2023-11-14T18:49:29-06:00 2022-12-31 910189318 MOSS ADAMS LLP 805 SW BROADWAY 1200 PORTLAND OR 97205 990 2022-01-01 263538192 BENEFIS MEDICAL GROUP INC BENE 4064552563 1401 25TH STREET SOUTH GREAT FALLS MT 59405 GREGORY TIERNEY MD CHIEF MEDICAL OFFICER 4064552563 2023-11-10 1 GREGORY TIERNEY MD 999009999 0 WENDY CAMPOS P00448102 5032421447 2023-11-10 2 AAL1 IAL1 2022 2023-04-26 12:10:37Z GREGORY TIERNEY MD 1401 25TH STREET SOUTH GREAT FALLS MT 59405 93950964 0 X WWW.BENEFIS.ORG X 2009 MT MULTI-SPECIALTY PHYSICIAN GROUP. 18 1 333 1 0 0 0 0 85663728 93950964 0 0 0 0 85663728 93950964 0 0 0 0 83750358 91647907 0 0 0 1913367 2303060 85663725 93950967 3 -3 555597152 648737803 555821934 648962588 -224782 -224785 X WE PROVIDE EXCELLENT CARE FOR ALL, HEALING BODY, MIND AND SPIRIT. WE OPERATE PROFESSIONAL MEDICAL SERVICES IN COLLABORATION WITH BENEFIS HEALTH SYSTEM, INC. AND BENEFIS HOSPITALS, INC. AS PART OF A COLLECTIVE EFFORT TO MEET THE HEALTHCARE (CONTINUED ON SCHEDULE O) NEEDS OF RESIDENTS OF NORTH CENTRAL MONTANA. 0 0 93950967 93950964 THROUGH BENEFIS HOSPITALS, INC., BENEFIS COMMUNITY HOSPITALS, INC., AND BENEFIS COMMUNITY CARE, INC., BENEFIS MEDICAL GROUP, INC. PROVIDERS SERVE THE PRIMARY AND SPECIALTY CARE NEEDS OF GREAT FALLS, HELENA AND THE SURROUNDING REGION. FAMILY MEDICINE, INTERNAL MEDICINE AND PEDIATRIC PRACTITIONERS PROVIDE PRIMARY CARE TO PATIENTS OF ALL AGES, FROM NEWBORN TO THE ELDERLY. SPECIALTY CARE INCLUDES ANESTHESIOLOGY; CARDIOLOGY AND CARDIOVASCULAR SURGERY; DERMATOLOGY; EMERGENCY MEDICINE; ENDOCRINOLOGY; GASTROENTEROLOGY; GERIATRICS; MEDICAL, RADIATION AND GYNECOLOGIC ONCOLOGY; NEONATOLOGY; NEUROSURGERY; OBSTETRICS; GYNECOLOGY AND INFERTILITY; PAIN MANAGEMENT; PATHOLOGY; PHYSICAL MEDICINE AND REHABILITATION; PLASTICS AND RECONSTRUCTIVE SURGERY; PSYCHIATRY AND PSYCHOLOGY; (CONTINUED ON SCHEDULE O) PULMONARY AND CRITICAL CARE MEDICINE; RHEUMATOLOGY; SPORTS MEDICINE; UROLOGY; ORTHOPEDICS; NEPHROLOGY; PALLIATIVE CARE; INFECTIOUS DISEASE & EAR, NOSE AND THROAT; PODIATRY, SLEEP STUDIES AND RADIOLOGY. 93950967 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 0 1 0 0 0 0 0 0 0 0 0 0 0 1 0 0 0 0 0 0 1 0 0 0 0 0 0 1 0 0 0 1 1 0 1 333 1 0 0 0 0 0 0 0 0 0 0 0 0 X 18 1 1 1 0 0 1 1 1 1 1 0 0 1 1 1 1 1 1 1 1 0 X FORREST EHLINGER 4064555479 1101 26TH STREET SOUTH GREAT FALLS MT 59405 BRICE ADDISON MD CHAIR 50.00 X X 600411 0 33148 MARK VANTIGHEM MD VICE CHAIR 50.00 X X 345827 0 52741 PATRICK TANG MD DIRECTOR 50.00 X 821644 0 47143 GREGORY TIERNEY MD DIRECTOR/SYSTEM CMO 20.00 40.00 X X 0 654721 197703 STEVEN BAILEY MD DIRECTOR 50.00 X 907569 0 46998 FORREST EHLINGER DIRECTOR 2.00 58.00 X 0 648517 169523 JEFFREY BAKER MD DIRECTOR 48.00 