2014-10-31T16:41:18-07:00 2013-12-31 990 2013-01-01 135656874 BLUE CROSS AND BLUE SHIELD ASSOCIATION BLUE 3122976000 225 North Michigan Avenue Chicago IL 60601 Robert Kolodgy Sr. VP & Chief Financial Officer 3122976000 2014-11-07 2013 2015-11-30 17:44:51Z Scott P Serota 225 North Michigan Avenue Chicago IL 60601 421060363 0 X www.bcbs.com X 1948 IL The organization's tax exempt purpose is promoting through independent BCBS member (Plans), the common good and general welfare of the community by fostering broad-based health insurance coverage. 38 37 1234 0 16230694 -1991801 0 0 401706209 412878752 894806 975908 64389 54823 402665404 413909483 0 0 0 0 170867694 179879571 0 0 0 230723477 245262984 401591171 425142555 1074233 -11233072 545808284 588221414 441368086 453203066 104440198 135018348 The Association serves its membership consisting of independent Blue Cross and Blue Shield Plans (Plans) which operates within specified geographic service areas. The Association provides a variety of services to member Plans and coordinates government services such as the Medicare Part A prime contract and the contract under the Federal Employee Health Benefit Program (FEP); all of which are the core of the organization's exempt purpose of promoting the common good and general welfare of the community by fostering broad-based health insurance coverage. 0 0 124572843 124706147 The Blue Cross and Blue Shield Association's Federal Employee Program (FEP) administers the Blue Cross and Blue Shield Service Benefit Plan. Approximately 61 percent of all federal employees and retirees who received their health care benefits through the government's Federal Employees Health Benefits Program (FEHBP) are members of the Service Benefit Plan receiving health coverage through member Plans. Service Benefit Plan has been part of the FEHBP since its inception in 1960 and is the largest plan in the program. The FEP program provides service to more than 5.2 million members and maintained a retention rate of 99 percent. Accomplishments in 2013 were related to expanding the Blues presence in the FEHBP market and managing the Blues entry in the OPM Multi-state Plan Program. Enhanced benefits, steady premiums, and active policy and advocacy support with OPM and Congress bolstered the Blues' leading position in the Federal Employee Program. The program also successfully negotiated a contract to participate in the Multi-state Program starting Jan. 1, 2014. 102590165 102433307 The BlueCard program is a clearinghouse service provided when a member Plan participant receives healthcare in another member Plan geographic service area. BlueCard gives Blue members seamless national access to the 92 percent of physicians and 96 percent of hospitals that participate in Blue networks. The program links participating healthcare providers with the independent Blue Cross and Blue Shield Plans through a single electronic network for claims processing and reimbursement. The BlueCard for Public Exchange Products initiative focus in 2013 was developing a qualified health plan (QHP) exchange standards implementation guide for use by Blue Plans to ensure future services include flexible out-of-area network options for their individual and small group public Exchange members. During 2013, BCBSA negotiated and signed the terms of the Multi-State Plan Program standard contract for the plan year 2014 with the Office of Personnel Management. 53179698 56339575 As the umbrella organization for the member Plans, the Association coordinates advertising and communications programs, providing policy and representation of member interests, monitors and fosters the financial stability of all the Plans and supports the ability of the Plans to operate efficiently by providing conferences, consulting and miscellaneous services to the Plans. 39004027 39004027 The Association develops, enhances and protects the value of the Blue Cross and Blue Shield brand names and symbols and supports the oversight and management of member Plan license agreements. 