2020-03-18T15:44:10-05:00 2019-06-30 592046542 DAVIES HOUSER & SECREST CPA PA PO BOX 129 COCOA FL 329230129 990 2018-07-01 591101553 CIRCLES OF CARE INC CIRC 3217225200 400 E SHERIDAN ROAD MELBOURNE FL 32901 WILLIAM VINTROUX VP BUS & FINANCE 3217225200 2020-03-16 true TODD M RUSSELL CPA P00440904 3216360426 2020-03-16 65.34.16.86 2020-03-18 15:44:10 CD P B503F5B51F399EF652FF4AEDBEF08DB7D32C186B BB94A6B485FE2EA5137A1914115C5340E68BC7B9 2018 2020-11-19 02:30:22Z DAVID FELDMAN 400 E SHERIDAN ROAD MELBOURNE FL 32901 42160181 false X WWW.CIRCLESOFCARE.ORG X THE MISSION OF CIRCLES OF CARE IS TO PROMOTE AND PROVIDE HIGH QUALITY MENTAL HEALTH, ALCOHOL, DRUG ABUSE AND RELATED SERVICES THROUGH ITS HOSPITAL BASED AND STATE AND COUNTY CONTRACTED PROGRAMS. 19 19 699 0 15072806 17379253 24443551 23478971 1787580 1127528 142945 174429 41446882 42160181 0 0 25047842 25817090 0 0 13999847 14617798 39047689 40434888 2399193 1725293 49142501 50844767 8404094 8234760 40738407 42610007 THE MISSION OF CIRCLES OF CARE IS TO PROMOTE AND PROVIDE HIGH QUALITY MENTAL HEALTH, ALCOHOL, DRUG ABUSE AND RELATED SERVICES THROUGH ITS HOSPITAL BASED AND STATE AND COUNTY CONTRACTED PROGRAMS. false false ALCOHOL, DRUG ABUSE, & MENTAL HEALTH - 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PART V, LINE 5 THE CHNA IS THE PRODUCT OF TWO UMBRELLA ORGANIZATIONS, CENTRAL FLORIDA CARES HEALTH SYSTEM (CFCHS) AND SPACE COAST HEALTH FOUNDATION (SCHF) EACH OF WHICH RECEIVES INPUT FROM CIRCLES OF CARE. CFCHS FOCUSES PRIMARILY ON BEHAVIORAL HEALTHCARE NEEDS AND REPRESENTS THE FOLLOWING ORGANIZATIONS: 211 BREVARD ASPIRE HEALTH PARTNERS, INC. BREVARD C.A.R.E.S CHILDREN'S HOME SOCIETY OF FLORIDA, INC. COMMUNITY COUNSELING CENTER OF CENTRAL FLORIDA CIRCLES OF CARE, INC. DEVEREUX ECKERD CONNECTS GULF COAST JEWISH FAMILY AND COMMUNITY SERVICES HEART OF FLORIDA UNITED WAY 211 HOUSE OF FREEDOM IMPOWER KINDER KONSULTING & PARENTS TOO LIFESTREAM BEHAVIORAL CENTER, INC. MENTAL HEALTH ASSOCIATION MENTAL HEALTH RESOURCE CENTER (MHRC) BREVARD COUNTY FACT TEAM METRO TREATMENT OF FLORIDA, L.P. (NEW SEASON) ORLANDO HEALTH / THE HEALING TREE PARK PLACE BEHAVIORAL HEALTH CARE RASE PROJECT SPACE COAST RECOVERY SPECIALIZED TREATMENT, EDUCATION AND PREVENTION SERVICES (STEPS) THE TRANSITION HOUSE, INC. UCF RESTORES UNIVERSITY BEHAVIORAL CENTER WAYNE DENSCH CENTER SPACE COAST HEALTH FOUNDATION FOCUSES ON THE MEDICAL AND BEHAVIORAL HEALTHCARE NEEDS OF BREVARD COUNTY RESIDENTS AND