2019-08-15T17:34:50-05:00 2018-09-30 430765316 RUBINBROWN LLP 5851 W CHARLESTON BLVD LAS VEGAS NV 89146 990 2017-10-01 237314364 NAVAJO HEALTH FOUNDATION - SAGE MEMORIAL NAVA 9287554500 PO BOX 457 GANADO AZ 86505 MICHAEL KATIGBAK INTERIM CFO 9287554500 2019-08-15 1 HEATHER GRECH P00165182 7028789788 24.234.153.165 2019-08-15 16:55:10 PD P FF1F382E797EE3D05EABFF84EF05A331996E6977 157E94362D87AD908323791A79CDD36DEF7C5F04 2017 2019-02-21 02:37:17Z MICHAEL KATIGBAK PO BOX 457 GANADO AZ 86505 49439475 0 X WWW.SAGEMEMORIAL.COM X 1974 AZ TO PROVIDE QUALITY HEALTHCARE SERVICES IN A FISCALLY RESPONSIBLE MANNER. 6 6 225 30 0 0 428929 72017 121091212 48816220 278582 327079 196504 206413 121995227 49421729 0 0 0 0 10246714 10450050 0 0 0 32084690 40104758 42331404 50554808 79663823 -1133079 143611255 140195449 7544889 5262162 136066366 134933287 OUR MISSION IS TO PROVIDE QUALITY PATIENT CARE IN A FISCALLY RESPONSIBLE MANNER FOCUSING ON THE PATIENTS PHYSICAL, SOCIAL AND SPIRITUAL WELL-BEING. 0 0 43552165 48816220 NAVAJO HEALTH FOUNDATION-SAGE MEMORIAL HOSPITAL CONTRACTED WITH INDIAN HEALTH SERVICES WITH A SELF-DETERMINATION CONTRACT WHICH PROVIDED CARE TO INPATIENTS, OUTPATIENTS, ER PATIENTS, DENTAL, PHYSIOTHERAPY, BEHAVIORIAL HEALTH, OPTOMETRY AND RADIOLOGY. SAGE MEMORIAL HOSPITAL SERVES PRIMARILY MEMBERS OF THE NAVAJO NATION. SAGE MEMORIAL HOSPITAL ALSO ADMINISTERED SPECIAL DIABETES PREVENTION AND TREATMENT FOR NAVAJOS. THE ORGANIZATION HAS DEVELOPED A PUBLIC HEALTH AND SOCIAL SERVICES EMERGENCY RESPONSE PLAN. 43552165 1 1 0 0 0 0 0 0 0 1 1 0 0 0 1 1 1 0 0 0 0 0 0 0 0 0 1 1 0 0 1 0 1 0 0 0 1 0 1 0 0 0 0 0 0 0 0 0 1 242 0 1 225 1 0 0 0 0 0 0 0 0 0 0 X 6 6 0 1 0 1 0 0 0 1 0 0 0 1 1 0 0 1 1 0 1 0 X MIKE KATIGBAK INTERIM CFO 9287554500 PO BOX 457 GANADO AZ 86505 MAYBELLE KELEWOOD BOARD TREASURER 2.00 X X 21500 0 0 ANDREW SIMPSON BOARD MEMBR 2.00 X 21500 0 0 LINDA S YAZZIE BOARD VICE CHAIRPERSON THROUGH MARCH 2018 2.00 X X 22500 0 0 STENSON WAUNEKA BOARD CHAIRPERSON 5.00 X X 42000 0 0 JOYCE MOORE BOARD MEMBER 2.00 X 20000 0 0 RAY ANN TERRY BOARD SECRETARY 2.00 X X 21500 0 0 CHANNARONG JARUVANGSANTI PHARMACIST 40.00 X 171472 0 0 THERESA HENSLER PHARMACIST 40.00 X 160450 0 0 MICHAEL NGUYEN PHARMACIST 40.00 X 143639 0 0 PIO M SIAN PHYSICIAN 40.00 X 262747 0 0 PAUL E HABENER PHYSICIAN 40.00 X 148781 0 0 1036089 0 0 10 0 1 0 RAZAGHI HEALTHCARE 7150 E CAMELBACK RD SUITE 444 SCOTTSDALE AZ 85251 MANAGEMENT SERVICES 11637539 AB STAFFING SOLUTIONS 2680 S VAL VISTA 152 GILBERT