38014668 38516806 The Association provides optional consulting services and other miscellaneous services. 17976475 16062062 National Data Warehouse (NDW) is a central data warehouse composed of aggregate standardized and de-identified data (such as medical and drug claims, membership and other provider information) obtained from participating member plans for use in complementing the analytical systems within each of the Plans to improve business intelligence and for the benefit of understanding and managing health care costs and quality via benchmarking and trend analysis. 12191815 12469509 Operation of the National Employee Benefits Administration Program which provides a comprehensive group package of employee benefits programs to the Plans. 10173650 17953022 Operation of the telecommunications network which facilitates inter-plan communication. 5394297 5394297 The Association performs services for the Medicare A program and other services agreements with the Secretary of the United States Department of Health and Human Services (DHHS). BCBSA acts in a coordinating role for all Blue Cross and Blue Shield Plans to perform certain aspects of the Medicare A intermediary functions and other government business services provided to Plans. The Association provides additional services to DHHS through contracts with the Agency for Healthcare Research and Quality (AHRQ). 0 0 -51955 K-1 Partnership Pass Through (Loss) from BlueCross BlueShield Venture Partners, LP II. (Loss) is attributed to partnership portfolio companies whose goods and service are consistent with the filing entities tax exempt purpose. 122754932 0 129347768 403097638 0 0 1 1 0 0 0 1 0 1 1 0 0 1 1 0 1 0 0 0 0 0 0 0 0 0 0 0 1 0 0 0 0 0 0 1 1 0 0 0 0 0 1 1 1 0 1 230 0 1 1234 1 1 1 0 0 0 0 0 X 38 37 1 0 0 0 1 1 1 1 1 0 1 1 1 1 1 1 1 1 1 1 1 1 IL X Robert J Kolodgy 3122976462 225 North Michigan Avenue Chicago IL 60601 David W Anderson BoardMember 1.20 0 X 0 0 0 Peter Andruszkiewicz BoardMember 1.60 0 X 0 0 0 Richard L Boals BoardMember 1.80 0 X 0 0 0 Christopher Booth BoardMember 1.40 0 X 0 0 0 H R Brereton Barlow BoardMember 2.50 0 X 0 0 0 Chester Burrell BoardMember 1.70 0 X 0 0 0 John Cannon BoardMember 2.90 0 X 0 0 0 Denise S Cesare BoardMember 0.90 0 X 0 0 0 Andrew C Corbin BoardMember 2.20 0 X 0 0 0 Andrew Dreyfus BoardMember 1.80 0 X 0 0 0 Paul von Ebers BoardMember 1.50 0 X 0 0 0 John D Forsyth BoardMember 3.00 0 X 0 0 0 Mike Frank BoardMember 1.40 0 X 0 0 0 Mark B Ganz BoardMember 2.20 0 X 0 0 0 David R Gentile BoardMember 1.50 0 X 0 0 0 Don C George BoardMember 1.40 0 X 0 0 0 Patrick J Geraghty BoardMember 2.90 0 X 0 0 0 Zelda Geyer-Sylvia BoardMember 1.20 0 X 0 0 0 Michael A Gold BoardMember 0.90 0 X 0 0 0 Bill Gracey BoardMember 1.80 0 X 0 0 0 Michael Guyette BoardMember 2.20 0 X 0 0 0 Patricia A Hemingway Hall BoardMember 2.80 0 X 0 0 0 Daniel J Hilferty BoardMember 2.60 0 X 0 0 0 Terry D Kellogg BoardMember 2.80 0 X 0 0 0 Scott D Kreiling BoardMember 1.10 0 X 0 0 0 Daniel J Loepp BoardMember 3.10 0 X 0 0 0 Scott B Lynch BoardMember 0 0 X 0 0 0 Paul Markovich BoardMember 1.70 0 X 0 0 0 Robert A Marino BoardMember 1.50 0 X 0 0 0 Steven S Martin BoardMember 2.40 0 X 0 0 0 Alphonso ONeil White BoardMember 1.60 0 X 0 0 0 David S Pankau BoardMember 1.90 0 X 0 0 0 M Carol Pigott BoardMember 1.20 0 X 0 0 0 Michael Reitz BoardMember 2.00 0 X 0 0 0 Ramon M Ruiz Comas BoardMember 2.20 0 X 0 0 0 Rick Schum BoardMember 1.50 0 X 0 0 0 Gary D St Hilaire BoardMember 1.10 0 X 0 0 0 Joseph Swedish BoardMember 3.50 0 X 0 0 0 P Mark White BoardMember 2.00 0 X 0 0 0 J Bradley Wilson BoardMember 2.80 0 X 0 0 0 William Winkenwerder BoardMember 1.20 0 X 0 0 0 Scott P Serota President & CEO 40 0 X 4210274 0 1467975 William A Breskin VP, Government Programs 40 0 X 420380 0 111494 Paul F Brown VP, Venturing 40 0 X 325774 0 2777 William J Colbourne SR VP, HR and Administration 40 0 X 629462 0 113780 Frank E Coyne VP, Operations & Ntl Programs 40 0 X 573975 0 158464 Kathy R Didawick VP, Congressional Comm 40 0 X 341307 0 73662 John T Ericksen VP, Federal