REPRESENTS THE FOLLOWING HOSPITALS AND ORGANIZATIONS: 211 BREVARD BREVARD C.A.R.E.S BREVARD COUNTY COURTS BREVARD COUNTY SHERIFFS OFFICE BREVARD FAMILY PARTNERSHIP BREVARD HEALTH ALLIANCE BREVARD HOMELESS COALITION BREVARD PUBLIC SCHOOLS BREVARD SCHOOLS CATHOLIC CHARITIES OF CENTRAL FLORIDA CENTRAL FLORIDA CARES HEALTH SYSTEM INC. CHILDREN'S ADVOCACY CENTER CIRCLES OF CARE COASTAL HEALTH SYSTEMS OF BREVARD FLORIDA INSTITUTE OF TECHNOLOGY HOUSING AND HUMAN SERVICES LIFETIME COUNSELING CENTER NAMI BREVARD COUNTY ONE SENIOR PLACE PARRISH MEDICAL CENTER SPACE COAST HEALTH FOUNDATION FACILITY 1, CIRCLES OF CARE, INC - PART V, LINE 6A OTHER HOSPITALS WITH WHICH THE CHNA WAS CONDUCTED INCLUDE PARRISH MEDICAL CENTER AND ASPIRE HEALTH PARTNERS, INC. FACILITY 1, CIRCLES OF CARE, INC - PART V, LINE 6B OTHER NON-HOSPITAL ORGANIZATIONS WITH WHICH THE CHNA WAS CONDUCTED INCLUDE: 211 BREVARD BREVARD C.A.R.E.S BREVARD COUNTY COURTS BREVARD COUNTY SHERIFF'S OFFICE BREVARD FAMILY PARTNERSHIP BREVARD HEALTH ALLIANCE BREVARD HOMELESS COALITION BREVARD PUBLIC SHCOOLS BREVARD SCHOOLS CATHOLIC CHARITIES OF CENTRAL FLORIDA CENTRAL FLORIDA CARES HEALTH SYSTEM INC. CHILDREN'S ADVOCACY CENTER COASTAL HEALTH SYSTEMS OF BREVARD FLORIDA INSTITUTE OF TECHNOLOGY HOUSING AND HUMAN SERVICES LIFETIME LEARNING CENTER NAMI BREVARD COUNTY ONE SENIOR PLACE SPACE COAST HEALTH FOUNDATION CHILDREN'S HOME SOCIETY OF FLORIDA, INC. COMMUNITY COUNSELING CENTER OF CENTRAL FLORIDA DEVEREUX ECKERD CONNECTS GULF COAST JEWISH FAMILY AND COMMUNITY SERVICES HEART OF FLORIDA UNITED WAY 211 HOUSE OF FREEDOM IMPOWER KINDER KONSULTING & PARENTS TOO LIFESTREAM BEHAVIORAL CENTER, INC. MENTAL HEALTH ASSOCIATION MENTAL HEALTH RESOURCE CENTER (MHRC) BREVARD COUNTY FACT TEAM MENTAL HEALTH RESOURCE CENTER, INC. OSCEOLA COUNTY FACT TEAM METRO TREATMENT OF FLORIDA, L.P. (NEW SEASON) ORLANDO HEALTH / THE HEALING TREE PARK PLACE BEHAVIORAL HEALTH CARE RASE PROJECT SPACE COAST RECOVERY SPECIALIZED TREATMENT, EDUCATION AND PREVENTION SERVICES (STEPS) THE TRANSITION HOUSE, INC. UCF RESTORES UNIVERSITY BEHAVIORAL CENTER WAYNE DENSCH CENTER FACILITY 1, CIRCLES OF CARE, INC - PART V, LINE 11 CIRCLES OF CARE IS ADDRESSING TWO PRIORITY AREAS FROM TEH CHNA: (1) COUNTY SUICIDE RATE AND (2) ACCESS TO BEHAVIORAL HEALTH SERVICES. TO ADDRESS THE COUNTY SUICIDE RATE, CIRCLES OF CARE INTENDS TO: (1) CIRCLES WILL LOBBY THE FLORIDA LEGISLATURE FOR DESIGNATION AS A CENTRAL RECEIVING SYSTEM THAT CAN BE BROUGHT