2020-07-15T11:03:22-05:00 2019-06-30 470617373 COMMONSPIRIT HEALTH 198 INVERNESS DRIVE WEST ENGLEWOOD CO 80112 990 2018-07-01 273733278 St Lukes Community Development Corporation - PMC STLU 7139487000 6624 FANNIN ST 2505 HOUSTON TX 77030 MARK TERESI INTERIM CHIEF FINANCIAL OFFICER 2020-07-15 true ANGELA NOEL P01051055 3032989100 2018 2021-01-29 14:40:06Z T DOUGLAS LAWSON 6624 FANNIN ST 2505 HOUSTON TX 77030 0 false X http://www.chistlukeshealth.org/pmc X 2010 TX To nurture the healing ministry of the Roman Catholic Church by bringing it new life, energy, and viability in the Twenty-First Century. Fidelity to the Gospel urges us to emphasize human dignity and social justice as it moves toward the creation of healthier communities. 3 1 0 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 8690100 8690100 19207870 19207870 -10517770 -10517770 As an affiliate of CommonSpirit Health, we make the healing presence of God known in our world by improving the health of the people we serve, especially those who are vulnerable, while we advance social justice for all. false false 0 0 0 See Schedule H 0 true false false false false false false false false true false true true true true false true false false false false false false false false true true false false true false false false false false false false false false false false false false true false false false true X 0 0 0 false false false false false false true false false false false false X 3 1 false false false false true true false true true false false true true true true true true false false true true X MARK TERESI 8323552885 6624 FANNIN STREET SUITE 2505 HOUSTON TX 77030 T DOUGLAS LAWSON PHD BOARD MEMBER/CEO of CHI ST. LUKE'S HEALTH SYSTEM 1.0 49.0 X X 0 1355710 146269 SUSAN BAILEY-NEWELL Board Member 1.0 49.0 X 0 424728 45705 Leonard C Tallerine Jr Board Member 1.0 8.0 X 0 0 0 MARK MCGINNIS CFO OF CHI ST. LUKE'S HEALTH SYSTEM 1.0 49.0 X 0 757960 70777 JENNY BARNETT-SARPALIUS FORMER CFO of CHI St. Luke's Health System 0.0 0.0 X 0 550000 0 Michael Covert FORMER President /BD Member/CEO OF CHI ST. LUKE'S HEALTH SYSTEM 1.0 49.0 X 0 1280995 18328 0 4369393 281079 0 true true false 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 2211079 81165 2129914 2129914 0 0 2095025 2095025 0 4465161 4465161 8690100 8690100 0 0 0 0 0 0 0 0 19207870 19207870 19207870 19207870 X -10517770 -10517770 0 0 -10517770 -10517770 8690100 8690100 0 0 X false true X true false X 2211079 81165 2129914 2129914 INVESTMENT IN UNCONSOLIDATED ORG 2095025 C 2095025 INTERCOMPANY RECEIVABLES 4465161 4465161 GOODWILL - PMC ACQUISITIONS 19207870 19207870 X Schedule D, Part X, Line 2 FIN 48 (ASC 740) footnote ST LUKE'S COMMUNITY DEVELOPMENT CORPORATION - PMC's financial information is included in the consolidated audited financial statements of CommonSpirit Health, a related organization. CommonSpirit Health's FIN 48 (ASC 740) footnote for the year ended June 30, 2019, reads as follows: "CommonSpirit has established its status as an organization exempt from income taxes under the Internal Revenue Code Section 501(c)(3) and the laws of the states in which it operates, and as such, is generally not subject to federal or state income taxes. However, CommonSpirit's exempt organizations are subject to income taxes on net income derived from a trade or business, regularly carried on, which does not further the organizations' exempt purposes. No significant income tax provision has been recorded in the accompanying consolidated financial statements for net income derived from unrelated trade or business. CommonSpirit's for-profit subsidiaries account for income taxes related to their operations. The for-profit subsidiaries recognize deferred tax assets and liabilities for temporary differences between the financial reporting basis and the tax basis of their assets and liabilities, along with net operating loss and tax credit carryovers, for tax positions that meet the more-likely-than-not recognition criteria. Changes in recognition or measurement are reflected in the period in which the change in judgement occurs. Income tax interest and penalties are recorded as income tax expense. For the years ended June 30, 2019 and 2018, CommonSpirit's taxable entities recorded an immaterial amount of interest and penalties as part of the provision for income taxes. CommonSpirit's taxable entities did not have any material unrecognized income tax benefits as of June 30, 2019 and 2018. CommonSpirit reviews its tax positions quarterly and has determined that there are no material uncertain tax positions that require recognition in the accompanying consolidated financial statements". true true X true X 300 true X true true true false false 53 106672 106672 0.0053 322083 736006 0 0.0 0 0.0 0 53 428755 736006 106672 0.0053 0 0.0 0 0.0 0 0.0 0 0.0 474207 474207 0.0236 0 0 474207 0 474207 0.0236 0 53 902962 736006 580879 0.0290 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0 0 0 0 0 0 0.0 true 2556476 0 4301904 4458527 -156623 X true true PMC HOSPITAL LLC MEDICAL CARE 0.25 0.0 0.49 1 1 PMC HOSPITAL LLC 4600 E SAM HOUSTON PKWY SOUTH PASADENA TX 77505 http://www.chistlukeshealth.org/pmc 100081 X X X PMC HOSPITAL LLC 1 false false true X X X X X X X X X 18 true true true true X https://www.chistlukeshealth.org/sites/default/files/Community%20Health%20Plan%20Implementation%20St X true 18 false true false true X 300.0 300.0 X X X X true true X X X true X http://www.chistlukeshealth.org/financial-assistance X http://www.chistlukeshealth.org/financial-assistance X http://www.chistlukeshealth.org/financial-assistance X X X X X X true X false X X X X true X false false Schedule H, Part V, Section B, Line 5 Facility , 1 Facility , 1 - PMC HOSPITAL, LLC. FOR THE LATEST CHNA, THE HOSPITAL WORKED WITH THE EPISCOPAL HEALTH FOUNDATION WHICH HIRED HEALTH RESOURCES IN ACTION, A NONPROFIT PUBLIC HEALTH INSTITUTE, TO CONDUCT KEY INFORMANT INTERVIEWS WITH INFORMANTS IDENTIFIED BY THE HOSPITALS AND TO ANALYZE THOSE INTERVIEWS FOR KEY THEMES. A TOTAL OF 53 KEY INFORMANT INTERVIEWS WERE CONDUCTED. COMMUNITY INPUT ALSO INCLUDED EMAIL AND TELEPHONE SURVEYS OF RESIDENTS, AND FOCUS GROUPS INCLUDING HEALTH CARE STAFF, COMMUNITY ORGANIZATIONS AND OTHER STAKEHOLDERS. PARTICIPANTS REPRESENTED A WIDE RANGE OF COMMUNITY SECTORS, INCLUDING LOCAL PUBLIC HEALTH AND POOR AND MEDICALLY INDIGENT POPULATIONS IN THE COMMUNITY. ORGANIZATIONS REPRESENTED INCLUDE: CATHOLIC CHARITIES-FORT BEND, CHILD ADVOCATES OF FORT BEND, FORT BEND COUNTY HEALTH AND HUMAN SERVICES, FORT BEND REGIONAL COUNCIL ON SUBSTANCE ABUSE, FORT BEND SENIORS, FORT BEND WOMEN'S CENTER, THE ARC OF FORT BEND COUNTY, AIDS FOUNDATION OF HOUSTON, ASSOCIATION FOR THE ADVANCEMENT OF MEXICAN AMERICANS, AVENUE CDC, CHRIST CLINIC, COASTAL AREA HEALTH EDUCATION CENTERS, COMMUNITY HEALTH CHOICE, GREATER HOUSTON PARTNERSHIP, HEALTH CARE FOR THE HOMELESS-HOUSTON, HOPE CLINIC, HOUSTON AREA FOOD BANK, KINDER INSTITUTE, LEGACY COMMUNITY HEALTH, NEIGHBORHOOD CENTERS HEAD START/EARLY HEAD START PROGRAM SERVICES/BAKER RIPLEY, THE ROSE, LIBERTY COUNTY SHERIFF'S OFFICE, TRI COUNTY SERVICES BEHAVIORAL HEALTH CARE, PRAIRIE VIEW A&M, AND EL CENTRO DE CORAZON. Schedule H, Part V, Section B, Line 6a Facility , 1 Facility , 1 - CHI ST. LUKE'S HOSPITAL FACILITIES AND SEVERAL OTHERS. THE HOSPITAL COLLABORATED WITH SEVERAL OTHER HOSPITALS AND HOSPITAL SYSTEMS. CHI ST. LUKE'S FACILITIES INCLUDED: BAYLOR ST. LUKE'S MEDICAL CENTER, PATIENTS MEDICAL CENTER, SPRINGWOODS VILLAGE HOSPITAL, SUGAR LAND HOSPITAL, THE VINTAGE HOSPITAL, THE WOODLANDS HOSPITAL, AND LAKESIDE HOSPITAL. OTHER PARTICIPATING