Relations 40 0 X 464150 0 100540 Jena Estes VP, Government Programs 40 0 X 380984 0 93718 Alissa T Fox SR VP, Policy & Representation 40 0 X 858630 0 155669 Paul Gerrard VP, Strategic Communications 40 0 X 323553 0 30305 Sudhama Gopalan VP, Strategy 40 0 X 217695 0 10831 Justine G Handelman VP, Legislative & Regulatory Policy 40 0 X 386375 0 81956 Trent T Haywood SR VP, Chief Medical Officer 40 0 X 389071 0 38920 Kari J Hedges VP, National Programs 40 0 X 348251 0 33932 Mitchell J Helfand VP, Finance 40 0 X 313276 0 148140 Robert J Kolodgy SR VP, FSGP and CFO 40 0 X 640134 0 39206 Shirley S Lady VP, Transformation Services 40 0 X 367347 0 111603 William S Nehs VP, Dep Gen Counsel Asst Sec 40 0 X 347428 0 35512 William B OLoughlin VP, Operational Readiness 40 0 X 461650 0 110178 Doug Porter SR VP, Chief Information Officer 40 0 X 642983 0 80821 Cynthia P Rolfe VP, Consumer Brand Strategy 40 0 X 349943 0 16279 Maureen E Sullivan SR VP, Strategic Services and CSO 40 0 X 676824 0 108978 Cheryl L Thomas VP, Human Resources 40 0 X 267015 0 36573 Jennifer Vachon VP and Chief of Staff 40 0 X 400999 0 77945 Jody A Voss VP, Strategic Business Services 40 0 X 374502 0 61323 Roger G Wilson SR VP, Gen Counsel & Secretary 40 0 X 716217 0 118708 John Cerisano Exec Dir, Congress Relations 40 0 X 375709 0 114731 Carole R Flamm Exec Med Dir, Ctr for Clinic Value 40 0 X 333742 0 72198 Daniel A Engel Sr Assoc Gen Counsel 40 0 X 305265 0 108145 Nasir Khan Exec Dir, Enterprise Informatics 40 0 X 299501 0 89471 Steven D Putziger Exec Dir, Brand Protect & Finance 40 0 X 320919 0 63516 Allan M Korn Former Officer 0 0 X 362671 0 1129 17426006 0 3868479 571 1 1 0 HP ENTERPRISE SERVICES LLC PO Box 92013 Chicago IL 60675 Systems Consulting 9405288 HEALTH INTELLIGENCE CO LLC 225 N Michigan Aveunue Chicago IL 60601 Data Analytics 7260950 AXA ASSISTANCE USA INC 122 S Michigan Avenue Chicago IL 60602 Medical Claims Processing 4571504 KIRKLAND & ELLIS 200 E Randolph Drive Chicago IL 60601 Legal Services 4530238 HEWITT ASSOCIATES LLC 100 Half Day Road Lincolnshire IL 60069 Actuarial Consulting Services 3784863 121 0 Federal Employee Program 900099 124706147 124706147 0 0 BlueCard 900099 102433307 102433307 0 0 Other Services 900099 56339575 56279377 60198 0 Brand Enhancement & Protection 900099 39004027 39004027 0 0 Consulting & Misc Services 900099 38516806 38515150 1656 0 51878890 35816828 16062062 0 412878752 1070660 0 0 1070660 0 0 0 0 0 0 0 0 0 0 7056128 0 6965669 185211 90459 -185211 -94752 0 0 -94752 Service Fee Revenue 525990 119041 0 119041 0 Partnership Pass Through Loss 900001 -64218 -51955 -12263 0 0 0 0 0 54823 413909483 396702881 16230694 975908 X 0 0 0 0 0 0 0 0 17188391 13809608 3378783 0 0 0 0 0 120387608 115360793 5026815 0 15323884 7048873 8275011 0 18151453 17323856 827597 0 8828235 8564809 263426 0 0 0 0 0 14479298 13974642 504656 0 691349 691349 0 0 4692925 4692925 0 0 0 0 0 0 0 0 128495770 127696308 799462 0 8413577 8413577 0 0 9145666 9063871 81795 0 33073005 32447088 625917 0 0 0 0 0 11615150 11172670 442480 0 5496113 4996816 499297 0 0 0 0 0 4199326 3666807 532519 0 26051 690 25361 0 0 0 0 0 14355126 14168826 186300 0 3772799 3737393 35406 0 Membership, Sponsorship, Gen'l Contribution 4844490 4366317 478173 0 Books & Periodicals 1812966 1763454 49512 0 149373 136966 12407 0 425142555 403097638 22044917 0 692444 711793 327372324 368976369 24332048 28053132 0 0 5014976 386485 0 9153032 14109695 92677546 71012472 25664715 21665074 15000 15000 132369364 145710892 0 0 4498115 3662752 16696266 4930222 545808284 588221414 91845720 93095762 0 1683739 4364488 276009273 312923125 0 0 0 0 0 0 71829354 42819691 441368086 453203066 X 104440198 135018348 0 0 0 0 104440198 135018348 545808284 588221414 X -11233072 -944054 0 0 -3283 42758559 X 0 1 X 1 0 507165 0 0 300000 300000 1 Democratic Governor's Association 1401 K Street NW Ste 200 Washington DC 20005 521304889 125000 0 Republican Governor's Association 1747 Pennsylvania Ave NW Ste 250 Washington DC 20006 113655877 100000 0 Republican State Leadership Committee 1201 F Street NW Ste 675 Washington DC 20004 050532524 50000 0 Democratic Attorney General Association 1580 Lincoln Street Ste 1125 Denver CO 80203 134220019 25000 0 0 0 0 89500000 11792658 0 11792658 11792658 0 0 Schedule C, Part I-A, Line 1 The filing organization made contributions from the general treasury to four Section 527 political organizations and sponsored a separate fund designated for exempt purposes. 