HOME TO DIRECTLY EXPAND THE AVAILABLE CRISIS SERVICES INCLUDING MOBILE CRISIS SUPPORT FOR BREVARD COUNTY RESIDENTS. (2) CIRCLES OF CARE WILL EXPAND ITS ENHANCED RISK ASSESSMENTS OF THE INPATIENT POPULATIONS TO ALL AMBULATORY PROGRAMS. (3) BY EXPANDING ACCESS TO CARE, PRIORTY AREA 1, CIRCLES OF CARE WILL INTERFACE WITH MORE SUICIDAL RESIDENTS AFFORDING A HIGHER OPPORUNITY FOR INTERVENTION. TO ADDRESS THE ACCESS TO BEHAVIORAL HEALTH SERVICES, CIRCLES OF CARE INTENDS TO: (1) CIRCLES OF CARE WILL UTILIZE CONTRACTED INCIDENTAL FUNDING TO PROVIDE TRANSPORTATION AND REDUCE MISSED APPOINTMENTS FOR CLIENTS WITH TRANSPORTATION CHALLENGES. (2) INCREASE CAPACITY OF SUBSTANCE USE DISORDERS, INCLUDING MAT AND CHILD WELFARE PROGRAMS. (3) CIRCLES WILL INCREASE THE NUMBER OF DESIGNATED DETOXIFICATION BEDS. OTHER PRIORITIES IDENTIFIED BY THE CHNA THAT WERE NOT ADDRESSED AT THIS TIME AS THEY REPRESENTED MORE MEDICALLY-CENTERED ISSUES VERSUS THE BEHAVIORAL HEALTHCARE MARKET THAT CIRCLES OF CARE SERVES. 9 TWIN RIVERS 400 EAST SHERIDAN ROAD MELBOURNE FL 32901 INPATIENT ADULT SUBSTANCE ABUSE CHILDRENS CRISIS STABILIZATION UNIT 400 EAST SHERIDAN ROAD MELBOURNE FL 32901 CHILDREN'S CRISIS STABILIZATION UNIT ADULT CRISIS STABILIZATION UNIT 880 AIRPORT ROAD MELBOURNE FL 32901 ADULT CRISIS STABILIZATION UNIT PSYCHIATRIC OUTPATIENT SERVICES 6700 S WASHINGTON AVE TITUSVILLE FL 32718 PSYCHIATRIC OUTPATIENT SERVICES PSYCHIATRIC OUTPATIENT SERVICES 1770 CEDAR STREET ROCKLEDGE FL 32955 PSYCHIATRIC OUTPATIENT SERVICES PSYCHIATRIC OUTPATIENT SERVICES 2020 COMMERCE DRIVE MELBOURNE FL 32904 PSYCHIATRIC OUTPATIENT SERVICES CHILDREN'S OUTREACH SERVICES 4450 W EAU GALLIE BLVD MELBOURNE FL 32934 CHILDREN'S OUTREACH SERVICES ADULT RESIDENTIAL SERVICES 2000 COMMERCE DRIVE MELBOURNE FL 32904 ADULT RESIDENTIAL SERVICES ADULT RESIDENTIAL SERVICES 1770 CEDAR STREET ROCKLEDGE FL 32955 ADULT RESIDENTIAL SERVICES PART I, LINE 3C - OTHER INCOME BASED CRITERIA FOR FREE OR DISCOUNTED CARE FOR UNINSURED CLIENTS WHOSE ANNUAL HOUSEHOLD INCOME IS: ABOVE FEDERAL POVERTY GUIDELINES TO 42,999 75% DISCOUNT 43,000 TO 74,999 60% DISCOUNT 75,000 AND ABOVE 40% DISCOUNT PART I, LINE 7G - SUBSIDIZED HEALTH SERVICES EXPLANATION AMOUNTS REPORTED ON PSYCHIATRIC INPATIENT UNIT REVENUE AND EXPENSES BASED ON COST ACCOUNTING SYSTEM. PART I, LINE 7 - COSTING METHODOLOGY EXPLANATION COSTING INFORMATION CALCULATED USING THE WEIGHTED AVERAGE OF THE INPATIENT COST TO CHARGE RATIO USED FOR THE