HOSPITALS WERE HOUSTON METHODIST HOSPITAL, MEMORIAL HERMANN HEALTH SYSTEM, AND TEXAS CHILDREN'S HOSPITAL. Schedule H, Part V, Section B, Line 6b Facility , 1 Facility , 1 - PMC HOSPITAL, LLC. EPISCOPAL HEALTH FOUNDATION Schedule H, Part V, Section B, Line 11 Facility , 1 Facility , 1 - PMC HOSPITAL, LLC. THE SIGNIFICANT COMMUNITY HEALTH NEEDS THE HOSPITAL IS HELPING TO ADDRESS WERE IDENTIFIED IN THE HOSPITAL'S MOST RECENT COMMUNITY HEALTH NEEDS ASSESSMENT. NEEDS BEING ADDRESSED BY STRATEGIES AND PROGRAMS ARE: ACCESS TO CARE, HUMAN TRAFFICKING, OBESITY, AND BEHAVIORAL HEALTH. THE HOSPITAL WILL TAKE ACTIONS TO HELP ADDRESS EACH OF THE SIGNIFICANT NEEDS. ACCESS TO CARE: DEFINE A PROCEDURE FOR TREATING AND/OR IDENTIFYING TRAFFICKED VICTIMS IN OUR FACILITIES AND COLLABORATING WITH COMMUNITY PARTNERS; PROVIDE EDUCATION FOR STAFF AND COMMUNITY REGARDING SERVICES, CULTURAL DIFFERENCE THAT EFFECT TREATMENT; COLLABORATE WITH COMMUNITY ORGANIZATIONS, CHURCHES, CIVIC GROUPS AND SUPPORT GROUPS TO PRESENT EDUCATIONAL SEMINARS; FOSTER NEW RELATIONSHIPS WITH PRIMARY CARE PROVIDERS AND HEALTHCARE SERVICE PROVIDERS TO ASSIST LINKING HOSPITAL PATIENTS TO MEDICAL HOMES. HUMAN TRAFFICKING: INCREASE PREVENTION AND TREATMENT RESOURCES IN AREAS OF PHYSICAL/SEXUAL ABUSE, HUMAN TRAFFICKING AND VIOLENCE IN SCHOOLS; PARTNER WITH HOUSTON WOMEN'S CENTER TO EDUCATE STAFF ON SIGNS TO RECOGNIZE ABUSED PATIENTS; PARTNER WITH LAW ENFORCEMENT AND SOCIAL SERVICE ORGANIZATIONS TO INCREASE TRAUMA INFORMED CARE TO HUMAN TRAFFICKING VICTIMS. OBESITY: PARTNER WITH SCHOOLS TO PROVIDE RESOURCES AND EDUCATIONAL SUPPORT FOR NUTRITION, OBESITY, AND HEALTHY LIFESTYLES AMONG YOUTH. BEHAVIORAL HEALTH: DEVELOP RESOURCES IN THE EMERGENCY DEPARTMENT TO MANAGE NEEDS OF BEHAVIORAL HEALTH PATIENTS; STRENGTHEN COMMUNITY PARTNERSHIPS TO ADVOCATE FOR ADDITIONAL SUPPORT FOR BEHAVIORAL HEALTH SPECIALISTS TO WORK ALONGSIDE CAREGIVERS. Schedule H, Part V, Section B, Line 13 Facility , 1 Facility , 1 - PMC HOSPITAL, LLC. The patient must have a minimum account balance of thirty-five dollars ($35.00) with the CHI Hospital Organization. Multiple account balances may be combined to reach this amount. Patients/Guarantors with balances below thirty-five dollars ($35) may contact a financial counselor to make monthly installment payment arrangements. The patient must submit a completed Financial Assistance application. Patient Cooperation Standards - A patient must exhaust all other payment options, including private coverage, federal, state and local medical assistance programs, and other forms of assistance provided by third-parties prior to being approved. An applicant for Financial Assistance is responsible for applying to public programs for available coverage. He or she is also expected to pursue public or private health insurance payment options for care provided by a CHI Hospital Organization within a Hospital Facility. A patient's and, if applicable, any Guarantor's cooperation in applying for applicable programs and identifiable funding sources, including COBRA coverage (a federal law allowing for a time-limited extension of employee healthcare benefits), shall be required. If a Hospital Facility determines that COBRA coverage is potentially available, and that a patient is not a Medicare or Medicaid beneficiary, the patient or Guarantor shall provide the Hospital Facility with information necessary to determine the monthly COBRA premium for such patient, and shall cooperate with Hospital Facility staff to determine whether he or she qualifies for Hospital Facility COBRA premium assistance, which may be offered for a limited time to assist in securing insurance coverage. A Hospital Facility shall make affirmative efforts to help a patient or patient's Guarantor apply for public and private programs. 0 Schedule H, Part I, Line 3c eligibility criteria for a patient to qualify for Financial Assistance Unless eligible for Presumptive Financial Assistance, the following eligibility criteria must be met in order for a patient to qualify for Financial Assistance: * The patient must have a minimum account balance of thirty-five dollars ($35.00) with the CHI Hospital Organization. Multiple account balances may be combined to reach this amount. Patients/Guarantors with balances below thirty-five dollars ($35) may contact a financial counselor to make monthly installment payment arrangements. * The patient's Family Income must be at or below 300% of the FPG. * The patient must comply with Patient Cooperation Standards as described [in the FAP]. * The patient must submit a completed Financial Assistance application. For patients and Guarantors who are unable to provide required documentation, a Hospital Facility may grant Presumptive Financial Assistance based on information obtained from other resources. In particular, presumptive eligibility may be determined on the basis of individual life circumstances that may include: * Recipient of state-funded prescription programs; * Homeless or one who received care from a homeless clinic; * Participation in Women, Infants and Children programs (WIC); * Food stamp eligibility; * Subsidized school lunch program eligibility; * Eligibility for other state or local assistance programs (e.g., Medicaid spend-down); * Low income/subsidized housing is provided as a valid address; or * Patient is deceased with no known estate. Schedule H, Part I, Line 7 Costing Methodology used to calculate financial assistance ST. LUKE'S COMMUNITY DEVELOPMENT CORPORATION - PMC HOLDS A 25% INTEREST IN PMC HOSPITAL LLC D/B/A ST. LUKE'S PATIENTS MEDICAL CENTER ("SLPMC"). ST. LUKE'S COMMUNITY DEVELOPMENT CORPORATION - PMC IS REPORTING ITS 25% OF MEDICAID SHORTFALL, MEDICARE SHORTFALL, AND BAD DEBT EXPENSE. AS THE AMOUNT OF CHARITY CARE PROVIDED IS THE DIRECT RESULT OF THE CONTROL OF THE EXEMPT PARTNER'S CHARITY CARE POLICY, THE ENTIRE AMOUNT OF CHARITY CARE PROVIDED AT SLPMC IS BEING REPORTED ON LINE 7A. THE COST TO CHARGE RATIO METHOD WAS UTILIZED TO DETERMINE FINANCIAL ASSISTANCE AND UNREIMBURSED MEDICAID AT COST. TOTAL EXPENSES FOR SLPMC TOTALED $22,615,037 AND WERE REDUCED BY BAD DEBT EXPENSE IN THE AMOUNT OF $2,556,475 TO DETERMINE THE PERCENTAGE IN SCHEDULE H, PART I, LINE 7(F). ST. LUKE'S COMMUNITY DEVELOPMENT CORPORATION - PMC RECEIVED SUPPLEMENTAL MEDICAID PAYMENTS OF $261,798 DURING THE YEAR ENDED JUNE 30, 2019. THESE PAYMENTS WERE INCLUDED IN THE DIRECT OFFSETTING REVENUE AMOUNTS FOUND IN SCHEDULE H, PART 1, LINE 7B, COLUMN D. THESE SUPPLEMENTAL MEDICAID PAYMENTS RESULTED IN REDUCTION IN NET COMMUNITY BENEFIT EXPENSE AND PERCENTAGES FOUND IN COLUMNS (E) AND (F). Schedule H, Part III, Line 2 Bad debt expense - methodology used to estimate amount ST. LUKE'S COMMUNITY DEVELOPMENT CORPORATION - PMC HOLDS A 25% INTEREST IN PMC HOSPITAL LLC D/B/A ST. LUKE'S PATIENTS MEDICAL CENTER ("SLPMC"). 