AZ 85295 STAFFING 1623898 MANAGEMENT HEALTH SYSTEMS INC 1580 SAWGRASS CORPORATE PKWY SUITE SUNRISE FL 33323 STAFFING 1533216 BARTON ASSOCIATES INC PO BOX 417844 BOSTON MA 02241 STAFFING 1465793 AYA HEALTHCARE 5930 CORNERSTONE CT WEST 300 SAN DIEGO CA 92121 STAFFING 837719 21 72017 72017 ISDEAA REVENUE 900099 29761640 29761640 NET PATIENT REVENUE 900099 18569816 18569816 OTHER REVENUES 900099 484764 484764 48816220 327079 327079 224159 17746 206413 206413 206413 49421729 48816220 0 533492 X 9148630 8451508 697122 106234 98160 8074 597050 551674 45376 598136 552558 45578 12904652 9033256 3871396 684141 478899 205242 699580 489706 209874 12956480 12647254 309226 231672 169196 62476 1394813 1040254 354559 258909 181236 77673 464654 325258 139396 401912 310957 90955 283210 198803 84407 162566 162566 838124 712405 125719 385118 331537 53581 SUPPLIES AND PHARMACEUT 3139393 3060183 79210 CONTRACT HEALTH SERVICE 2666810 2666810 PURCHASED SERVICES 1788004 1537755 250249 BAD DEBT EXPENSE 122818 122818 721902 591938 129964 50554808 43552165 7002643 0 10966 1704428 10243276 95594578 122500000 321117 1287075 1577737 317230 409338 353375 519653 24527558 18467774 6379401 6059784 1179917 31367531 1340015 2641283 143611255 140195449 7466206 4917645 65758 300883 12925 43634 7544889 5262162 X 134359037 133219846 1105420 1111534 601909 601907 136066366 134933287 143611255 140195449 -1133079 0 X X 0 1 X 1 1 1 X X 803062 6113 809175 792938 10124 803062 769772 23166 792938 767958 1814 769772 761219 6739 767958 0.75000 0.25000 0 0 26000 26000 12831783 9174748 3657035 11669775 9293026 2376749 6059784 HOUSING DEPOSITS 14132 OTHER LIABILITIES 29502 43634 X 48986092 -108558 -108558 49094650 327079 327079 49421729 50446248 0 50446248 108560 108560 50554808 PART III, LINE 4: HUBBELL'S TRADING POST MANAGES ALL COLLECTIONS, OBJECTS AND ARTIFACTS IN ACCORDANCE WITH PROPER MUSEUM STANDARDS AND CONDITIONS. PART V, LINE 4: THE ENDOWMENT CONSISTS OF SCANDLING MEMORIAL SCHOLARSHIP FUNDS ESTABLISHED TO PROVIDE FINANCIAL SCHOLARSHIP OPPORTUNITIES FOR FULL-TIME NAVAJO COLLEGE STUDENTS. PART X, LINE 2: FINANCIAL STATEMENT FOOTNOTE 1 PAGE 13 - THE HOSPITAL BELIEVES THAT IT IS IN SUBSTANTIAL COMPLIANCE WITH ALL IRS TAX REGULATIONS AS OF SEPTEMBER 30, 2018, AND THEREFORE HAS NOT RECORDED ANY UNRECOGNIZED TAX BENEFIT OR LIABILITIES FOR INCOME TAXES. SPECIFICALLY, HOSPITAL IS DISCLOSING AN EXCESS BENEFIT TRANSACTION THAT IS ALSO THE SUBJECT OF ONGOING FEDERAL LITIGATION ALLEGING