PROVIDER'S MEDICARE COST REPORT AND THE OUTPATIENT COST TO CHARGE RATIO DEVELOPED USING THE PROVIDER'S COST ACCOUNTING SYSTEM. PART III, LINE 2 - BAD DEBT EXPENSE METHODOLOGY COSTING INFORMATION IS CALCULATED USING THE WEIGHTED AVERAGE OF THE INPATIENT COST TO CHARGE RATIO USED FOR THE PROVIDER'S 2019 MEDICARE COST REPORT AND THE OUTPATIENT COST TO CHARGE RATIO DEVELOPED USING THE PROVIDER'S COST ACCOUNTING SYSTEM. THE AMOUNT OF BAD DEBT EXPENSE (AT COST) ATTRIBUTABLE TO PATIENTS ELIGIBLE UNDER THE ORGANIZATION'S CHARITY CARE POLICY IS BASED ON AN ANALYSIS OF PATIENTS WHOSE COVERAGE UNDER THIRD PARTY PAYORS OR OTHER AGENCIES WAS REJECTED DUE TO INCOMPLETE OR ERRONEOUS INFORMATION BEING PROVIDED UPON ADMISSION. GROSS PATIENT SERVICE REVENUE IS ADJUSTED FOR CONTRACTUAL AND POLICY ADJUSTMENTS TO DETERMINE NET PATIENT SERVICE REVENUE. ACCORDINGLY, ALL AMOUNTS WRITTEN OFF AS BAD DEBT EXCLUDE THESE CONTRACTUAL AND POLICY ADJUSTMENTS. PART III, LINE 8 - MEDICARE EXPLANATION REVENUE RECEIVED UNDER THE MEDICARE REIMBURSEMENT AGREEMENT IS SUBJECT TO AUDIT AND RETROACTIVE ADJUSTMENT BY THE MEDICARE INTERMEDIARY AGENCY. THE RETROACTIVE MEDICARE ADJUSTMENTS ARE REPORTED IN NET PATIENT SERVICE REVENUE IN THE YEAR IN WHICH THE FUNDS ARE PAID OUT OR RECEIVED. ALL MEDICARE REPORTS, FOR THE YEARS ENDED JUNE 30, 2019 AND PRIOR, HAVE BEEN AUDITED OR SUBJECTED TO A DESK REVIEW AND FINAL SETTLEMENTS HAVE BEEN DETERMINED. MANAGEMENT RECORDS ADDITIONAL RECEIVABLES AND PAYABLES RELATING TO MEDICARE BASED ON THE MEDICARE COST REIMBURSEMENT REPORTS. THE TOTAL INPATIENT REVENUE RECEIVED FROM MEDICARE AND ALLOWABLE COSTS OF CARE RELATING TO THOSE PAYMENTS ARE TAKEN DIRECTLY FROM THE 2019 MEDICARE COST REPORT SETTLEMENT SUMMARY. NO BAD DEBTS WERE TAKEN INTO CONSIDERATION WHEN CALCULATING THESE AMOUNTS. THE TOTAL OUTPATIENT REVENUE RECEIVED FROM MEDICARE ARE TAKEN DIRECTLY FROM THE 2019 MEDICARE COST REPORT. COSTS ASSOCIATED WITH THSE REVENUES ARE BASED ON THE COST TO CHARGE RATIO DEVELOPED FOR OUTPATIENT SERVICES USING THE PROVIDER'S COST ACCOUNTING SYSTEM. NO BAD DEBTS WERE TAKEN INTO CONSIDERATION WHEN CALCULATING THESE AMOUNTS. PART III, LINE 9B - COLLECTION PRACTICES EXPLANATION INSURED CLIENTS ARE RESPONSIBLE FOR CO-PAYS REGARDLESS OF THEIR INCOME BY LAW. THE INPATIENT COLLECTION POLICY MANDATES THAT THE PROVIDER MAKE THREE ATTEMPTS (LETTERS, TELEPHONE) TO COLLECT PRIOR TO WRITING A RECEIVABLE OFF AS A BAD DEBT. IF THE PATIENT MEETS THE CRITERIA