2.00 X 570738 0 35297 TRACY LORDS DO DIRECTOR 50.00 X 561880 0 40685 JEFFREY PALEN DO DIRECTOR 50.00 X 494170 0 49875 BRIDGET BRENNAN MD DIRECTOR/CMO 30.00 30.00 X X 0 379610 49728 KEITH BORTNEM DO DIRECTOR 50.00 X 360540 0 48683 MICHAEL SHEFFIELD MD DIRECTOR (FROM 3/22) 50.00 X 345390 0 12930 MATTHEW WETZEL MD DIRECTOR (FROM 3/22) 50.00 X 723540 0 49007 BRAD NIESET MD DIRECTOR 48.00 2.00 X 427932 0 17480 KELLY TIMMER DIRECTOR 50.00 X 170363 0 31437 RAYN GINNATY DIRECTOR (FROM 1/22) 2.00 48.00 X 0 374744 60835 KATHY HILL DIRECTOR/COO (FROM 1/22) 25.00 25.00 X 0 262843 43363 MIKE MILBURN DIRECTOR 2.00 4.00 X 0 0 0 STEVEN AYRES MD PHYSICIAN 50.00 X 820575 0 20933 MATTHEW KUNKEL MD PHYSICIAN 50.00 X 757771 0 49026 MARK VAN TASSELL MD PHYSICIAN 50.00 X 730671 0 53191 JAMES DANIEL MD PHYSICIAN 50.00 X 725585 0 47088 JEFFREY KESSLER DO PHYSICIAN 50.00 X 724437 0 57250 10089043 2320435 1214064 316 0 1 0 0 PHYSICIAN LEASING SERV 561300 93950964 93950964 93950964 93950964 93950964 0 0 6795425 6795425 230166 230166 76112621 76112621 2131023 2131023 2827449 2827449 3551223 3551223 1213093 1213093 EDUCATION 838689 838689 LICENSES 251278 251278 93950967 93950967 0 0 -244367 -222530 555841519 648960333 555597152 648737803 555821934 648962588 555821934 648962588 X -224782 -224785 -224782 -224785 555597152 648737803 -3 0 X 0 1 X 1 0 X 0 X PART X, LINE 2: THE ORGANIZATION COMPRISES SEVERAL CORPORATIONS THAT ARE EXEMPT FROM FEDERAL INCOME TAX UNDER SECTION 501(C)(3) OF THE IRC, EXCEPT TO THE EXTENT OF UNRELATED BUSINESS TAXABLE INCOME AS DEFINED UNDER IRC SECTIONS 511 THROUGH 515, AND SEVERAL LIMITED LIABILITY COMPANIES. THE ORGANIZATION HAS ADOPTED ACCOUNTING FOR UNCERTAIN TAX POSITIONS, THE ACCOUNTING STANDARD THAT PRESCRIBES A RECOGNITION THRESHOLD AND MEASUREMENT PROCESS FOR UNCERTAIN TAX POSITIONS. THE ORGANIZATION HAD NO UNCERTAIN TAX POSITIONS AS OF DECEMBER 31, 2022 OR 2021. 0 1 0 0 0 0 0 1 0 STEVEN BAILEY MD DIRECTOR 866953 0 22000 0 18616 0 15250 0 31748 0 954567 0 0 0 PATRICK TANG MD DIRECTOR 577168 0 223731 0 20745 0 15250 0 31893 0 868787 0 0 0 GREGORY TIERNEY MD DIRECTOR/SYSTEM CMO 0 591642 0 17100 0 45979 0 177574 0 20129 0 852424 0 23979 STEVEN AYRES MD PHYSICIAN 630816 0 169264 0 20495 0 18300 0 2633 0 841508 0 0 0 FORREST EHLINGER DIRECTOR 0 513850 0 16167 0 118500 0 148018 0 21505 0 818040 0 92000 MATTHEW KUNKEL MD PHYSICIAN 470992 0 286779 0 0 0 15250 0 33776 0 806797 0 0 0 MARK VAN TASSELL MD PHYSICIAN 571804 0 158867 0 0 0 21350 0 31841 0 783862 0 0 0 JEFFREY KESSLER DO PHYSICIAN 565570 0 158867 0 0 0 21350 0 35900 0 781687 0 0 0 JAMES DANIEL MD PHYSICIAN 565918 0 158867 0 800 0 15250 0 31838 0 772673 0 0 0 MATTHEW WETZEL MD DIRECTOR (FROM 