONS OF THE BYLAWS SHALL REQURE THE BISHOP OF THE CHICAGO METROPOLITAN SYNOD AND THE ILLINOIS CONFERENCE MINISTER OF THE UNITED CHURCH OF CHRIST ("UCC") TO PROVIDE APPROVAL PRIOR TO RATIFICATION BY A MAJORITY VOTE OF THE UCC AND EVANGELICAL LUTHERAN CHURCH IN AMERICA ("ELCA") DIRECTORS THEN IN OFFICE VOTING FOR SUCH CHANGE. FURTHER, PRIOR TO THE BOARD'S CONSIDERATION OF SUCH AMENDMENTS, THE APPROVAL OF THE ELCA AND THE ILLINOIS UCC CONFERENCE COUNCIL SHALL BE OBTAINED. FORM 990, PART VI, SECTION B, LINE 11B ADVOCATE'S TAX PREPARATION PROCESS INCLUDES ONGOING CONSULTATION WITH ITS OUTSIDE TAX CONSULTING FIRM AND TAX LEGAL COUNSEL, BOTH OF WHICH POSSESS EXPERTISE IN HEALTH CARE AND TAX-EXEMPT RETURN PREPARATION, TO ADVISE AND ASSIST WITH PREPARATION OF THE FORM 990. THESE ADVISORS WORKED CLOSELY WITH THE ORGANIZATION'S FINANCE, TAX, AND LEGAL ASSOCIATES AND OTHER MEMBERS OF THE ORGANIZATION'S TEAM ASSEMBLED TO PARTICIPATE IN THE PREPARATION OF THE FORM 990. THE FORM 990 IS REVIEWED BY FINANCE MANAGEMENT, THE TAX MANAGER, THE VP OF FINANCE/CORPORATE CONTROLLER, THE CHIEF FINANCIAL OFFICER, AND ADVOCATE'S OUTSIDE TAX CONSULTING FIRM AND TAX LEGAL COUNSEL. PRIOR TO PRESENTING THE FORM 990 TO THE BOARD OF DIRECTOR'S AUDIT COMMITTEE IN NOVEMBER, THE ORGANIZATION'S TEAM, INCLUDING ITS ADVISORS, MET FREQUENTLY TO DISCUSS AND REVIEW DRAFTS OF THE FORM 990. AT THE NOVEMBER AUDIT COMMITTEE MEETING, THE VP OF FINANCE/CORPORATE CONTROLLER AND CHIEF FINANCIAL OFFICER COORDINATED A REVIEW OF THE FORM 990 WITH COMMITTEE MEMBERS, AS THE AUDIT COMMITTEE IS THE COMMITTEE OF THE BOARD OF DIRECTORS CHARGED WITH OVERSIGHT OF AUDIT AND TAX MATTERS. THE VP OF FINANCE/CORPORATE CONTROLLER AND CHIEF FINANCIAL OFFICER RESPONDED TO THE AUDIT COMMITTEE MEMBERS' QUESTIONS AND PROVIDED THE OPPORTUNITY FOR DETAILED DISCUSSION OF THE FORM 990. THE CHANGES IDENTIFIED WERE INCORPORATED, AND THEN A COMPLETE COPY OF THE FINAL FORM 990 WAS PROVIDED TO EACH MEMBER OF THE ORGANIZATION'S BOARD OF DIRECTORS BEFORE THE FORM 990 WAS FILED. FORM 990, PART VI, SECTION B, LINE 12C THE ORGANIZATION'S CONFLICT OF INTEREST POLICY APPLIES TO VARIOUS PEOPLE, INCLUDING MEMBERS OF ADVOCATE'S BOARD OF DIRECTORS, GOVERNING COUNCILS, OFFICERS, ASSOCIATES, VOLUNTEERS, AND MEDICAL STAFF MEMBERS WITH ADMINISTRATIVE RESPONSIBILITIES. ANNUALLY, THE COMPLIANCE DEPARTMENT SENDS THIS POLICY AND THE ADVOCATE CODE OF BUSINESS CONDUCT TO A RANGE OF INDIVIDUALS WHO MAY BE IN A POSITION TO EXERCISE SUBSTANTIAL INTEREST OVER A PARTICULAR MATTER (DEFINIED AS "INTERESTED PERSONS"). THEY ARE REQUIRED TO READ THE POLICIES AND PROVIDE A DISCLOSURE STATEMENT TO THE COMPLIANCE DEPARTMENT, WHICH IDENTIFIES ACTIVITIES AND RELATIONSHIPS THAT COULD POTENTIALLY GIVE RISE TO A CONFLICT OF INTEREST. THE CHIEF COMPLIANCE OFFICER REVIEWS THE DISCLOSURES AND PROVIDES A REPORT TO THE SYSTEM BUSINESS CONDUCT (COMPLIANCE) COMMITTEE, EXECUTIVE MANAGEMENT TEAM AND THE AUDIT COMMITTEE OF THE BOARD FOR REVIEW. THE REPORT IS THEN PROVIDED, IN RELEVANT PART, TO THE SITE CHIEF EXECUTIVE OFFICERS. POTENTIAL CONFLICTS ARE REVIEWED BY THE COMPLIANCE DEPARTMENT ON A CASE BY CASE BASIS. FOLLOW UP PROCEDURES CONDUCTED ARE UNIQUE TO THE GIVEN CIRCUMSTANCE, AND MAY INCLUDE REVIEWING THE POTENTIAL CONFLICT WITH THE INTERESTED PERSON, OR INVESTIGATING THE MATTER IN CONSULTATION WITH THE INTERESTED PERSON'S SUPERVISOR AND/OR SITE MANAGEMENT. IN CIRCUMSTANCES WHERE THE INTERESTED PERSON IS NOT A MEMBER OF THE BOARD, OR GOVERNING COUNCIL, OR A COMMITTEE THEREOF, OR A PERSON OF INTEREST, IF IT IS DETERMINED THAT THERE IS AN ACTUAL CONFLICT OF INTEREST, THE SUPERVISOR OF THE INDIVIDUAL IS RESPONSIBLE FOR MAKING AN APPROPRIATE RESPONSE, POTENTIALLY INCLUDING A RESTRICTION OF THE INDIVIDUAL'S JOB DUTIES WITH RESPECT TO THE MATTER GIVING RISE TO THE CONFLICT. FORM 990, PART VI, SECTION C, LINE 19 THE ORGANIZATION MAKES ITS FINANCIAL STATEMENTS AVAILABLE TO THE PUBLIC THROUGH THE FOLLOWING WEBSITES: ADVOCATEHEALTH.COM, DACBOND.COM (DIGITAL ASSURANCE CERTIFICATION, LLC), EMMA.MSRB.ORG (ELECTRONIC MUNICIPAL MARKET ACCESS). THE ORGANIZATION DOES NOT MAKE ITS GOVERNING DOCUMENTS OR CONFLICT OF INTEREST POLICY AVAILABLE TO THE PUBLIC. FORM 990, PART XI, LINE 9: TCOM -6,325,327. 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