FRAUD, RACKETEERING, CONSPIRACY AND UNLAWFUL TAKING OF $10.8 MILLION AS DESCRIBED MORE THOROUGHLY IN SCHEDULE O HEREIN. PART XI, LINE 2D - OTHER ADJUSTMENTS: BAD DEBT EXPENSE CLASSIFIED AS REDUCTION OF INCOME ON FINANCIAL STATEMENT -122,818. RENTAL EXPENSE REPORTED AS EXPENSE ON FINANCIAL STATEMENT 17,746. OTHER CLASSIFICATION DIFFERENCES -3,486. PART XI, LINE 4B - OTHER ADJUSTMENTS: INVESTMENT INCOME INCLUDED AS OTHER INCOME ON FINANCIAL STATEMENT 320,966. TEMPORARILY RESTRICTED INCOME 6,113. PART XII, LINE 4B - OTHER ADJUSTMENTS: BAD DEBT EXPENSE CLASSIFIED AS REDUCTION OF INCOME ON FINANCIAL STATEMENTS 122,817. RENTAL EXPENSE REPORTED AS EXPENSE ON FINANCIAL STATEMENT -17,746. OTHER CLASSIFICATION DIFFERENCES 3,489. 1 1 0 0 0 0 0 1 122818 0 3668172 3704601 -36429 X 0 1 1 NAVAJO HEALTH FOUNDATIONSAGE MEMORIAL PO BOX 457 GANADO AZ 86505 WWW.SAGEMEMORIAL.ORG X X X X DENTAL AND OPTOMOLOGY SAGE MEMORIAL HOSPITAL 1 0 0 1 X X X X X X X X X 15 1 0 0 1 X X 1 15 0 0 0 1 1 1 1 X 0 0 1 0 0 SAGE MEMORIAL HOSPITAL PART V, SECTION B, LINE 5: SAGE MEMORIAL HOSPITAL ("SMH") ASSEMBLED AN ASSESSMENT TEAM CONSISTING OF HOSPITAL ADMINISTRATION AND EXECUTIVE LEADERSHIP, PUBLIC HEALTH PROFESSIONALS, AND CLINICAL STAFF. THE TEAM CONDUCTED SURVEYS, INTERVIEWS AND FOCUS GROUPS AND RESEARCHED SECONDARY DATA SOURCES TO OBTAIN RELEVANT COMMUNITY HEALTH INFORMATION. THIS INFORMATION WAS THEN ANALYZED AND CROSS-REFERENCED TO PUBLIC DATABASES TO IDENTIFY THE TOP HEALTH CARE NEEDS OF THE COMMUNITY.THE TEAM TOOK A COMPREHENSIVE APPROACH TO ASSESSING THE NEEDS. FIRST THEY ENGAGED WITH THE COMMUNITY TO CAPTURE INPUT ABOUT HEALTH NEEDS AND FACTORS AFFECTING THE ACCESS AND DELIVERY OF HEALTH CARE SERVICES IN THE REGION. THE ASSESSMENT TEAM INDENTIFIED 2 GROUPS TO REPRESENT THE COMMUNITY'S HEALTH INTEREST. (1) INDIVIDUAL MEMBERS OF THE COMMUNITY AND (2) SAGE'S BOARD OF DIRECTORS WHO ARE ALSO COMMUNITY MEMBERS OF THE NAVAJO NATION. THESE GROUPS PARTICIPATED IN SURVEYS AND FOCUS GROUPS COORDINATED BY ASSESSMENT TEAM MEMBERS WITH PUBLIC HEALTH EXPERTISE. THE TEAM ALSO RESEARCHED SECONDARY DATA SOURCES TO BETTER UNDERSTAND THE DEMOGRAPHICS OF THE COMMUNITY AND ASSOCIATED HEALTH ISSUES. THE RESULTS WERE ANALYZED AND REVIEWED WITH THE SMH EXECUTIVE TEAM, MEDICAL STAFF AND PUBLIC HEALTH EXPERTS IN ORDER TO IDENTIFY AND PRIORITZE THE COMMUNITY'S HEALTH NEEDS. SAGE MEMORIAL HOSPITAL PART V, SECTION B, LINE 7D: PAMPHLETS DISTRIBUTED IN THE LOCAL COMMUNITY. SAGE MEMORIAL HOSPITAL PART V, SECTION B, LINE 11: THE HOSPITAL HAS IDENTIFIED AND PRIORITIZED SIGNIFICANT NEEDS OF THE COMMUNITY. TO ADDRESS THE NEEDS, THE HOSPITAL IS EXPANDING BEHAVIORAL HEALTH SERVICES, INCLUDING IMPLEMENTING AN OUTREACH PROGRAM AND COLLABORATING WITH SCHOOLS; EXPANDING PUBLIC IMMUNIZATION PROGRAMS, NUTRITIONAL EDUCATION PROGRAMS AND EXPANDING CAPACITY FOR PEDIATRIC SERVICES; CONTINUE TO EDUCATE COMMUNITY ABOUT DIABETES AND INCREASE COMMUNITY ACTIVITIES, DEVELOP A WELLNESS PROGRAM, AND EXPAND HEALTH SCREENINGS; EXPAND ACCESSIBILITY TO HEALTHCARE SERVICES AND COORDINATE PATIENT HOME VISITS AND EXPAND ER SERVICES ALONG WITH A FOCUS ON RECRUITING AND TRAINING IN ALL AREAS. LONG TERM PLANS INCLUDE AN OUTPATIENT MEDICAL CENTER AND NEW HOSPITAL. 4 1 - OUTPATIENT CLINIC PO BOX 457 GANADO AZ 86505 OUTPATIENT SERVICES 2 - SPECIALITY CLINIC PO BOX 457 GANADO AZ 86505 CARDIOLOGY AND ECHO 3 - DENTAL CLINIC PO BOX 457 GANADO AZ 86505 DENTAL SERVICES 4 - GREASEWOOD CLINIC PO BOX 457 GANADO AZ 86505 DENTAL AND OUTPATIENT SERVICES PART I, LINE 3C: THE ORGANIZATION PRIMARILY SERVICES MEMBERS OF THE NAVAJO NATION. UNDER AGREEMENTS WITH INDIAN HEALTH SERVICES, IF TRIBAL MEMBERS DO NOT HAVE INSURANCE AND/OR ARE NOT ELIGIBLE FOR MEDICARE OR MEDICAID, THE HOSPITAL BEARS THE COST OF PROVIDING MEDICAL SERVICES. PRIOR TO COVERING THE COSTS, THE HOSPITAL VERIFIES ALL ALTERNATIVE INSURANCE OPTIONS HAVE BEEN APPLIED FOR AND OBTAINS PROOF OF INDIAN HERITAGE. PART III, LINE 4: FINANCIAL STATEMENT FOOTNOTE 1 PAGE 9 - THE CARRYING AMOUNT OF PATIENT RECEIVABLES IS REDUCED BY A VALUATION ALLOWANCE THAT REFLECTS MANAGEMENT'S BEST ESTIMATE OF AMOUNTS THAT WILL NOT BE COLLECTED FROM PATIENTS AND THIRD-PARTY PAYORS. MANAGEMENT REVIEWS PATIENT RECEIVABLES BY PAYOR CLASS AND APPLIES PERCENTAGES TO DETERMINE ESTIMATED AMOUNTS THAT WILL NOT BE COLLECTED FROM THIRD PARTIES UNDER CONTRACTUAL AGREEMENTS AND AMOUNTS THAT WILL NOT BE COLLECTED FROM PATIENTS DUE TO BAD DEBTS. MANAGEMENT CONSIDERS HISTORICAL WRITE OFF AND RECOVERY INFORMATION IN DETERMINING THE ESTIMATED BAD DEBT PROVISION. THE DIFFERENCE BETWEEN THE AMOUNTS BILLED AND THE AMOUNTS ACTUALLY COLLECTED AFTER ALL REASONABLE COLLECTION EFFORTS HAVE BEEN EXHAUSTED IS CHARGED OFF AGAINST THE VALUATION ALLOWANCE. PART III, LINE 8: IT IS A COMMUNITY BENEFIT FOR THE HOSPITAL TO PROVIDE SERVICES REGARDLESS OF MEDICARE SURPLUS OR SHORTFALL. THE SOURCE USED IS MEDICARE'S COST REPORT COMPLETED BY THE HOSPITAL FOR FISCAL YEAR END 2017. PART VI, LINE 2: THE HOSPITAL CONDUCTED