3/22) 564673 0 158867 0 0 0 15250 0 33757 0 772547 0 0 0 BRICE ADDISON MD CHAIR 380131 0 193787 0 26493 0 18300 0 14848 0 633559 0 0 0 JEFFREY BAKER MD DIRECTOR 420993 0 149745 0 0 0 18300 0 16997 0 606035 0 0 0 TRACY LORDS DO DIRECTOR 431673 0 106707 0 23500 0 15250 0 25435 0 602565 0 0 0 JEFFREY PALEN DO DIRECTOR 453067 0 11903 0 29200 0 15250 0 34625 0 544045 0 0 0 BRAD NIESET MD DIRECTOR 399120 0 28812 0 0 0 15250 0 2230 0 445412 0 0 0 RAYN GINNATY DIRECTOR (FROM 1/22) 0 338130 0 13698 0 22916 0 50871 0 9964 0 435579 0 21906 BRIDGET BRENNAN MD DIRECTOR/CMO 0 343073 0 23237 0 13300 0 15250 0 34478 0 429338 0 0 KEITH BORTNEM DO DIRECTOR 303713 0 36327 0 20500 0 21350 0 27333 0 409223 0 0 0 MARK VANTIGHEM MD VICE CHAIR 318787 0 27000 0 40 0 18207 0 34534 0 398568 0 0 0 MICHAEL SHEFFIELD MD DIRECTOR (FROM 3/22) 304130 0 0 0 41260 0 0 0 12930 0 358320 0 0 0 KATHY HILL DIRECTOR/COO (FROM 1/22) 0 170827 0 6302 0 85714 0 16382 0 26981 0 306206 0 44714 KELLY TIMMER DIRECTOR 135937 0 34426 0 0 0 8593 0 22844 0 201800 0 0 0 PART I, LINE 3 THE COMPENSATION OF THE SENIOR EXECUTIVE TEAM OF BENEFIS MEDICAL GROUP, INC. WAS SET BY THE INDEPENDENT COMPENSATION COMMITTEE OF BENEFIS HEALTH SYSTEM, INC., WHICH IS CHARGED WITH ADMINISTERING THE SYSTEM'S EXECUTIVE COMPENSATION PHILOSOPHY, POLICIES AND PROGRAMS IN THE MANNER SET FORTH IN THE COMMITTEE'S WRITTEN CHARTER. THE COMMITTEE'S RESPONSIBILITIES INCLUDE (I) DETERMINING APPROPRIATE COMPENSATION FOR ALL EXECUTIVES, (II) EVALUATING AND ADOPTING EXECUTIVE COMPENSATION PLANS, POLICIES AND PROGRAMS, (III) REVIEWING AND APPROVING EXECUTIVE BENEFIT PLANS, AND (IV) VERIFYING THAT COMPENSATION IS APPROPRIATELY AND FULLY DISCLOSED AND REPORTED. THE COMMITTEE HAS ENGAGED AN INDEPENDENT COMPENSATION CONSULTING FIRM TO ASSIST IN ENSURING THAT AMOUNTS PAID TO THE SYSTEM'S EXECUTIVES ARE CONSISTENT WITH REASONABLE, FAIR MARKET LEVELS. THE PROCESS FOLLOWED BY THE COMMITTEE, INCLUDING THE DATA RELIED UPON AND THE COMMITTEE'S DECISIONS, WAS THOROUGHLY AND TIMELY DOCUMENTED. THIS PROCESS IS COMPLETED ON AN ANNUAL BASIS. PART I, LINE 4B PART I, LINE 4B: BENEFIS HEALTH SYSTEM, INC. PROVIDES A SECTION 457F NONQUALIFIED DEFERRED COMPENSATION PLAN FOR DR. TIERNEY, MR. EHLINGER, MS. GINNATY, AND MS. HILL WHO MEET THE REQUIREMENTS OF THE PLAN. DR. TIERNEY, MR. EHLINGER, MS. GINNATY, AND MS. HILL RECEIVED A PAYOUT FROM THE PLAN IN 2022. PART I, LINE 7 BENEFIS HEALTH SYSTEM, INC. AND ITS AFFILIATES (INCLUDING THE ORGANIZATION) MAINTAIN AN INCENTIVE COMPENSATION PLAN THAT INCORPORATES BOTH SHARED AND INDIVIDUAL GOALS FOR MEMBERS OF THE EXECUTIVE AND MANAGEMENT LEADERSHIP TEAMS. PAYMENTS PURSUANT TO THE INCENTIVE PLAN ARE SUBJECT TO A