25% OF THE BAD DEBT EXPENSE FOR PMC HOSPITAL LLC WAS REPORTED ON PART III, LINE 2. Bad Debt Expense is calculated monthly based on the balance in Self Pay Accounts Receivable. Historical percentages are developed and applied against the current Self Pay balance to estimate the required reserve. The Bad Debt provision is a function of actual write-offs and the change in reserve requirement. The organization has reported bad debt expense at gross charges written off. The organization's bad debt expense represents amounts billed to patients that was deemed uncollectible and does not include any charges that were ultimately reimbursed or discounted. Patient discounts are recorded in contractual allowance or financial assistance, as appropriate, as an offset to gross revenue and are not included in bad debt expense. Schedule H, Part III, Line 3 Bad Debt Expense Methodology SLPMC does not believe that any portion of bad debt expense could reasonably be attributed to patients who qualify for financial assistance since amounts due from those individuals' accounts will be reclassified from bad debt expense to charity care within 30 days following the date that the patient is determined to qualify for charity care. Schedule H, Part III, Line 4 Bad debt expense - financial statement footnote St. Luke's Community Development Corporation - PMC does not issue separate company audited financial statements. However, the organization is included in the consolidated financial statements of CommonSpirit Health. The consolidated footnote reads as follows: CommonSpirit relies on the results of detailed reviews of historical write-offs and collections in estimating the collectability of accounts receivable. Updates to the hindsight analysis is performed at least quarterly using primarily a rolling eighteen-month collection history and write-off data. Subsequent changes to estimates of the transaction price are generally recorded as adjustments to net patient revenue in the period of change. Subsequent changes that are determined to be the result of an adverse change in a third-party payor's ability to pay are recorded as bad debt expense in purchased services and other in the accompanying consolidated statements of operations and change in net assets. Bad debt expense for 2019 was not significant. Schedule H, Part III, Line 8 Community benefit & methodology for determining medicare costs Using essentially the same Medicare cost report principles as to the allocation of general services costs and "apportionment" methods, the "CHI Workbook" calculates a payers' gross allowable costs by service (so as to facilitate a corresponding comparison between gross allowable costs and ultimate payments received). The term "gross allowable costs" means costs before any deductibles or co-insurance are subtracted. SLPMC's ultimate reimbursement will be reduced by any applicable copayment/ deductible. Where Medicare is the secondary insurer, amounts due from the insured's primary payer were not subtracted from Medicare allowable costs because the amounts are typically immaterial. Although not presented on the Medicare cost report, in order to facilitate a more accurate understanding of the "true" cost of services (for "shortfall" purposes) the CHI Workbook allows a health care facility not to offset costs that Medicare considers to be non-allowable, but for which the facility can legitimately argue are related to the care of the facility's patients. In addition, although not reportable on the Medicare cost report, the CHI workbook includes the cost of services that are paid via a set fee-schedule rather than being reimbursed based on costs (e.g. outpatient clinical laboratory). Finally, the CHI Workbook allows a facility to include other health care services performed by a separate facility (such as a physician practice) that are maintained on separate books and records (as opposed to the main facility's books and records which has its costs of service included within a cost report). True costs of Medicare computed using this methodology: Total Medicare Revenue: $4,301,904 Total Medicare costs: $4,458,527 Shortfall $156,623 SLPMC believes that excluding Medicare losses from community benefit makes the overall community benefit report more credible for these reasons: Unlike subsidized areas such as burn units or behavioral-health services, Medicare is not a differentiating feature of tax-exempt health care organizations. In fact, for-profit hospitals focus on attracting patients with Medicare coverage, especially in the case of well-paid services that include cardiac and orthopedics. Significant effort and resources are devoted to ensuring that hospitals are reimbursed appropriately by the Medicare program. The Medicare Payment Advisory Commission (MedPAC), an independent Congressional agency, carefully studies Medicare payment and the access to care that Medicare beneficiaries receive. The commission recommends payment adjustments to Congress accordingly. Though Medicare losses are not included by Catholic hospitals as community benefit, the Catholic Health Association guidelines allow hospitals to count as community benefit some programs that specifically serve the Medicare population. For instance, if hospitals operate programs for patients with Medicare benefits that respond to identified community needs, generate losses for the hospital, and meet other criteria, these programs can be included in the CHA framework in Category C as "subsidized health services." Medicare losses are different from Medicaid losses, which are counted in the CHA community benefit framework, because Medicaid reimbursements generally do not receive the level of attention paid to Medicare reimbursement. Medicaid payment is largely driven by what states can afford to pay, and is typically substantially less than what Medicare pays. Schedule H, Part III, Line 9b Collection practices for patients eligible for financial assistance ST. LUKE'S COMMUNITY DEVELOPMENT CORPORATION - PMC HOLDS A 25% INTEREST IN PMC HOSPITAL LLC D/B/A ST. LUKE'S PATIENTS MEDICAL CENTER ("SLPMC"). SLPMC's billing and collections policy applies to all individuals presenting for emergency or other medically necessary care. The policy contains provisions for collecting amounts due from those patients who the organization knows to qualify for financial assistance either through the traditional financial assistance application process or through presumptive eligibility processes. Before engaging in extraordinary collection actions (ECAs) to obtain payment for EMCare, Hospital Facilities must make reasonable efforts through its billing and collections processes, pursuant to Treas. Reg. §1.501(r)-6(c), to determine whether an individual is eligible for Financial Assistance. In no event will an ECA be initiated prior to 120 days from the date the Facility provides the first post-discharge billing statement (i.e., during the Notification Period) unless all reasonable efforts have been made. Hospital Facilities will not refer accounts for collection where the patient has initially applied for Financial Assistance, and the Hospital Facility has not yet made reasonable efforts with respect to the account. For patients and Guarantors who are unable to provide required documentation, a Hospital Facility may grant Presumptive Financial Assistance based on information obtained from other resources. Patients who qualify for Medicaid are presumed to qualify for full charity write off. Any charges for days or services written off (excluding Medicaid denials related to timeliness of billing, insufficient medical record documentation, missing invoices, authorization, or eligibility issues) as a result of a Medicaid are booked as charity. Some Medicaid plans offer coverage for a limited or restricted list of services. If a patient is eligible for Medicaid, any charges for days or services not covered by the patient's coverage may be written off to charity without a completed application. This does not include any Share of Cost (SOC) or other patient cost-sharing amounts such as deductibles or copayments, as such costs are determined by the state to be an amount that the patient must pay before the patient is eligible for Medicaid. Health and Human Services (HSS) uses the term "Spend Down" instead of Share of Cost. All collection activities conducted by the Facility, a