0 1 X 0 0 0 0 0 0 0 0 28226151 16155956 12070195 0 64451395 54856516 9594879 0 0 0 0 21665074 0 0 Non Public Mutual Funds 83182929 C Wells Fargo Mutual Funds (MNSGX) 43203747 F 1 share common BCBSA Services, Inc. 13262469 C Investments in Affiliates >5% 5851747 C 206,889 Common, BCS Insurance Corp 210000 C 145710892 0 Pension Liability 16327134 Long-Term Deferred Revenue 15299999 Lease Liability 8432282 Other Benefits 2760276 42819691 X Schedule D, Part IV, Line 2b The Association holds funds as agent for its member Plans under arrangements covering its Blue Card and Federal Employee Program. Schedule D, Part X, Line 2 The Association follows the requirements of ASC 740-10-25 "Accounting for Uncertainty in Income Taxes," which clarifies the accounting and disclosure for uncertainty in tax positions, as defined. ASC 740-10-25 seeks to reduce the diversity in practice associated with certain aspects of the recognition and measurement related to accounting for income taxes. Under ASC 740-10-25, an organization must recognize the tax benefit associated with tax positions taken for tax return purposes when it is more-likely-than-not that the position will be sustained. The Association does not believe that there are any uncertain tax positions that should be recorded. No interest or penalties were recorded or included in the consolidated statement of activities for the years ended December 31, 2013 and 2012. The Association is open to examination by taxing authorities from fiscal year 2010 forward. X 1 1 X X X X X X 0 1 0 0 0 0 0 1 0 Scott P Serota President & CEO 958621 0 2084292 0 1167361 0 1419395 0 48580 0 5678249 0 1031720 0 William A Breskin VP, Government Programs 271186 0 85000 0 64194 0 80176 0 31318 0 531874 0 0 0 Paul F Brown VP, Venturing 10930 0 23000 0 291844 0 2066 0 712 0 328552 0 270356 0 William J Colbourne SR VP, HR and Administration 323642 0 158000 0 147820 0 87813 0 25967 0 743242 0 0 0 Frank E Coyne VP, Operations & Ntl Programs 305443 0 123100 0 145432 0 127284 0 31180 0 732439 0 0 0 Kathy R Didawick VP, Congressional Comm 231220 0 75000 0 35087 0 48145 0 25517 0 414969 0 0 0 John T Ericksen VP, Federal Relations 268462 0 97000 0 98688 0 77584 0 22956 0 564690 0 0 0 Jena Estes VP, Government Programs 243097 0 67000 0 70886 0 55706 0 38012 0 474701 0 0 0 Alissa T Fox SR VP, Policy & Representation 392165 0 200000 0 266466 0 114698 0 40971 0 1014300 0 0 0 Paul Gerrard VP, Strategic Communications 236001 0 80800 0 6753 0 2838 0 27467 0 353859 0 0 0 Sudhama Gopalan VP, Strategy 217205 0 0 0 490 0 9649 0 1182 0 228526 0 0 0 Justine G Handelman VP, Legislative & Regulatory Policy 243672 0 100000 0 42703 0 52665 0 29292 0 468332 0 0 0 Trent T Haywood SR VP, Chief Medical Officer 355183 0 0 0 33888 0 9913 0 29007 0 427991 0 0 0 Kari J Hedges VP, National Programs 225629 0 88000 0 34622 0 6620 0 27313 0 382184 0 0 0 Mitchell J Helfand VP, Finance 214943 0 74000 0 24333 0 116190 0 31950 0 461416 0 0 0 Robert J Kolodgy SR VP, FSGP and CFO 423250 0 192000 0 24884 0 5019 0 34187 0 679340 0 0 0 Shirley S Lady VP, Transformation Services 237748 0 85000 0 44599 0 94604 0 16999 0 478950 0 0 0 William S Nehs VP, Dep Gen Counsel Asst Sec 257200 0 88200 0 2028 0 12750 0 22762 0 382940 0 0 0 William B OLoughlin VP, Operational Readiness 273387 0 118500 0 69763 0 64346 0 45832 0 571828 0 0 0 Doug Porter SR VP, Chief Information Officer 376910 0 185000 0 81074 0 51350 0 29471 0 723805 0 0 0 Cynthia P Rolfe VP, Consumer Brand Strategy 252048 0 95800 0 2096 0 10516 0 5764 0 366224 0 0 0 Maureen E Sullivan SR VP, Strategic Services and CSO 367646 0 175000 0 134178 0 65305 0 43672 