PRECONDITION THAT THE SYSTEM MUST ACHIEVE BUDGETED OPERATING PERFORMANCE. THE SYSTEM HAS ADOPTED SHARED PERFORMANCE OBJECTIVES INCLUDING SYSTEM GROWTH AS WELL AS MEASURES TIED TO WORKFORCE, PATIENT EXPERIENCE, PATIENT SAFETY, CLINICAL QUALITY, AND FINANCE/OPERATIONS. THE INDIVIDUAL PERFORMANCE OBJECTIVES ADOPTED ARE BASED ON AN ARRAY OF QUALITY, FINANCIAL, OPERATIONAL AND STRATEGIC INITIATIVES. INCENTIVE OPPORTUNITY LEVELS ARE CALCULATED BASED ON PREDETERMINED PERCENTAGES OF EACH EXECUTIVE'S AND MANAGER'S BASE SALARY, AND VARY BASED ON THE ACHIEVEMENT OF THRESHOLD, TARGET OR STRETCH LEVELS AS TO EACH PERFORMANCE OBJECTIVE. THE SYSTEM ALSO MAINTAINS A LONG-TERM INCENTIVE PLAN DIRECTED AT RECRUITING AND RETAINING EXECUTIVE LEADERSHIP. PAYMENTS UNDER THE LONG-TERM INCENTIVE PLAN ARE CONDITIONED ON AN EXECUTIVE REMAINING EMPLOYED BY THE SYSTEM AND MAINTAINING SATISFACTORY OVERALL PERFORMANCE. INCENTIVE OPPORTUNITIES UNDER THE LONG-TERM PLAN ARE APPROVED IN ADVANCE BY THE BENEFIS HEALTH SYSTEM, INC. COMPENSATION COMMITTEE, WITH LATER PAYOUTS APPROVED BY THE COMMITTEE BASED ON ACTUAL PERFORMANCE RESULTS. PHYSICIAN COMPENSATION WAS SET IN ACCORDANCE WITH THE BENEFIS HEALTH SYSTEM PHYSICIAN COMPENSATION POLICY. RESPONSIBILITY FOR THE ADMINISTRATION AND USE OF THE POLICY TO ATTRACT AN RETAINING HIGH CALIBER PHYSICIANS WHILE MEETING ALL REGULATORY REQUIREMENTS RESTS WITH A COMMITTEE WHICH IS COMPRISED OF BENEFIS HEALTH SYSTEM AND BENEFIS MEDICAL GROUP EXECUTIVES. THIS COMMITTEE USES PUBLISHED MARKET SURVEY DATA FROM MULTIPLE NATIONALLY RECOGNIZED ORGANIZATIONS TO ESTABLISH MARKET NORMS FOR COMPENSATION AND PRODUCTION. THE RESULT OF THIS WORK IS A PROGRAM OF PROVIDER COMPENSATION THAT IS CONSISTENT WITH REASONABLE MARKET PRACTICE, WITHIN FAIR MARKET VALUE NORMS, AND REWARDS PRODUCTIVITY, QUALITY, AND EFFICIENCY. JAIMEE GREGOIRE FAMILY MEMBER OF GREGORY TIERNEY, MD, OFFICER 104598 COMPENSATION 0 STACEY SHEFFIELD FAMILY MEMBER OF MICHAEL SHEFFIELD, MD, OFFICER 125568 COMPENSATION 0 PART VI, SECTION A, LINE 1B: THE ORGANIZATION IS AN AFFILIATE OF BENEFIS HEALTH SYSTEM, INC. (BHS), A TAX EXEMPT MONTANA NONPROFIT CORPORATION SERVING AS THE PARENT ENTITY OF AN INTEGRATED SYSTEM OF PROVIDER ORGANIZATIONS ADDRESSING THE HEALTH NEEDS OF PERSONS THROUGHOUT NORTH CENTRAL MONTANA. AS THE CORPORATE MEMBER OF THE ORGANIZATION, BHS HOLDS VARIOUS RESERVED POWERS IN RELATION TO THE ORGANIZATION, INCLUDING THE AUTHORITY TO APPROVE THE ELECTION OF INDIVIDUALS TO ITS BOARD OF DIRECTORS. THE BOARD OF DIRECTORS OF THE ORGANIZATION INCLUDES CERTAIN INDIVIDUALS WHO ARE EMPLOYED BY THE ORGANIZATION OR ITS AFFILIATES, AND WHO MAY NOT BE CONSIDERED "INDEPENDENT" FOR PURPOSES OF