Designated Supplier, or its third-party collection agents will be in conformance with all federal and state laws governing debt collection practices. All third-party agreements governing collection and recovery activities must include a provision requiring compliance with the hospital facilities' financial assistance and billing and collections policy and indemnification for failures as a result of its noncompliance. This includes, but is not limited to, agreements between third parties who subsequently sell or refer debt of the Hospital Facility. Schedule H, Part V, Section B, Line 16a FAP website - PMC HOSPITAL, LLC: Line 16a URL: http://www.chistlukeshealth.org/financial-assistance; Schedule H, Part V, Section B, Line 16b FAP Application website - PMC HOSPITAL, LLC: Line 16b URL: http://www.chistlukeshealth.org/financial-assistance; Schedule H, Part V, Section B, Line 16c FAP plain language summary website - PMC HOSPITAL, LLC: Line 16c URL: http://www.chistlukeshealth.org/financial-assistance; Schedule H, Part VI, Line 2 Needs assessment THE CHNA IS THE PRIMARY WAY BY WHICH THE HOSPITAL FORMALLY ASSESSES COMMUNITY HEALTH NEEDS. Schedule H, Part VI, Line 3 Patient education of eligibility for assistance Notification about the availability of Financial Assistance from CHI Hospital Organizations shall be disseminated by various means, which may include, but not be limited to: * Conspicuous publication of notices in patient bills; * Notices posted in emergency rooms, urgent care centers, admitting/registration departments, business offices, and at other public places as a Hospital Facility may elect; and * Publication of a summary of this Policy on the Hospital Facility's website, www.catholichealth.net, and at other places within the communities served by the Hospital Facility as it may elect. Such notices and summary information shall include a contact number and shall be provided in English, Spanish, and other primary languages spoken by the population served by an individual Hospital Facility, as applicable. Referral of patients for Financial Assistance may be made by any member of the CHI Hospital Organization non-medical or medical staff, including physicians, nurses, financial counselors, social workers, case managers, chaplains, and religious sponsors. A request for assistance may be made by the patient or a family member, close friend, or associate of the patient, subject to applicable privacy laws. In addition, Hospital registration clerks are trained to provide consultation to those who have no insurance or potentially inadequate insurance concerning their financial options including application for Medicaid and for assistance under the Financial Assistance Policy. Counselors assist Medicare eligible patients in enrollment by providing referrals to the appropriate government agencies. Once it is determined that the patient does not qualify for any third party funding, the patient is verbally notified about the existence of Financial Assistance Application and additional screening takes place by a Hospital employee to determine if the patient is eligible for charity service prior to discharge. Upon registration (and once all EMTALA requirements are met), patients who are identified as uninsured (and not covered by Medicare or Medicaid) are provided with a packet of information that addresses the Financial Assistance Policy, the plain language summary of that policy, and an application for assistance. Hospital registration clerks read the organization's medical assistance policy to those who appear to be incapable of reading, and provide translators for non-English-speaking individuals. Patients that have been discharged prior to charity screening, such as emergency room patients, receive a written notification of possible eligibility for services. If the patient is determined not to be eligible for government assistance, he/she may notify the hospital that they seek charity assistance. The appropriate charity form is sent to the patient/guarantor for completion and then returned to the hospital for evaluation and qualification. Once determination of eligibility is made, the patient is sent a notice informing him/her if they qualify for full, partial, or no charity care services. Hospital Facilities must make reasonable efforts through its billing and collections processes, pursuant to Treas. Reg. §1.501(r)-6(c), to determine whether any individual is eligible for Financial Assistance. Schedule H, Part VI, Line 4 Community information CHI ST. LUKE'S HEALTH - PATIENTS MEDICAL CENTER PROVIDES INPATIENT AND OUTPATIENT MEDICAL AND SURGICAL SERVICES TO RESIDENTS OF PASADENA, DEER PARK, LA PORTE, BAYTOWN, AND CLEAR LAKE. THE COMMUNITY SERVED BY THE HOSPITAL IS DESCRIBED BY THE GEOGRAPHIC AREA OF THE CONTIGUOUS ZIP CODES DETERMINED BY DISCHARGE DATA. LOCATED IN HARRIS COUNTY, THE HOSPITAL SERVICE AREA CONTAINS BOTH A LARGE URBAN COMPLEX, AS WELL AS SMALLER RURAL COMMUNITIES, AND IS HOME TO OVER 200,000 WORKING CLASS RESIDENTS REPRESENTING MANY DIVERSE ETHNICITIES AND BACKGROUNDS. INDUSTRIAL AND PETROCHEMICAL COMPANIES ARE LARGE EMPLOYERS IN THIS AREA AND SIGNIFICANTLY INFLUENCE THE LOCAL COMMUNITY. THE SERVICE AREA IS PRIMARILY RESIDENTS IN HARRIS, BRAZORIA AND GALVESTON COUNTIES, AND PREDOMINANTLY HARRIS COUNTY. BELOW ARE DETAILS RELATED TO THE DEMOGRAPHICS OF THE COMMUNITY COMPARED WITH TEXAS: AGE: THE LARGEST DISCREPANCIES IN AGE BETWEEN THE PATIENTS MEDICAL CENTER COMMUNITY AND TEXAS FALL WITHIN 25-34 YEARS (16.2% PATIENTS MEDICAL CENTER COMMUNITY VS. 14.4% TEXAS) AND OLDER THAN 65 YEARS (8.7% PATIENTS MEDICAL CENTER COMMUNITY VS. 10.9% TEXAS). ALL OTHER AGE CATEGORY PERCENTAGES IN THE COMMUNITY ARE SIMILAR TO TEXAS. RACE/ETHNICITY: FEWER RESIDENTS SELF-IDENTIFY AS WHITE NON-HISPANIC IN THE COMMUNITY (32.1%) THAN IN TEXAS (44.3%). COMPARED WITH TEXAS, MORE RESIDENTS OF THE COMMUNITY SELF-IDENTIFY AS HISPANIC (41.4% PATIENTS MEDICAL CENTER COMMUNITY VS. 38.2% TEXAS), BLACK NON-HISPANIC (18.5% PATIENTS MEDICAL CENTER COMMUNITY VS. 11.6% TEXAS) AND ASIAN NON-HISPANIC (6.4% PATIENTS MEDICAL CENTER COMMUNITY VS. 4.0% TEXAS). GENDER: THE HOSPITAL'S COMMUNITY AND TEXAS PRESENT A VERY SIMILAR DISTRIBUTION OF MALES AND FEMALES: MALES ACCOUNTED FOR 50.7% OF THE PATIENTS MEDICAL CENTER POPULATION AND 49.6% OF THE TEXAS POPULATION, AND FEMALES ACCOUNTED FOR 49.3% OF THE PATIENTS MEDICAL CENTER POPULATION AND 50.4% OF THE TEXAS POPULATION. EDUCATION: IN BOTH THE PATIENTS MEDICAL CENTER COMMUNITY AND TEXAS, MOST RESIDENTS AGE 25 YEARS OR OLDER HAVE MORE THAN OR EQUAL TO A HIGH SCHOOL EDUCATION AND/OR GED. HOWEVER, WHEN COMPARED TO TEXAS, THE PATIENTS MEDICAL CENTER COMMUNITY IS HOME TO MORE INDIVIDUALS WITH LESS THAN A HIGH SCHOOL EDUCATION (20.8% PATIENTS MEDICAL CENTER COMMUNITY VS. TEXAS 18.5%). THOSE RESIDING IN HARRIS COUNTY (29%) IDENTIFY AS HAVING MORE COLLEGE, GRADUATE OR PROFESSIONAL, EDUCATION THAN THOSE IN THE STATE OF TEXAS (27%). Schedule H, Part VI, Line 5 Promotion of community health The organization's hospital facility(ies) promote health for the benefit of the community. Medical staff privileges in the hospital are available to all qualified physicians in the area, consistent with the size and nature of its facilities. The organization's hospital facility(ies) have an open medical staff. Its board of trustees is composed of prominent citizens in the community. Excess funds are generally applied to expansion and replacement of existing facilities and equipment, amortization of indebtedness, improvement in patient care, and medical training, education, and research. The facility(ies) treat