ITS MOST RECENT COMMUNITY HEALTH NEEDS ASSESSMENT DURING THE FISCAL YEAR ENDED SEPTEMBER 30, 2016 (TAX YEAR 2015). THE HOSPITAL IS IN THE PROCESS OF COMPLETING A NEW COMMUNITY HEALTH NEEDS ASSESSMENT. PART VI, LINE 3: UPON ADMITTANCE, PATIENTS ARE INFORMED OF THE POLICIES, EDUCATED ON THE VARIOUS ASSISTANCE PROGRAMS AVAILABLE AND THEY ARE GIVEN FORMS TO ASSIST IN COMPLETING FINANCIAL ASSISTANCE PAPERWORK. THE EMPLOYEES IN ADMITTING HAVE A CHECKLIST OF INFORMATION AND FORMS THEY ARE TO PROVIDE TO THE PATIENTS. PART VI, LINE 4: THE ORGANIZATION PRIMARILY SERVICES THE MEMBERS OF THE NAVAJO NATION AND OTHER RESIDENTS OF GRAZING DISTRICT 17 AND THE NAZLINI CHAPTER LOCATED WITHIN THE STATE OF ARIZONA. X 1 1 X X 0 0 0 0 0 0 0 0 0 CHANNARONG JARUVANGSANTI PHARMACIST 171472 0 0 0 0 0 0 0 0 0 171472 0 0 0 THERESA HENSLER PHARMACIST 160450 0 0 0 0 0 0 0 0 0 160450 0 0 0 PIO M SIAN PHYSICIAN 262747 0 0 0 0 0 0 0 0 0 262747 0 0 0 PART I, LINE 1A DUE TO LIMITED HOUSING AVAILABLE IN THE AREA, THE ORGANIZATION OFFERS HOUSING ON PROPERTY FOR A MONTHLY RENTAL FEE. RAZAGHI HEALTHCARE MANAGEMENT COMPANY $10,855,134 UNAUTHORIZED AND UNAPPROVED ACH PAYMENT TO RAZAGHI HEALTHCARE UNDER GUISE OF MANAGEMENT CONTRACT DISPUTE PAYMENT AS DISCLOSED IN SCHEDULE O 0 AHMAD RAZAGHI CEO/RH OWNER/PRESIDENT SAME AS THE DESCRIPTION OF TRANSACTION FOR RAZAGHI HEALTHCARE 0 TAUSIF HASAN CONTRACTED CFO VIA RH SAME AS THE DESCRIPTION OF TRANSACTION FOR RAZAGHI HEALTHCARE 0 RAZAGHI DEVELOPMENT COMPANY DBA RAZAGHI HEALTHCARE LLC OFFICERS AND KEY EMPLOYEES WORK FOR RAZAGHI HEALTHCARE, LLC 6075245 RAZAGHI HEALTHCARE LLC ("RH") MANAGED HOSPITAL OPERATIONS UNDER A MANAGEMENT CONTRACT, AS FURTHER DISCLOSED IN PART VI, SECTION A, LINE 3. UNDER THE CONTRACT, RH HAD THE AUTHORITY AND RESPONSIBILITY TO OVERSEE THE SUPERVISION AND EFFECTIVE MANAGEMENT OF THE BUSINESS OPERATIONS OF THE HOSPITAL. THE CEO, AHMAD RAZAGHI, CFO, TAUSIF HASAN, AND OTHER KEY EMPLOYEES WERE EMPLOYED BY RH THROUGH AUGUST 2018 WHEN THE MANAGEMENT AGREEMENT ENDED. RH RECEIVED AN HOURLY RATE FOR THE PERSONNEL IT PROVIDED DEPENDING ON THE TYPE OF SERVICE PROVIDED BY THE INDIVIDUAL IN ADDITION TO A MANAGEMENT SERVICE FEE FOR PERFORMING SUCH SERVICES. THE MANAGEMENT AGREEMENT IS CURRENTLY THE SUBJECT OF ONGOING FEDERAL LITIGATION DESCRIBED IN MORE DETAIL IN SCHEDULE O HEREIN. THE HOSPITAL WILL CONTINUE TO WORK WITH ITS LEGAL AND TAX ADVISORS FOR COMPLIANCE WITH ALL REGULATORY AUTHORITIES. 