FOR CHARITY CARE AS INDIGENT UNDER THE FEDERAL POVERTY GUIDELINES, NO ATTEMPT TO COLLECT IS MADE. IF THE PROVIDER IS UNABLE TO CONTACT THE CLIENT VIA MAIL OR PHONE, THE RELATED RECEIVABLE IS WRITTEN OFF AS BAD DEBT. PART VI, LINE 2 - NEEDS ASSESSMENT CIRCLES OF CARE, INC. MAINTAINS COMMUNICATION WITH THE DEPARTMENT OF CHILDREN AND FAMILIES, THE STATE'S MENTAL HEALTH AND SUBSTANCE ABUSE AUTHORITY. THE ORGANIZATION ALSO CONDUCTS IT'S OWN LOCAL SURVEYS AND COLLABORATES WITH OTHER LOCAL HOSPITAL ORGANIZATIONS AND THE SPACE COAST HEALTH FOUNDATION TO ACCESS THE CURRENT NEEDS OF THE COMMUNITY. IN ADDITION, THE ORGANIZATION IS A MEMBER OF THE HEALTH SYSTEMS AGENCY OF EAST CENTRAL FLORIDA THAT CONDUCTS REGIONAL AND STATEWIDE NEEDS ASSESSMENTS. PART VI, LINE 3 - PATIENT EDUCATION OF ELIGIBILITY FOR ASSISTANCE AFTER ADMISSION TO THE INPATIENT UNITS, CLIENT FINANCIAL REPRESENTATIVES MEET WITH THE CLIENT TO DISCUSS THE CLIENT'S INSURANCE COVERAGE. DURING THIS DISCUSSION, ALONG WITH A FINANCIAL ELIGIBILTY APPLICATION, THE FINANCIAL REPRESENTATIVE INFORMS THE CLIENT OF ANY AVAILABLE FINANCIAL ASSISTANCE WHICH INCLUDES FREE OR DISCOUNTED SERVICES. UPON DISCHARGE, THIS INFORMATION IS ONCE AGAIN REVIEWED WITH THE CLIENT. PART VI, LINE 4 - COMMUNITY INFORMATION CIRCLES OF CARE, INC. SERVES BREVARD COUNTY FLORIDA. BREVARD COUNTY, A COASTAL REGION BORDERED ON THE EAST BY THE ATLANTIC OCEAN. BREVARD IS AN EXTRA-LONG COUNTY, EXTENDING 72 MILES FROM NORTH TO SOUTH, BUT AVERAGING 26.5 MILES INLAND FROM THE SEACOAST AT ANY POINT. BREVARD COUNTY IS APPROXIMATELY 35 MILES EAST OF ORLANDO AND "HALFWAY" DOWN FLORIDA. THERE IS NO MAJOR URBAN CENTER IN THE COUNTY. THE RACIAL MAKEUP OF THE COUNTY ACCORDING TO THE MOST RECENT POPULATION ESTIMATES BASED ON 2010 CENSUS DATA, RACE WAS: WHITE 83.0%; BLACK OR AFRICAN AMERICAN 10.1%; ASIAN 2.1%; SOME OTHER RACE 2.2%; TWO OR MORE RACES 2.6%. THE HISPANIC OR LATINO POPULATION IS 8.1%. THE POPULATION OF 590,000 WAS DISTRIBUTED AS FOLLOWS: 18.5% UNDER THE AGE OF 18, 58.2% FROM 18 TO 64, AND 23.3% WHO WERE 65 YEARS OF AGE OR OLDER. THE PERCENT OF FEMALES WAS 51.2%. THERE WERE 227,223 WITH AN AVERAGE HOUSEHOLD SIZE OF 2.47. THE MEDIAN HOUSEHOLD INCOME IN 2017 DOLLARS WAS 51,536. THE PERCENT OF PERSONS IN POVERTY WAS 12.4%. THOSE WITHOUT INSURANCE UNDER AGE 65 WAS 13.2%. INDIVIDUALS WITH A DISABILITY UNDER AGE 65 IS 10.0% PART VI, LINE 5 - PROMOTION OF COMMUNITY HEALTH A VOLUNTARY CITIZEN BOARD OF TWENTY-TWO PERSONS