persons paying their bills with the aid of public programs like Medicare and Medicaid. All patients presenting at the hospital for emergency and other medically necessary care are treated regardless of their ability to pay for such treatment. AS AN INTEGRAL PART OF ST. LUKE'S HEALTH SYSTEM, THE HOSPITAL CONTINUES TO CONTRIBUTE TO ENHANCING COMMUNITY HEALTH CONCERNS, INCLUDING HEALTH IMPROVEMENT, EDUCATION, AND ACCESS TO HEALTH CARE. IT DIRECTS LEADERSHIP TIME AND TALENT TO SERVICE ON COMMUNITY COLLABORATION BOARDS AND HEALTH ADVOCACY PROGRAMS TO PROMOTE THE HEALTH OF THE COMMUNITY, INCLUDING THE "THINK HEALTHY" EDUCATION OUTREACH PROGRAM, THE COURSE ON SAFE SITTER FOR YOUNG TEENS, AND PROGRAMS FOR BREAST CANCER AWARENESS. THE HOSPITAL ALSO WORKS WITH NEIGHBORHOOD RESOURCES (E.G. SCHOOLS, BUSINESSES, COMMUNITY ORGANIZATIONS) TO PROMOTE HEALTH, WELLNESS AND DISEASE PREVENTION THROUGH HEALTH AND SAFETY FAIRS, EDUCATIONAL LECTURES AND SPONSORSHIPS OF VARIOUS COMMUNITY EVENTS. EDUCATION/COMMUNITY HEALTH: EDUCATIONAL PRESENTATIONS AND HEALTH SCREENINGS OFFERED TO THOSE RESIDING IN THE COMMUNITY SERVED BY PATIENT'S MEDICAL CENTER. TARGET POPULATION- SENIOR CITIZENS; ADOLESCENTS (AGE 11-17). EDUCATION/SPEAKERS BUREAU: PHYSICIAN LED EDUCATIONAL PRESENTATIONS AND INFORMATION ARE PROVIDED ON PREVENTION, SCREENING, AND RISK REDUCTION OF VARIOUS CHRONIC DISEASES. TARGET POPULATION- BROAD COMMUNITY; THOSE LIVING IN POVERTY; CLINICAL PROVIDERS. FOR MORE INFORMATION REGARDING THE HOSPITAL'S ACTIVITIES AND ACCOMPLISHMENTS, PLEASE VISIT HTTP://WWW.CHISTLUKESHEALTH.ORG/PMC. Schedule H, Part VI, Line 6 Affiliated health care system The organization is affiliated with CommonSpirit Health. CommonSpirit Health was created by the alignment of Catholic Health Initiatives and Dignity Health as a single ministry in early 2019. CommonSpirit Health, a nonprofit, faith-based health system is committed to building healthier communities, advocating for those who are poor and vulnerable, and innovating how and where healing can happen - both inside its hospitals and out in the community. CommonSpirit Health owns and operates health care facilities in 21 states and comprises 142 hospitals, including three academic health centers, major teaching hospitals as well as 31 critical-access facilities; community health services organizations; accredited nursing colleges; home health agencies; living communities; a medical foundation and other affiliated medical groups; and other facilities and services that span the inpatient and outpatient continuum of care. In fiscal year 2019, CommonSpirit Health provided more than $2.1 billion in financial assistance and community benefit for programs and services for the poor, free clinics, education and research. Financial assistance and community benefit totaled more than $4.4 billion with the inclusion of the unpaid costs of Medicare. The health system, which generated operating revenues of $20.96 billion in fiscal year 2019, has total assets of approximately $40.6 billion. CommonSpirit Health provides strategic planning and management services as well as centralized "share services" for its Divisions. The provision of centralized management and shared services including areas such as accounting, human resources, payroll and supply chain provides economies of scale and purchasing power to the Divisions. The cost savings achieved through CommonSpirit Health's centralization enable Divisions to dedicate additional resources to high-quality health care and community outreach services to the most vulnerable members of our society. Schedule H, Part VI, Line 7 State filing of community benefit report TX true true false false false false false false false Michael Covert FORMER President /BD Member/CEO OF CHI ST. LUKE'S HEALTH SYSTEM 0 145959 0 108433 0 1026603 0 15934 0 2394 0 1299323 0 0 T DOUGLAS LAWSON PHD BOARD MEMBER/CEO of CHI ST. LUKE'S HEALTH SYSTEM 0 733582 0 443750 0 178378 0 126625 0 19644 0 1501979 0 0 SUSAN BAILEY-NEWELL Board Member 0 358529 0 45326 0 20873 0 16375 0 29330 0 470433 0 0 JENNY BARNETT-SARPALIUS FORMER CFO of CHI St. Luke's Health System 0 0 0 0 0 550000 0 0 0 0 0 550000 0 0 MARK MCGINNIS CFO OF CHI ST. LUKE'S HEALTH SYSTEM 0 549815 0 127460 0 80685 0 41025 0 29752 0 828737 0 0 Schedule J, Part I, Line 3 Arrangement used to establish the top management official's compensation During the calendar year 2018, compensation for the top management official was established and paid by Catholic Health Initiatives ("CHI"), a related organization. CHI used the following to establish the top management official's compensation: (1) Compensation Committee; (2) Independent Compensation Consultant; (3) Written Employment Contracts; (4) Compensation Survey or Study; (5) Approval by the Board or Compensation Committee. Schedule J, Part I, Line 4a Severance or change-of-control payment During the calendar year 2018, post-termination payments were addressed in executive employment agreements for Catholic Health Initiatives and related organizations' employees at the level of Vice President and above, including the MBO CEOs. These employment agreements require that in order for the executive to receive post-termination payments, these individuals must execute a general release and settlement agreement. Post-termination payment arrangements are periodically reviewed for overall reasonableness in light of the executive's overall compensation package. The following reportable individuals received severance payments from Catholic Health Initiatives (a Related Organization) during the 2018 calendar year, and these severance payments were included in the individual's W-2 income and reportable compensation on Schedule J: Jennifer Barnett-Sarpalius - $550,000 Michael Covert - $1,008,106 Schedule J, Part I, Line 4b Supplemental nonqualified retirement plan During the 2018 calendar year, Catholic Health Initiatives ("CHI"), a related organization, maintained a supplemental non-qualified deferred compensation plan for MBO CEOs/Presidents and other CHI employees at the level of Senior Vice President and above. Due to the "super" vesting rules under the CHI deferred compensation plan, participants who had met certain requirements such as involuntary termination without cause, age, age and years of service, or more than 5 years of plan participation were eligible to receive their 2018 contributions in cash during the calendar year. These cash payouts are included in the participant's reportable compensation in column (iii) Other Reportable Compensation on Schedule J Part II. During 2018, the following contributions and any associated investment income, gain or loss that would have been made by CHI to the deferred compensation plan were paid in cash: Michael Covert - $15,395 Form 990, Part V, Line 1a FORM 1096 REPORTING PAYMENTS TO VENDORS FOR ENTITIES THAT ARE PART OF CATHOLIC HEALTH INITIATIVES (CHI) ARE MADE BY CHI. THEREFORE NO FORM 1099S ARE ISSUED BY THE ORGANIZATION. CHI FILES THE FORM 1099S AND COMPLIES WITH THE BACKUP WITHHOLDING RULES FOR REPORTABLE PAYMENTS TO VENDORS AND GAMING WINNINGS. THE 1099S ISSUED BY CHI ON BEHALF OF THE ORGANIZATION ARE REPORTED TO THE IRS. Form 990, Part VI, Line 16b HOSPITAL JOINT VENTURE ST. LUKE'S COMMUNITY DEVELOPMENT CORPORATION - PMC (SLCDC-PMC) AND ITS RELATED EXEMPT ORGANIZATION, ST. LUKE'S HEALTH SYSTEM CORPORATION (SLHSC), PARTICIPATE IN A HOSPITAL JOINT VENTURE, PMC HOSPITAL LLC. COMBINED OWNERSHIP OF SLCDC-PMC AND SLHSC OF PMC HOSPITAL IS 51%. THE OPERATING AGREEMENT OF THE HOSPITAL JOINT VENTURE EXPRESSLY STATES THAT THE JOINT VENTURE WILL OPERATE AND CONDUCT ITS