0 AHMAD RAZAGHI CEO/RH OWNER/PRESIDENT PART OF ABOVE 0 TAUSIF HASAN CONTRACTED CFO VIA RH PART OF ABOVE 0 FORM 990, PART VI, SECTION A, LINE 3 THE ORGANIZATION CONTRACTED WITH RAZAGHI DEVELOPMENT COMPANY DBA RAZAGHI HEALTHCARE LLC ("RH") TO MANAGE HOSPITAL OPERATIONS UNDER A MANAGEMENT AGREEMENT. THE SECOND AMENDED MANAGEMENT AGREEMENT BECAME EFFECTIVE JUNE 16, 2017 AND INCLUDED AN EXPIRATION DATE OF SEPTEMBER 30, 2025 BUT ENDED IN AUGUST 2018 AS FURTHER EXPLAINED BELOW. ACCORDING TO THE SECOND AMENDED MANAGEMENT AGREEMENT, ALL MATTERS REQUIRING PROFESSIONAL MEDICAL JUDGMENT REMAINED THE RESPONSIBILITY OF THE HOSPITAL'S MEDICAL STAFF AND PROFESSIONALS. RH HAD THE AUTHORITY AND RESPONSIBILITY TO OVERSEE THE SUPERVISION AND EFFECTIVE MANAGEMENT OF THE DAY-TO-DAY BUSINESS OPERATIONS OF THE HOSPITAL. ADDITIONALLY, RH WAS REQUIRED TO PERFORM THE DUTIES AND RESPONSIBILITIES OF THE CHIEF EXECUTIVE OFFICER, INCLUDING PERSONNEL RECRUITMENT, HIRING, PROMOTION, DISCIPLINING, AND FIRING. THE AGREEMENT ENDED IN AUGUST 2018 AND THE HOSPITAL FILED A CIVIL RICO COMPLAINT IN THE UNITED STATES DISTRICT COURT, DISTRICT OF NEVADA ALLEGING THAT RH COMMITTED FEDERAL AND STATE RACKETEERING AND CONSPIRACY VIOLATIONS AND COMPLETED AN UNLAWFUL AND FRAUDULENT TAKING OF FUNDS UNDER THE GUISE OF A MANAGEMENT AGREEMENT DISPUTE. FORM 990, PART VI, SECTION A, LINE 5 THE HOSPITAL HAD A MANAGEMENT AGREEMENT WITH RAZAGHI DEVELOPMENT COMPANY DBA RAZAGHI HEALTHCARE ("RH") THAT WAS SCHEDULED TO EXPIRE IN SEPTEMBER 2025 BUT WAS ENDED IN AUGUST 2018. IN AUGUST 2018, RH TOOK $10,855,134 UNDER THE GUISE OF A MANGEMENT AGREEMENT DISPUTE. THE TRANSACTION WAS NOT APPROVED BY THE BOARD. THE HOSPITAL HAS FILED A CIVIL RICO COMPLAINT IN THE UNITED STATES DISTRICT COURT, DISTRICT OF NEVADA ALLEGING THAT RH COMMITTED FEDERAL AND STATE RACKETEERING AND CONSPIRACY VIOLATIONS AND COMPLETED AN UNLAWFUL AND FRAUDULENT TAKING OF THE FUNDS. THE COMPLAINT IS SEEKING COMPENSATORY AND PUNITIVE DAMAGES AND EMERGENCY INJUCTIVE RELIEF AGAINST RH, AHMAD RAZAGHI (RH'S OWNER), INDIVIDUALLY, AND TAUSIF HASAN, THE FORMER CFO CONTRACTED THROUGH THE RH MANAGEMENT AGREEMENT. IT IS THE HOSPITAL'S POSITION THAT THE $10.8 MILLION UNAUTHORIZED AND UNAPPROVED ACH WAS FRAUDULENT AND WAS PART OF A CIVIL CONSPIRACY AND THAT AHMAD RAZAGHI AND TAUSIF HASAN BREACHED THEIR FIDUCIARY DUTIES. THE HOSPITAL BELIEVES HAD THERE BEEN A BREACH OF THE MANAGEMENT CONTRACT, THE HOSPITAL SHOULD HAVE BEEN GIVEN A 30 DAY CURE PERIOD AS REQUIRED BY THE CONTRACT AND THAT ANY CONTRACT