WHO LIVE AND WORK IN BREVARD COUNTY GOVERNS CIRCLES OF CARE, INC. THIS ACTIVE AND INVOLVED BOARD OF DIRECTORS IS CHARGED WITH: ESTABLISHING ALL POLICIES GOVERNING THE CORPORATION , APPROVING ANNUALLY THE GOALS, OBJECTIVES AND A PLAN OF OPERATION FOR THE DELIVERY OF SERVICES, APPROVAL OF AN ANNUAL BUDGET, OVERSIGHT OF FINANCIAL RECORDS AND AUDITS, ASSURING THOSE PERSONS OF THE BREVARD COMMUNITY ARE SERVED WITH QUALITY, APPROPRIATE AND EFFICIENT PROGRAMS. BOARD MEMBERS ARE SELECTED FOR THEIR INTEREST AND DESIRE IN THE PROVISION OF QUALITY BEHAVIORAL HEALTHCARE SERVICES IN BREVARD COUNTY. THE BOARD MEMBERS ARE REFLECTIVE OF THE DIFFERENT GEOGRAPHICAL AREAS OF THE COUNTY AND MANY REPRESENT CONSUMERS AND FAMILY MEMBERS WITH SPECIAL INTEREST IN OUR VARIOUS PROGRAMS. PART VI, LINE 6 - AFFILIATED HEALTH CARE SYSTEM N/A ADDITIONAL INFORMATION CHARITY CARE CIRCLES OF CARE IDENTIFIES CHARITY CARE PATIENTS USING THE SAME CRITERIA USED BY THE STATE OF FLORIDA AGENCY FOR HEALTH CARE ADMINISTRATION. IT IS THEIR POLICY THAT A PATIENT, WHOSE INCOME DOES NOT EXCEED 150 PERCENT OF THE CURRENT FEDERAL POVERTY GUIDELINES, WILL BE CLASSIFIED AS A CHARITY CARE PATIENT. ADDITIONALLY, IF THE PATIENT'S TOTAL CHARGES EXCEED 25 PERCENT OF THE PATIENT'S ANNUAL INCOME, THE PATIENT WILL BE CLASSIFIED AS A CHARITY CARE PATIENT, UNLESS THE PATIENT'S INCOME EXCEEDS FOUR TIMES THE FEDERAL POVERTY LEVEL FOR A FAMILY OF FOUR. BECAUSE CIRCLES OF CARE DOES NOT PURSUE COLLECTION OF AMOUNTS DETERMINED TO QUALIFY AS CHARITY CARE, SUCH AMOUNTS ARE NOT REPORTED AS GROSS PATIENT SERVICE REVENUE. X X X X X false false false false false false false false false DAVID FELDMAN PRESIDENT 245244 64218 19130 45690 19190 393472 STEPHEN LORD VP INFORMATION SYSTE 137440 28017 17875 34663 23871 241866 WILLIAM VINTROUX VP BUS & FINANCE 152732 25589 3649 33749 23871 239590 BARRY HENSEL VP CLINICAL DIR 181145 50220 2471 41272 18090 293198 LINDA BRANNON VP HR 134830 22244 11941 23807 192822 JASON WIESELER SENIOR CLINICAL ADMI 138841 29772 250 26852 9325 205040 REHAN FAROOQUI MD 297342 38073 23871 359286 LUIS VINUELA MD 246783 31728 23871 302382 APARNA KOPURI MD 232000 24402 256402 SUBRAMANIYAM VASUDEVAN MD 228669 32437 261106 JOSEPH MINGOIA MD 218525 19342 43213 281080 SARAH BEST WIFE - OFFICER 62028 WAGES false X 1 987807 false false false FORM 990, PAGE 6, PART VI, LINE 11B THE PREPARER EMAILS A COPY OF THE FINAL VERSION OF FORM 990 TO THE CHAIRMAN OF THE AUDIT AND FINANCE