ACTIVITIES IN A MANNER THAT SATISFIES THE COMMUNITY BENEFIT STANDARD APPLICABLE TO TAX-EXEMPT HEALTHCARE ORGANIZATIONS, AND THAT THIS COMMUNITY BENEFIT STANDARD SHALL TAKE PRECEDENCE OVER ANY OTHER FIDUCIARY DUTY. IN ADDITION, THE OPERATING AGREEMENT GIVES ST. LUKE'S ENTITIES THE ABILITY TO APPOINT A MAJORITY OF THE JOINT VENTURE'S BOARD OF MANAGERS, AS WELL AS ITS CHAIRMAN. ACTIVITIES OF THE JOINT VENTURE ARE MONITORED THROUGH ST. LUKE'S MAJORITY PRESENCE ON THE JOINT VENTURE'S BOARD OF MANAGERS. Form 990, Part VI, Line 12c Conflict of Interest Policy b) Board evaluation of transactions involving an officer / board member conflict of interest - I. The board carefully scrutinizes and must in good faith approve or disapprove any transaction in which CHI or a CHI entity is a party and in which the trustee or a corporate officer either: 1. Has a material financial interest; or 2. Is a trustee or corporate officer of the other party (other than a CHI affiliated organization). II. The board must approve the transaction by a majority of the trustees on the board (not counting any interested trustee). In reviewing such transactions between CHI or CHI entities and vendors or other contractors who are, or are affiliated with, trustees or corporate officers, the board acts no more or less favorably than it would in reviewing transactions with unrelated third parties. The transaction is not approved unless the board determines that the transaction is fair to CHI or the CHI entity. III. A conflicted trustee or corporate officer is not permitted to use his or her personal influence with respect to the approval or disapproval of the conflicted transaction. However, if requested, such trustee or corporate officer is not prevented from briefly stating his or her position in the matter, nor from answering pertinent questions from trustees, as his or her knowledge may be relevant. The trustee or corporate officer is excused from the meeting during discussion and vote on the conflict of interest. c) Board evaluation of non-transactional conflicts - I. The board carefully reviews and scrutinizes any non-transactional conflict of interest (e.g., disclosure of nonpublic information, competition with CHI or a CHI entity, failure to disclose a corporate opportunity, excessive gifts or entertainment, etc.). II. In such circumstances, by a majority vote of the disinterested trustees, the board takes whatever action is deemed appropriate with respect to the trustee or corporate officer under the circumstances (including possible disciplinary or corrective action) to best protect the interests of CHI or the CHI entity. The board is encouraged to consult with the general counsel of CHI or his or her designee when considering disciplinary or corrective action. III. The conflicted trustee or corporate officer is not permitted to use his or her personal influence with respect to the conflict matter. However, if requested, such trustee or corporate officer is not prevented from briefly stating his or her position in the matter, nor from answering pertinent questions from trustees, as his or her knowledge may be relevant. The trustee or corporate officer is excused from the meeting during discussion and vote on the conflict of interest. d) Record of proceedings - with respect to board member and officer conflicts of interest, minutes of the board are expected to reflect the identity of the individual making the disclosure, the nature of the disclosure, discussion regarding any proposed transaction, the decision made by the board, and that the interested trustee or corporate officer was excused during the discussion, and that the interested trustee abstained from voting. D. Conflicts reporting: All conflicts of interest are reported by CHI as required by law, regulations, and policy. Form 990, Part VI, Line 6 Classes of members or stockholders According to the bylaws of CHI St. Luke's Community Development Corporation - PMC, the entity's sole member is ST. LUKE'S HEALTH SYSTEM CORPORATION, A RELATED EXEMPT ORGANIZATION. Form 990, Part VI, Line 7a Members or stockholders electing members of governing body THE SOLE MEMBER OF THE ORGANIZATION IS ST. LUKE'S HEALTH SYSTEM CORPORATION. THE BOARD OF DIRECTORS CONSISTS OF NOT LESS THAN FOUR ELECTED MEMBERS, ALL OF SUCH MEMBERS TO BE ELECTED BY ST. LUKE'S HEALTH SYSTEM CORPORATION, A RELATED EXEMPT ORGANIZATION. Form 990, Part VI, Line 11b Review of form 990 by governing body THE RETURN WAS MADE AVAILABLE TO THE OFFICERS AND DIRECTORS BEFORE FILING. Subsequent to the return being provided to the board, the tax department files the return with the appropriate federal and state agencies, making any non-substantive changes necessary to effect e-filing. Any such changes are not re-submitted to the board. Form 990, Part VI, Line 12c Conflict of interest policy The organization has a conflicts of interest ("COI") policy (the "policy") in place to maintain the integrity of its activities. Through February 7, 2019, conflicts were administered solely through Catholic Health Initiatives' ("CHI") Governance Policy No. 1 (described below). On February 8, 2019, in connection with the alignment of the Catholic Health Ministries of CHI and Dignity Health, the CommonSpirit Health Board of Stewardship Trustees approved CommonSpirit Health Corporate Responsibility Policy No. G-001, a CommonSpirit Health conflicts of interest policy. This policy stipulates that, at minimum, the pre-closing CHI COI policies and pre-closing Dignity Health COI policies identify the individuals that are covered under the new policy. In addition, subject to certain exceptions, pre-closing CHI COI policies shall continue to apply to the CHI entities and the individuals who were subject to the Pre-Closing CHI COI policies; and the Pre-Closing Dignity Health COI policies shall continue to apply to the Dignity Health entities and the individuals who were subject to the Pre-Closing Dignity Health COI policies. Until CommonSpirit Health adopts a single process for identifying and managing conflicts of interest for all system entities, the following individuals shall be subject to the Pre-Closing CHI COI policies from and after the effective date of Corporate Responsibility Policy No. G-001: 1. Members of the CommonSpirit Health Board of Stewardship Trustees and members of the committees of the Board of Stewardship Trustees; 2. Corporate officers of CommonSpirit Health; 3. Members of the Board of Directors of Dignity Health and members of the committees of the Board of Directors of Dignity Health. CHI Governance Policy No. 1: The policy applies to the following persons: members of the CHI board of stewardship trustees and its committees; members of any CHI direct affiliate or subsidiary (each a CHI entity) board and their committees; employees of CHI entities, and all CHI researchers (as defined in the policy). Disclosure, review and management of perceived, potential or actual conflicts of interest are accomplished through a defined COI disclosure review process. A. Disclosure obligations: 1. Ongoing: Each person is required to promptly and fully disclose to his/her direct manager, supervisor, medical staff office, board or board committee chair any situation or circumstance that may create a conflict of interest. The person must disclose the actual or potential conflict as soon as she/he becomes aware of it. In any situation in which the person is in doubt it is expected that full disclosure be made to permit an impartial and objective determination as to the existence of a conflict. 