0 785801 0 0 0 Cheryl L Thomas VP, Human Resources 226391 0 35000 0 5624 0 9228 0 27345 0 303588 0 0 0 Jennifer Vachon VP and Chief of Staff 238527 0 114000 0 48472 0 41792 0 36154 0 478945 0 0 0 Jody A Voss VP, Strategic Business Services 225806 0 82900 0 65797 0 43078 0 18246 0 435827 0 0 0 Roger G Wilson SR VP, Gen Counsel & Secretary 405531 0 179000 0 131686 0 105547 0 13160 0 834924 0 0 0 John Cerisano Exec Dir, Congress Relations 299770 0 62500 0 13439 0 76024 0 38707 0 490440 0 0 0 Carole R Flamm Exec Med Dir, Ctr for Clinic Value 259528 0 56700 0 17515 0 46924 0 25274 0 405941 0 0 0 Daniel A Engel Sr Assoc Gen Counsel 217436 0 49000 0 38829 0 87514 0 20631 0 413410 0 0 0 Nasir Khan Exec Dir, Enterprise Informatics 208773 0 64000 0 26728 0 60177 0 29294 0 388972 0 0 0 Steven D Putziger Exec Dir, Brand Protect & Finance 214649 0 60000 0 46270 0 29049 0 34467 0 384435 0 0 0 Allan M Korn Former Officer 12808 0 0 0 349863 0 1073 0 56 0 363800 0 73490 0 Schedule J, Part I, Line 1a As an organization serving a system of locally based independent Plans offering health insurance in all 50 States, DC and Puerto Rico, the Association's officers are expected to maintain an unusually demanding travel schedule. Accordingly, a committee of the Association's Board comprised of independent Plan executives has established CEO travel policies designed to assure the organization is able to meet his travel commitments, including travel to underserved regional destinations. These policies include the use of charter aircraft and first class travel on scheduled commercial flights under certain limited circumstances. Schedule J, Part I, Line 3 The compensation of the CEO and the continued retention of his services are approved each year by a committee of the Associations Board comprised of independent Plan executives. That committee acts after deliberations based upon advice from a qualified independent compensation consulting firm. The consultants advice and those deliberations include a review of the results of the independent consultants research regarding compensation paid by other organizations for officers serving in capacities comparable to that of the Associations CEO. Each year this committees decisions are reported to the full Board during a regularly scheduled meeting. The Board deliberates on both matters. Extension of the period of the CEOs service requires action by the full Board. The compensation determinations of the committee stand approved unless the Board exercises its inherent prerogative to modify the committees compensation decisions. The same committee of independent Plan executives annually receives the CEOs recommendations regarding the compensation to be paid to the officers. As with the CEOs compensation, the deliberations of this committee and its decisions to approve or modify the CEOs recommendation are based upon the results of an independent consultants market research regarding comparable officer pay and the independent consultants advice. Schedule J, Part I, Line 4 As required by the instructions to Form 990, Schedule J, Part II, a hypothetical SERP accrual was calculated for each reportable person who was eligible to participate in that program. The accrual amounts were determined using the Association's best estimate of the accrual using the methodology specified in the instructions to Schedule J. Because vested accruals under the SERP are currently taxed based on a different methodology and the instructions to Schedule J specify that amounts reported in columns B(i) through B(iii) should not be reported again in column C or D, the amount of imputed SERP income reported in column B(iii) was subtracted in each case and the balance of the hypothetical accrual was included in column C for the applicable reportable persons as follows: William A. Breskin - 23,972; William J Colbourne - 4,450; Frank E Coyne Jr- 42,602; Kathy Didawick - 2,644; John T Ericksen - 3,885; Alissa T Fox -39,400; Justine Handleman - 10,200; Mitchell Helfand - 41,189; Shirley Lady - 18,474; Doug