COMMITTEE BEFORE IT IS FILED. THE CHAIRMAN THEN DISTRIBUTES THE COPY OF THE FINAL VERSION TO THE BOARD MEMBERS FOR REVIEW. AFTER REVIEWING THE RETURN, THE AUDIT AND FINANCE COMMITTEE APPROVES THE RELEASE OF THE FORM 990 PENDING ANY APPLICABLE CHANGES. THE RETURN IS THEN MODIFIED AS NECESSARY AND FILED. FORM 990, PAGE 6, PART VI, LINE 12C THE ORGANIZATION'S CONFLICT OF INTEREST POLICY REQUIRES EACH DIRECTOR, OFFICER AND MANAGEMENT STAFF TO SIGN A STATEMENT ANNUALLY THAT AFFIRMS THAT EACH PERSON (A) HAS RECEIVED A COPY OF THE CONFLICT OF INTEREST POLICY; (B) HAS READ AND UNDERSTANDS THE POLICY; (C) HAS AGREED TO COMPLY WITH THE POLICY AND (D) UNDERSTANDS THAT CIRCLES OF CARE IS A CHARITABLE ORGANIZATION AND THAT IN ORDER TO MAINTAIN ITS FEDERAL TAX EXEMPTION, IT MUST ENGAGE PRIMARILY IN ACTIVITIES THAT ACCOMPLISH ONE OR MORE OF ITS TAX EXEMPT PURPOSES. THE ORGANIZATION'S CONFLICT OF INTEREST POLICY HAS THREE ESSENTIAL ELEMENTS. (1) FULL DISCLOSURE BOARD MEMBERS AND STAFF MEMBERS IN DECISION- MAKING ROLES SHOULD MAKE KNOWN THEIR CONNECTIONS WITH GROUPS DOING BUSINESS WITH THE ORGANIZATION. THIS INFORMATION SHOULD BE PROVIDED ANNUALLY. (2) BOARD MEMBER ABSTENTION FROM DISCUSSION AND VOTING BOARD MEMBERS WHO HAVE AN ACTUAL OR POTENTIAL CONFLICT OF INTEREST SHOULD NOT PARTICIPATE IN DISCUSSIONS OR VOTE ON MATTERS AFFECTING TRANSACTIONS BETWEEN THE ORGANIZATION AND OTHER GROUPS. (3) STAFF MEMBER ABSTENTION FROM DECISION-MAKING STAFF MEMBERS WHO HAVE AN ACTUAL OR POTENTIAL CONFLICT SHOULD NOT BE SUBSTANTIALLY INVOLVED IN DECISION-MAKING AFFECTING SUCH TRANSACTIONS. IF THERE IS REASONABLE CAUSE TO BELIEVE THAT A DIRECTOR, OFFICER OR MANAGEMENT STAFF MEMBER IS INVOLVED IN OR IS AWARE OF ANY TRANSACTION OR SITUATION THAT RESULTS IN A CONFLICT, OR THE APPEARANCE OF A CONFLICT, DIRECTLY OR INDIRECTLY THROUGH BUSINESS, INVESTMENT OR FAMILY, THEN SUCH PERSON SHALL PROMPTLY DISCLOSE THE EXISTENCE AND NATURE OF HIS OR HER CONFLICT. A FULL DISCLOSURE OF ALL THE FACTS PERTAINING TO ANY TRANSACTION THAT IS SUBJECT TO ANY DOUBT CONCERNING THE POSSIBLE EXISTENCE OF A CONFLICT OF INTEREST SHALL BE MADE BEFORE CONSUMMATION OF THE TRANSACTION. IF THERE IS REASONABLE CAUSE TO BELIEVE THAT A DIRECTOR, OFFICER OR MANAGEMENT STAFF MEMBER HAS FAILED TO DISCLOSE ACTUAL OR POSSIBLE CONFLICTS OF INTEREST, THE INDIVIDUAL SHALL BE INFORMED OF THE BASIS FOR SUCH BELIEF AND SHALL BE AFFORDED AN OPPORTUNITY TO EXPLAIN THE ALLEGED FAILURE TO DISCLOSE. IF