2. Periodic written: In addition to the ongoing disclosure obligation, periodic written conflict of interest disclosure forms must be completed as follows: a) Initially: 1) Upon hiring (employees), 2) Appointment (board / committee members), 3) Upon consideration of affiliation with research sponsor (researchers). b) Annually: 1) Board / committee members, 2) Employees at the level vice president or above, 3) Researchers, 4) Supply chain employees at the level of vice president and above and those employees involved in contracting regardless of employment level, 5) Other employees as determined by CommonSpirit Health leadership. 3. Failure to disclose - an individual who fails to disclose a perceived, potential, or actual conflict of interest, or all material facts surrounding an actual or potential conflict or fails to abide by the final decision regarding the conflict may be subject to disciplinary or corrective actions such as termination of employment, removal from a board or committee, loss or restriction of clinical privileges, or restrictions on research activities in accordance with applicable laws, regulations, rules, contracts, and bylaws. B. Conflicts review: 1. No disclosed conflicts: In the absence of perceived, potential or actual conflicts of interest, no follow-up conflicts review is required or performed. 2. Disclosure of perceived, potential or actual conflicts: a) Are initially reviewed by national or regional legal or corporate responsibility team members (depending upon the role of the individual disclosing the actual or potential conflict) to determine whether an actual or potential for a conflict may exist. b) If it is determined that a potential or actual conflict may exist, I. In the case of board or committee members or officers, issues are elevated to the executive committee of the board or board chair. II. In the case of other persons, conflicts issues are elevated to the conflicts of interest review committee ("C-CIRC"). C. Conflicts determination and management: 1. Matters elevated to C-CIRC: a) The C-CIRC determines whether a disclosed or otherwise identified interest is a conflict of interest. If the C-CIRC determines that a COI exists, and adequate controls are not in place to mitigate the conflict, the C-CIRC facilitates development of a COI management plan designed to mitigate the conflict. Designated entity staff are responsible for monitoring the COI management plan and for documenting monitoring activities. Notwithstanding the foregoing, at its sole discretion, an entity may reject a person's request to enter into the relationship in question, or require the relationship be sufficiently altered to avoid a potential conflict of interest. b) Appeal - if a person does not agree with a determination made by the C-CIRC, its interpretation of the COI policy, still seeks an exemption or exception, or seeks further clarification of the C-CIRC 's decision, the individual may appeal the decision through his or her manager for reconsideration by the C-CIRC, and the C-CIRC will review and issue a final determination based upon any new or additional information presented. 2. Matters elevated to the executive committee or board chair: a) Determination of existence of conflict - the board chair or his or her designee performs any further investigation of any conflict of interest disclosures as he or she may deem appropriate. If the conflict involves the board chair, the vice chair assumes the chair's role outlined in the COI policy. Based on review and evaluation of the relevant facts and circumstances, the board chair makes an initial determination as to whether a conflict of interest exists and whether, pursuant to the COI policy, review and approval or other action by the board is required. A written record of the board chair's determination, including relevant facts and circumstances, is made. The board chair then makes an appropriate report to the executive committee of the board concerning the COI review, evaluation and determination. If a difference of opinion exists between the board chair and another trustee as to whether the facts and circumstances of a given situation constitute a conflict of interest or whether board review and approval or other action is required under the COI policy, the matter is submitted to the board's executive committee, which makes a final determination as to the matter presented. That determination, including relevant facts and circumstances, is reflected in the executive committee minutes and is reported to the board. (Continued on Schedule O) Form 990, Part VI, Line 19 Required documents available to the public The organization's financial statements, conflict of interest policy and governing documents are available to the public upon request. The organization's financial statements are included in CommonSpirit Health's consolidated audited financial statements that are available at www.commonspirit.org or www.catholichealthinitiatives.org. FORM 990, PART VI, LINE 15A PROCESS FOR DETERMINING COMPENSATION - TOP MANAGEMENT OFFICIAL The organization's top management official's compensation was paid by Catholic Health Initiatives ("CHI"), a related organization. CHI had a defined compensation philosophy. Both the executive and non-executive compensation structures and ranges were reviewed annually in comparison to market data. Catholic Health Initiatives used Korn Ferry as the independent third party to assess executive compensation programs and to ensure the reasonableness of actual salaries and total compensation packages. Compensation of the senior most executives was reviewed annually. Korn Ferry reviewed both cash and total compensation for overall reasonableness, for adherence to Catholic Health Initiatives' compensation philosophy, and for comparability to the not-for-profit healthcare market. This independent review was delivered by Korn Ferry to the CHI HR committee of the Board of Stewardship Trustees annually at their September meeting and minutes shared with the full board at the December meeting. The last review was September 25, 2018. In addition, Korn Ferry completed a comprehensive review of all positions at the level of vice president and above in the fall of 2014 to determine and validate appropriate compensation levels. These levels were reviewed annually and revised based on market data, where applicable. FORM 990, PART VI, LINE 15B PROCESS FOR DETERMINING COMPENSATION - OFFICERS/KEY EMPLOYEES During the tax year ended 6/30/2019, no officers, directors or trustees received compensation from the organization. Any executive compensation paid to officers, directors or trustees by related organizations was set by the related organization's compensation committee utilizing both an independent consultant and comparability studies to determine compensation. Therefore, these questions are more appropriately answered as N/A. FORM 990, PART VI, LINE 14 WRITTEN DOCUMENT RETENTION AND DESTRUCTION POLICY ST LUKE'S HEALTH SYSTEM CORPORATION AND RELATED ENTITIES HAVE A WRITTEN GENERAL POLICY RELATED TO DOCUMENT RETENTION AND DESTRUCTION. DOCUMENTS AND RECORDS ARE RETAINED FOR VARIOUS FEDERAL, STATE OR OTHER JURISDICTION STATUTES FOR MEDICAL OR FINANCIAL REVIEW ON A DEPARTMENT BY-DEPARTMENT BASIS. ALEGENT CREIGHTON CLINIC 12809 W DODGE RD OMAHA NE 68154 470765154 HOSPITAL NE 501(c)(3) 3 ACH false ALEGENT CREIGHTON HEALTH 12809 W DODGE RD OMAHA NE 68154 470757164 HOSPITAL NE 501(c)(3) 3 CHI NEBRASKA false ALEGENT HEALTH - BERGAN MERCY HEALTH SYSTEM 7500 MERCY RD OMAHA NE 68124 470484764 HOSPITAL NE 501(c)(3) 3 CHI NEBRASKA false ALEGENT HEALTH - COMMUNITY MEMORIAL HOSPITAL OF MISSOURI