Porter - 570; Maureen E Sullivan - 325; Jennifer Vachon - 2,847; Roger G Wilson - 17,320; John Cerisano - 33,167; Dan Engel - 14,567and Nasir Khan - 7,022. The combined total of imputed SERP included in column C = 262,634. Schedule J, Part I, Line 7 The Association maintains an Association wide annual performance bonus program that assures a portion of employees annual compensation is contingent upon the attainment of pre-approved organizational performance goals, as weighted by the performance measurement process that evaluates each individual employees efforts. Officers, like all employees, are eligible to participate in this program. The performance goals and the budget for this bonus program are approved each year by the Associations Board based upon recommendations from a Board committee consisting of independent Plan executives. Moreover, the performance assessment judgments and the approval of actual payouts require approval by that committee. The CEO also participates in a Long Term Incentive Bonus program. As with the regular performance bonus program, payouts under the Long Term Incentive Program reflect the extent to which preestablished performance goals are reached. However, unlike the annual performance bonus program, the Long Term Incentive program operates on a multi-year cycle to assure that the CEO has incentives that look beyond the immediate year. This program, the performance measurements and the assessment of the achievement of those goals and the resulting payout amounts are all approved by the same Board committee described above and reported to the full Board. The committees deliberations regarding the establishment of the program, the selection of the performance factors and assessment of performance all include consultation and recommendation from a qualified independent compensation consultant based upon a market study of comparable programs for comparable executives. F Ruiz Directors Family 89313 Employee Salary 0 N Parker Officers Family 71066 Employee Salary 0 Health Intelligence Co LLC Officer - Vendors Director 14416296 Receipts - Contract Fees 0 Health Intelligence Co LLC Officer - Customer Director 7361176 Payment for Services 0 Consortium Health Plans Inc Director-Vendors Director 3339186 Payment for Services 0 BCS Insurance Company Officer-Vendors Director 952525 Payment for Insurance 0 BCBS Venture Partners LP Officer-Customer Director 285296 Receipts for Services 0 BCBS Venture Partners II LP Officer-Customer Director 283221 Receipts for Services 0 Consortium Health Plans Inc Director-Customer Director 145300 Receipts - Contract Fees 0 BCS Life Insurance Co Director-Customer Director 117123 Receipts for Services 0 Form 990, Part VI, Section A, Line 2 Various BCBSA Board members (directors) also sit on the board of Blue Cross and Blue Shield Association affiliates. Form 990, Part VI, Section A, Line 6 Blue Cross and Blue Shield Association has thirty seven (37) independent member health care plan licensees operating in specified domestic service areas. Form 990, Part VI, Section A, Line 7a The governing body approves a nominating committee to oversee governing body elections. Form 990, Part VI, Section A, Line 7b Governing body decisions are approved according to the by-laws of the corporation. Form 990, Part VI, Section B, Line 11b In general, Form 990 content and sources of information are reviewed by subject matter experts including, but not limited to, internal and external tax and accounting professionals and internal legal personnel. Finalizing the return draft consists of discussions between Finance Officers and Finance Managers regarding the numeric results and written responses to select return questions. Upon internal agreement as to the form and content, an electronic draft 990 is sent to the Associations board one month prior to filing. Form 990, Part VI, Section B, Line 12c BCBSA maintains a comprehensive code of conduct and compliance program applicable to all employees and officers. In addition, all employees, officers, and board