AFTER HEARING THE RESPONSE OF THE DIRECTOR, OFFICER OR MANAGEMENT STAFF MEMBER AND MAKING SUCH FURTHER INVESTIGATION AS MAY BE WARRANTED IN THE CIRCUMSTANCES, IT IS DEEMED THE DIRECTOR, OFFICER OR MANAGEMENT STAFF MEMBER HAS IN FACT FAILED TO DISCLOSE AN ACTUAL OR POSSIBLE CONFLICT OF INTEREST, APPROPRIATE DISCIPLINARY ACTION SHALL BE TAKEN. FORM 990, PAGE 6, PART VI, LINE 15A THE EXECUTIVE COMMITTEE OF THE BOARD UTILIZED STATE-WIDE (FLORIDA COUNCIL OF COMMUNITY MENTAL HEALTH) AND NATIONAL (MENTAL HEALTH CORPORATION OF AMERICA) COMPENSATION SURVEYS OF CEOS IN THE MENTAL HEALTH INDUSTRY. USING THE RESULTS OF THE SURVEYS, THE EXECUTIVE COMMITTEE DRAFTED A PROPOSED COMPENSATION PACKAGE FOR THE CEO AND FORWARDED IT TO THE AUDIT AND FINANCE COMMITTEE FOR REVIEW PRIOR TO ITS INCORPORATIION INTO THE BUDGET. PARAMETERS UTILIZED IN SETTING THE COMPENSATION PACKAGE FOR THE CEO INCLUDED SERVICE DELIVERY TO THE COMMUNITY AND COMPLIANCE WITH INDUSTRY STANDARDS/REGULATIONS. COMPENSATION IS NOT BASED ON THE REVENUES OR NET EARNINGS OF THE ORGANIZATION. FORM 990, PAGE 6, PART VI, LINE 15B USING AVAILABLE STATEWIDE (FLORIDA COUNCIL OF COMMUNITY MENTAL HEALTH) AND NATIONAL (MENTAL HEALTH CORPORATION OF AMERICA) INDUSTRY DATA, THE CEO FORMULATES COMPENSATION PACKAGES FOR ALL OTHER OFFICERS AND KEY EMPLOYEES. FACTORS CONSIDERED IN FORMULATING COMPENSATION INCLUDE EDUCATION, EXPERIENCE AND COST OF LIVING DIFFERENCES WHERE APPLICABLE. COMPENSATION IS NOT BASED ON THE REVENUE OR NET EARNINGS OF THE ORGANIZATION. ONCE THE COMPENSATION PACKAGES FOR OFFICERS AND KEY EMPLOYEES ARE ASSEMBLED, THE CEO FORWARDS HIS PROPOSALS TO THE AUDIT AND FINANCE COMMITTEE FOR INCORPORATION INTO THE BUDGET. ONCE THE AUDIT AND FINANCE COMMITTEE RECEIVES THE PROPOSED COMPENSATION PACKAGES FOR THE CEO AND OTHER OFFICERS AND KEY EMPLOYEES, THEY ARE REVIEWED AND INCORPORATED INTO THE BUDGET PROCESS. ONCE THE BUDGET IS COMPLETED, IT IS FORWARDED TO THE FULL BOARD FOR APPROVAL. FORM 990, PAGE 6, PART VI, LINE 19 THE ORGANIZATION PROVIDES MEMBERS OF THE PUBLIC COPIES OF ITS GOVERNING DOCUMENTS, CONFLICT OF INTEREST POLICY AND FINANCIAL STATEMENTS FREE OF CHARGE UPON RECEIPT OF A WRITTEN REQUEST FOR SUCH INFORMATION. FINANCIAL STATEMENTS ARE ALSO AVAILABLE ON THE ORGANIZATION'S WEBSITE. FORM 990, PART XI, LINE 9 CHANGE IN UNREALIZED GAINS AND LOSSES ON OTHER 0 THAN TRADING SECURITIES 0 GAIN ON DERIVATIVE INVESTMENTS 0 CHANGE IN PERM RESTRICTED NET ASSETS -3,708 TOTAL -3,708