VALLEY IA 631 N 8TH ST MISSOURI VALLEY IA 51555 420776568 HOSPITAL IA 501(c)(3) 3 CHI NEBRASKA false ALEGENT HEALTH - IMMANUEL MEDICAL CENTER 6901 N 72ND ST OMAHA NE 68122 470376615 HOSPITAL NE 501(c)(3) 3 CHI NEBRASKA false ALEGENT HEALTH - MEMORIAL HOSPITAL SCHUYLER 104 W 17TH ST SCHUYLER NE 68661 470399853 HOSPITAL NE 501(c)(3) 3 CHI NEBRASKA false ALEGENT HEALTH - MERCY HOSPITAL CORNING IOWA PO BOX 368 CORNING IA 50841 420782518 HOSPITAL IA 501(c)(3) 3 CHI NEBRASKA false ALVERNA APARTMENTS 300 SE 8TH AVE LITTLE FALLS MN 56345 411351177 LTERM CARE MN 501(c)(3) 10 CSH false APPLETREE COURT 601 OAK ST BRECKENRIDGE MN 56520 411850500 SENIOR LIVING MN 501(c)(3) 10 SFH false Arroyo Grande Community Hospital Foundation 345 S Halcyon Rd Arroyo Grande CA 93420 203256066 FUNDRAISING FOUNDATION CA 501(c)(3) Type I DH false Bakersfield Memorial Hospital 420 34TH Street Bakersfield CA 93301 951802779 HOSPITAL CA 501(c)(3) 3 DCC false Barrow Neurological Foundation 350 West Thomas Road Phoenix AZ 85013 860174371 FUNDRAISING AZ 501(c)(3) 7 DH false BAYLOR ST LUKE'S HEALTH VENTURES 17200 ST LUKES WAY STE 170 THE WOODLANDS TX 77384 274499340 PHYSICIANS TX 501(c)(3) Type I SLCHS false BAYLOR ST LUKE'S MEDICAL GROUP 6624 FANNIN ST STE 1100 HOUSTON TX 77030 760458535 PHYSICIANS TX 501(c)(3) 3 SLHS false BORNEMANN HEALTHCARE CORPORATION 198 INVERNESS DRIVE WEST ENGLEWOOD CO 80112 232187242 HEALTHCARE PA 501(c)(3) Type I CSH false BRAZOSPORT HEALTH FOUNDATION INC 1 West Way Ct LAKE JACKSON TX 77566 760080110 FUNDRAISING FOUNDATION TX 501(c)(3) Type I BRHS false BRAZOSPORT REGIONAL PHYSICIAN SERVICES 100 MEDICAL DRIVE LAKE JACKSON TX 77566 800240261 PHYSICIANS TX 501(c)(3) 3 BRHS false BURLESON ST JOSEPH HEALTH CENTER 2801 FRANCISCAN DRIVE BRYAN TX 77802 742759890 HOSPITAL TX 501(c)(3) 3 SJSC false BURLESON ST JOSEPH MANOR 2801 FRANCISCAN DRIVE BRYAN TX 77802 742913931 HEALTHCARE TX 501(c)(3) 10 SJSC false California Hospital Medical Center Foundation 1401 South Grand Avenue Los Angeles CA 90015 954000909 FUNDRAISING FOUNDATION CA 501(c)(3) Type I DCC false CARRINGTON HEALTH CENTER 800 N 4TH ST CARRINGTON ND 58421 450227311 HOSPITAL ND 501(c)(3) 3 CSH false CATHOLIC HEALTH INITIATIVES - COLORADO 9100 East Mineral Circle Centennial CO 80112 840405257 HOSPITAL CO 501(c)(3) 3 CSH false CATHOLIC HEALTH INITIATIVES - IOWA CORP 1111 6TH AVE DES MOINES IA 50314 420680448 HOSPITAL IA 501(c)(3) 3 CSH false CATHOLIC HEALTH INITIATIVES COLORADO FOUNDATION 1150 Kelly Johnson Blvd 204 COLORADO SPRINGS CO 80920 840902211 FUNDRAISING FOUNDATION CO 501(c)(3) 7 CHIC false CATHOLIC HEALTH INITIATIVES NATIONAL FOUNDATION 1150 Kelly Johnson Blvd 204 COLORADO SPRINGS CO 80920 270930004 HEALTHCARE CO 501(c)(3) Type I CSH false CATHOLIC HEALTH INITIATIVES VIRTUAL HEALTH SERVICES 198 INVERNESS DRIVE WEST ENGLEWOOD CO 80112 460992796 PHYSICIANS CO 501(c)(3) Type I CHINS false CENTENNIAL MEDICAL GROUP INC 2700 STEWART PKWY ROSEBURG OR 97471 263946191 SURGERY CENTER OR 501(c)(3) 10 MMC false CENTRAL KANSAS MEDICAL CENTER 3515 BROADWAY GREAT BEND KS 67530 480543724 HOSPITAL KS 501(c)(3) 3 CSH false CHI HEALTH CONNECT AT HOME - FARGO 4816 AMBER VALLEY PKWY S FARGO ND 58104 271966847 FUNDRAISING FOUNDATION MN 501(c)(3) 10 CSH false CHI HEALTH FOUNDATION 12809 W DODGE RD OMAHA NE 68154 470648586 FUNDRAISING FOUNDATION NE 501(c)(3) 7 ACH false CHI INSTITUTE FOR RESEARCH AND INNOVATION 198 INVERNESS DRIVE WEST ENGLEWOOD CO 80112 271050565 HEALTHCARE CO 501(c)(3) Type I CSH false CHI KENTUCKY INC 3900 OLYMPIC BLVD STE 400 ERLANGER KY 41018 202741651 HEALTHCARE KY 501(c)(3) Type I CSH false CHI LIVING COMMUNITIES 5942 RENAISSANCE PLACE STE A TOLEDO OH 43623 341892096 HEALTHCARE OH 501(c)(3) Type II SFH false CHI Memorial Hospital - Georgia 100 GROSS CRESCENT CIRCLE FORT OGLETHORPE GA 30742 822748395 HOSPITAL GA 501(c)(3) 3 MHCS false CHI NATIONAL HOME CARE 198 INVERNESS DRIVE WEST ENGLEWOOD CO 80112 451261716 HEALTHCARE CO 501(c)(3) 10 CHI NS false CHI NATIONAL SERVICES 198 INVERNESS DRIVE WEST ENGLEWOOD CO 80112 452532084 HEALTHCARE CO 501(c)(3) Type I CSH false CHI NEBRASKA 12809 West Dodge Road Omaha NE 68510 363233121 HEALTHCARE NE 501(c)(3) Type I CSH false CHI ST JOSEPH CHILDREN'S HEALTH 1929 LINCOLN HWY E STE 150 LANCASTER PA 17602 232342997 HEALTHCARE PA 501(c)(3) Type I CSH false CHI ST JOSEPH'S CHILDREN 1516 5TH ST NW ALBUQUERQUE NM 87102 710897107 COMMUNITY NM 501(c)(3) Type I CSH false CHI ST VINCENT HOSPITAL HOT SPRINGS 300 WERNER ST HOT SPRINGS AR 71913 710236913 HOSPITAL AR 501(c)(3) 3 CHISVHS false CHI ST VINCENT HOT SPRINGS 300 WERNER ST HOT SPRINGS AR 71913 261125064 HOLDING CO AR 501(c)(3) Type II SVIMC false CHI ST VINCENT MEDICAL GROUP HOT SPRINGS 300 WERNER ST HOT SPRINGS AR 71913 261125131 PHYSICIANS AR 501(c)(3) 3 CHISVHS false COMMONSPIRIT HEALTH 198 INVERNESS DRIVE WEST ENGLEWOOD CO 80112 470617373 HEALTHCARE CO 501(c)(3) Type I NA false Community Hospital of San Bernardino 1805 Medical Center Drive San Bernardino CA 92411 951643373 HOSPITAL CA 501(c)(3) 3 DCC false COMMUNITY LIMITED CARE DIALYSIS CENTER 619 OAK ST ACCOUNTING-3 W CINCINNATI OH 45206 237419853 HOLDING CO OH 501(c)(4) GSH false COMMUNITY MEMORIAL HOSPITAL MEDICAL SERVICE FOUNDATION 631 N 8TH ST MISSOURI VALLEY IA 51555 421294399 FUNDRAISING FOUNDATION IA 501(c)(3) Type I AH-CMHMV false CONTINUING CARE HOSPITAL One Saint Joseph Drive LEXINGTON KY 40504 611400619 HOSPITAL KY 501(c)(3) 3 SJHS false Dignity Community Care 185 Berry Street Suite 300 San Francisco CA 94107 815009488 HOSPITAL CO 501(c)(3) 3 NA false DIGNITY HEALTH 185 BERRY STREET STE 300 SAN FRANCISCO CA 94107 941196203 HOSPITAL CA 501(c)(3) 3 CSH false Dignity Health Connected Living 200 Mercy Oaks Drive Redding CA 96003 237115371 Senior Center Services CA 501(c)(3) 7 DH false Dignity Health Foundation 185 Berry Street San Francisco CA 94107 462037641 FUNDRAISING FOUNDATION CA 501(c)(3) Type I DH false Dignity Health Foundation - Inland Empire 2101 N Waterman Avenue San Bernardino CA 92404 237440086 FUNDRAISING FOUNDATION CA 501(c)(3) Type I DH false Dignity Health Foundation East Valley 475 South Dobson Road Chandler AZ 85224 742418514 FUNDRAISING FOUNDATION AZ 501(c)(3) Type I DH false Dignity Health HPL Self-Insurance Trust 185 Berry Street San Francisco CA 94107 943006034 Self Insurance CA 501(c)(3) Type I DH false Dignity Health Insurance Nevada Ltd 185 Berry Street San Francisco NV 94107 813800752 Self Insurance NV 501(c)(3) Type I DH false Dignity Health Medical Foundation 3400 Data Drive Rancho Cordova CA 95670 680220314 MULTI-SPECIALTY OUTPATIENT MEDICAL CLINIC CA 501(c)(3) Type I DCC false Dignity Health Workers Comp Self-Insurance Trust 185 Berry Street San Francisco CA 94107 946612446 Self Insurance CA 501(c)(3) Type I DH false Dominican Health Services 1555 Soquel Drive Santa Cruz CA 95065 770056778 Community Health System CA 501(c)(3) Type I DH false Dominican Hospital Foundation 1555 Soquel Drive Santa Cruz CA 95065 942450442 FUNDRAISING FOUNDATION CA 501(c)(3) Type I DH false Dominican Oaks Corporation 1555 Soquel Drive Santa Cruz CA 95065 770127719 Operation and management of housing complex to elderly persons CA 501(c)(3) 10 DHS false East Texas Clinical Services 2801 VIA FORTUNA SUITE 500 AUSTIN TX 78746 454736213 HEALTHCARE TX 501(c)(3) Type I SLHS false ENUMCLAW REGIONAL HOSPITAL ASSOCIATION 1455 BATTERSBY AVE ENUMCLAW WA 98022 910715805 HOSPITAL WA 501(c)(3) 3 FHS false FLAGET HEALTHCARE INC 4305 NEW SHEPHERDSVILLE RD BARDSTOWN KY 40004 611345363 HOSPITAL KY 501(c)(3) 3 KOH false FLAGET MEMORIAL HOSPITAL FOUNDATION INC 4305 NEW 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