FORM 990. HOWEVER, AS ACKNOWLEDGED BY THE IRS IN ITS "CPE TEXT FOR FISCAL YEAR 1997", IN A MULTI-ENTITY HOSPITAL SYSTEM, THE BOARD OF A SUBSIDIARY NON-PROFIT HEALTH CARE ORGANIZATION IS CONSIDERED TO BE COMPRISED OF INDEPENDENT COMMUNITY MEMBERS IF IT IS CONTROLLED BY AN EXEMPT ORGANIZATION WHOSE OWN BOARD IS COMPRISED OF A MAJORITY OF VOTING MEMBERS WHO ARE INDEPENDENT COMMUNITY MEMBERS. THE ORGANIZATION MEETS THIS STANDARD BECAUSE IT IS A CONTROLLED SUBSIDIARY OF BHS, AND BHS'S OWN GOVERNING BOARD INCLUDES INDEPENDENT COMMUNITY MEMBERS AS A MAJORITY THEREOF. FORM 990, PART VI, SECTION A, LINE 2 CERTAIN OFFICERS AND DIRECTORS LISTED IN PART VII ALSO HOLD OFFICER AND/OR DIRECTOR POSITIONS IN RELATION TO THE ORGANIZATION'S AFFILIATES (AS IDENTIFIED IN SCHEDULE R) AND, IN THAT REGARD, MAY BE CONSIDERED TO HAVE BUSINESS RELATIONSHIPS WITH EACH OTHER. SUCH BUSINESS RELATIONSHIPS ARE UNDERTAKEN IN THE ORDINARY COURSE OF BUSINESS. FORM 990, PART VI, SECTION A, LINE 3 PURSUANT TO A CONTRACTUAL ARRANGEMENT, THE ORGANIZATION OBTAINS CERTAIN MANAGEMENT AND ADMINISTRATIVE SERVICES FROM ITS PARENT ENTITY, BENEFIS HEALTH SYSTEM, INC. (BHS). BHS, AS THE PARENT AND SYSTEM ENTITY, PROVIDES THE SERVICES TO ITS SUBSIDIARY TAX-EXEMPT NON-PROFIT CORPORATE ENTITIES ON A CENTRALIZED BASIS. THE SERVICES INCLUDE THE FOLLOWING: - MANAGEMENT OF HUMAN RESOURCES INCLUDING POLICIES AND PRACTICES AND BENEFITS - MANAGEMENT, PLANNING, BUDGETING AND REPORTING OF FINANCIAL OPERATIONS - MANAGEMENT OF BILLING AND COLLECTIONS POLICIES AND FUNCTIONS - MANAGEMENT OF INFORMATION TECHNOLOGY SERVICES - OVERSIGHT OF QUALITY STANDARDS, COMPLIANCE AND RISK MANAGEMENT - MANAGEMENT OF REGIONAL, COMMUNITY AND GOVERNMENT RELATIONS AND MARKETING - MANAGEMENT OF GRANTS DEVELOPMENT THE FOLLOWING PERSONS LISTED IN PART VII WERE COMPENSATED BY BHS: GREGORY TIERNEY - $852,425 (COMPENSATION FOR SERVICES AS A KEY EMPLOYEE OF BHS) FORREST EHLINGER - $818,040 (COMPENSATION FOR SERVICES AS A OFFICER OF BHS) BRIDGET BRENNAN - $429,337 (COMPENSATION FOR SERVICES AS A KEY EMPLOYEE OF BHS) FORM 990, PART VI, SECTION A, LINE 6 THE SOLE CORPORATE MEMBER OF THE ORGANIZATION IS BENEFIS HEALTH SYSTEM, INC., A MONTANA NOT-FOR-PROFIT PUBLIC BENEFIT CORPORATION THAT HAS BEEN RECOGNIZED BY THE IRS AS DESCRIBED IN IRC SECTION 501(C)(3). FORM 990, PART VI, SECTION A, LINE 7A AS THE SOLE CORPORATE MEMBER OF THE ORGANIZATION, BENEFIS HEALTH SYSTEM, INC. (ACTING THROUGH ITS OWN GOVERNING BODY) HAS THE AUTHORITY TO APPROVE INDIVIDUALS PROPOSED TO SERVE ON THE ORGANIZATION'S BOARD OF DIRECTORS. FORM 990, PART VI, SECTION A, LINE 7B AS THE SOLE CORPORATE MEMBER OF THE ORGANIZATION, BENEFIS HEALTH SYSTEM, INC. RETAINS CERTAIN