TERMINATION PAYMENT SHOULD HAVE BEEN CALCULATED PURSUANT TO THE CONTRACT AND APPROVED BY THE BOARD PRIOR TO PAYMENT AND THE FUNDING OF SUCH PAYMENT WOULD HAVE BEEN PAID THROUGH THE RESTRICTED ESCROW ACCOUNT AS DESCRIBED IN AN ESCROW AGREEMENT EXECUTED WITH RESPECT TO THE MANAGEMENT AGREEMENT. INSTEAD OF ARBRITRATION, RH CHOSE TO UNILATERLLY PAY ITSELF $10.8 MILLION WITH MEDICAID (FEDERAL AND STATE FUNDS) WITHOUT THE GOVERNING BOARD'S VERBAL OR WRITTEN APPROVAL. FORM 990, PART VI, SECTION A, LINE 8B THE BOARD DID NOT HAVE FORMAL COMMITTEE'S WITH AUTHORITY TO ACT ON BEHALF OF THE GOVERNING BODY. FORM 990, PART VI, SECTION B, LINE 11B A SUBSTANTIALLY REVISED DRAFT VERSION OF FORM 990 IS PROVIDED TO THE ENTIRE BOARD PRIOR TO THE FILING OF FORM 990. SUBSEQUENT ADDITIONAL DUE DILIGENCE WITH HOSPITAL LEGAL AND TAX ADVISORS ARE UNDERTAKEN BY THE CFO AND HOSPITAL MANAGEMENT IN ORDER TO COMPLETE AND SUBMIT THE FINAL 990. FORM 990, PART VI, SECTION B, LINE 12 QUESTION 12A - BOARD OF DIRECTORS ARE REQUIRED TO COMPLY WITH THE HOSPITAL'S BYLAWS THAT INCLUDE A CONFLICT OF INTEREST POLICY. QUESTIONS 12B AND C - THE MANAGEMENT COMPANY WAS RESPONSIBLE FOR THE WRITTEN CONFLICT OF INTEREST POLICY AND OTHER OPERATING POLICIES OF THE HOSPITAL. THE MANAGEMENT COMPANY ASSERTED ITS CONTRACTUAL RESPONSIBILITY TO BE THE SOLE PROVIDER OF LEGAL AND OTHER ADVISORS ON BEHALF OF THE HOSPITAL PRIOR TO SEPTEMBER 2018. FORM 990, PART VI, SECTION B, LINE 15B REMUNERATION OF KEY EXECUTIVES AND OFFICERS WERE COMMENSURATE WITH THE MARKET, ROLE, APPLICANT'S EDUCATION-EXPERIENCE-SKILLS AND WERE SUBJECT TO APPROVAL AND ACCEPTANCE BY THE BOARD OF DIRECTORS. SEVERAL OF THE KEY OFFICERS WERE PAID THROUGH THE MANAGEMENT CONTRACT. FORM 990, PART VI, SECTION C, LINE 18 DOCUMENTS ARE AVAILABLE UPON REQUEST FORM 990, PART VI, SECTION C, LINE 19 DOCUMENTS ARE AVAILABLE UPON REQUEST FORM 990, PART IX, LINE 11G CONSULTANTS AND AGENCY PERSONNEL: PROGRAM SERVICE EXPENSES 12,647,254. MANAGEMENT AND GENERAL EXPENSES 309,226. FUNDRAISING EXPENSES 0. TOTAL EXPENSES 12,956,480. FORM 990, PART XII, LINE 2C: PRIOR TO SEPTEMBER 2018, THE OVERSIGHT OF THE AUDIT OF THE ORGANIZATION'S FINANCIAL STATEMENTS WAS PERFORMED BY THE MANAGEMENT COMPANY. FOR THE YEAR ENDED SEPTEMBER 30, 2018, THE EXECUTIVE MANAGEMENT TEAM ALONG WITH ASSISTANCE FROM FINANCIAL CONSULTANTS OVERSAW THE AUDIT. THE AUDITED FINANCIAL STATEMENTS, ALONG WITH FINDINGS NOTED DURING THE AUDIT, WERE PRESENTED TO THE BOARD BY THE INDEPENDENT ACCOUNTING FIRM.