members are required to complete an annual conflict of interest form. The BCBSA Chief Auditor and Compliance Officer is charged with investigating any allegations of non compliance with the code of conduct, including any complaints reported through the anonymous hotline maintained through an independent organization. The results of the compliance programs effectiveness are reported to the audit committee of the Board of Directors on an annual basis. Failure to adhere to the code of conduct may result in disciplinary action, up to and including termination of employment Form 990, Part VI, Section B, Line 15 The compensation of the CEO and the continued retention of his services are approved each year by a committee of the Associations Board comprised of independent Plan executives. That committee acts after deliberations based upon advice from a qualified independent compensation consulting firm. The consultants advice and those deliberations include a review of the results of the independent consultant's research regarding compensation paid by other organizations for officers serving in capacities comparable to that of the Association's CEO. Each year this committee's decisions are reported to the full Board during a regularly scheduled meeting. The Board deliberates on both matters. Extension of the period of the CEO's service requires action by the full Board. The compensation determinations of the committee stand approved unless the Board exercises its inherent prerogative to modify the committees compensation decisions. The same committee of independent Plan executives annually receives the CEO's recommendations regarding the compensation to be paid to the officers. As with the CEO's compensation, the deliberations of this committee and its decisions to approve or modify the CEO's recommendation are based upon the results of an independent consultant's market research regarding comparable officer pay and the independent consultant's advice Form 990, Part VI, Section C, Line 19 The Association complies with all applicable public disclosure requirements. Thus, for example, members of the public may request an opportunity to review the Association's Form 990 for the past three years or to make a copy by sending a written req'uest or appearing in person at its principal office or any of its other locations. The Associations favorable determination letter regarding its tax exempt status and materials comprising its exemption application are also available in this manner. If the Association's governing documents (articles of incorporation and bylaws) and conflict of interest policy are subject to applicable federal or state public disclosure requirements, those documents will be made publicly available as applicable law may require. For example, Form 990 filings may include bylaw amendments and those amendments will be made available as noted above. Otherwise, the governing documents and conflict of interest policy will be provided to the public at the discretion of the Association's management. Form 990, Part IX, Line 11g Temporary Help - $35,436,234; Recruiting - $464,748; Printing and Graphics - $3,449,550; Various Consulting Fees including (but not limited to) actuaries, public relations, market research and business strategy, public policy and government relations, data analysis and infrastructure design - $89,145,238 Form 990, Part XI, Line 9 Form 990, Part XI, Line 9 - ASC 715, Other comprehensive income from pension plan obligations $42,758,559 Health Services Foundation 225 North Michigan Avenue Chicago IL 60601 237011867 Education,Research IL 501(c)(3) 9 N/A 0 BC and BS Foundation on Health Care 225 North Michigan Avenue Chicago IL 60601 237164980 Education,Research IL 501(c)(3) 9 N/A 0 BCBSA Services Inc 225 North Michigan Avenue Chicago IL 60601 364176277 Int'l Licensing IL N/A C 33519 43333 1 1 0 0 0 0 0 0 0 0 0 0 0 1 0 0 0 0 1 0 0 BCBSA Services Inc l 73974 Actual cost for plus markup for Direct Costs to BCBSA BCBSA Services Inc q 114208 Actual costs incurred by Reporting Entity