RESERVED POWERS WITH RESPECT TO THE ORGANIZATION, INCLUDING AUTHORITY OVER MATTERS SUCH AS (WITHOUT LIMITATION) THE ORGANIZATION'S MISSION AND VISION STATEMENTS, STRATEGIC AND LONG-TERM PLANS, ELECTION OF ITS DIRECTORS AND OFFICERS, ANNUAL CAPITAL AND OPERATING BUDGETS, CHARITY CARE AND COMMUNITY BENEFIT POLICIES, AND ANY AMENDMENTS TO ITS ARTICLES OF INCORPORATION AND BYLAWS. FORM 990, PART VI, SECTION B, LINE 11B THIS FORM 990 WAS PREPARED BY THE FINANCE DEPARTMENT PERSONNEL OF BENEFIS HEALTH SYSTEM, INC. IN COLLABORATION WITH ITS ACCOUNTING FIRM. PRIOR TO FILING, A COPY OF THIS FORM 990 WAS PRESENTED TO THE BENEFIS HEALTH SYSTEM, INC. BOARD BY THE ACCOUNTING FIRM. FORM 990, PART VI, SECTION B, LINE 12C BOARD MEMBERS ARE ASKED TO INDICATE WHETHER THEY HAVE A CONFLICT OF INTEREST WITH RESPECT TO ANY ACTION ITEM ON THE AGENDA FOR THE MEETING. CONSISTENT WITH THE ORGANIZATION'S CONFLICTS OF INTEREST POLICY, BOARD MEMBERS ARE PROHIBITED FROM PARTICIPATING IN DELIBERATIONS AND VOTING ON ANY MATTERS AS TO WHICH THEY HAVE A CONFLICT. FORM 990, PART VI, SECTION B, LINE 15 THE COMPENSATION OF THE SENIOR EXECUTIVE TEAM WAS SET BY THE INDEPENDENT COMPENSATION COMMITTEE OF BENEFIS HEALTH SYSTEM, INC., WHICH IS CHARGED WITH ADMINISTERING THE SYSTEM'S EXECUTIVE COMPENSATION PHILOSOPHY, POLICIES AND PROGRAMS IN THE MANNER SET FORTH IN THE COMMITTEE'S WRITTEN CHARTER. THE COMMITTEE'S RESPONSIBILITIES INCLUDE (I) DETERMINING APPROPRIATE COMPENSATION FOR ALL EXECUTIVES AND OTHER KEY EMPLOYEES, (II) EVALUATING AND ADOPTING EXECUTIVE COMPENSATION PLANS, POLICIES AND PROGRAMS, (III) REVIEWING AND APPROVING EXECUTIVE BENEFIT PLANS, AND (IV) VERIFYING THAT COMPENSATION IS APPROPRIATELY AND FULLY DISCLOSED AND REPORTED. THE COMMITTEE HAS ENGAGED AN INDEPENDENT COMPENSATION CONSULTING FIRM TO ASSIST IN ENSURING THAT AMOUNTS PAID TO THE SYSTEM'S EXECUTIVES ARE CONSISTENT WITH REASONABLE, FAIR MARKET LEVELS. THE PROCESS FOLLOWED BY THE COMMITTEE, INCLUDING THE DATA RELIED UPON AND THE COMMITTEE'S DECISIONS, WAS THOROUGHLY AND TIMELY DOCUMENTED. THIS PROCESS IS COMPLETED ON AN ANNUAL BASIS. THE COMPENSATION OF THE ORGANIZATION'S KEY EMPLOYEES AND MANAGERS WAS SET BY THEIR RESPECTIVE SUPERVISORY EXECUTIVES IN CONSULTATION WITH BENEFIS HEALTH SYSTEM INC.'S HUMAN RESOURCES DEPARTMENT AND EXECUTIVE LEADERSHIP, BASED ON A REVIEW OF INDEPENDENT DATA AS TO AMOUNTS PAID BY SIMILARLY SITUATED ORGANIZATIONS FOR PERSONS PERFORMING COMPARABLE SERVICES. FORM 990, PART VI, SECTION C, LINE 19 THE ORGANIZATION PROVIDES COPIES OF AUDITED FINANCIAL STATEMENTS AND THE FORM 990 TO THE PUBLIC UPON REQUEST DURING NORMAL BUSINESS HOURS. 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