2023-11-03T08:36:19-05:00 2022-12-31 PwC US Tax LLP 101 SEAPORT BLVD SUITE 500 BOSTON MA 02210 990 2022-01-01 455399218 ONECARE VERMONT ACCOUNTABLE CARE ORGANIZATION LLC % THOMAS BORYS ONEC 8028477220 356 MOUNTAIN VIEW DRIVE Suite 301 COLCHESTER VT 05446 THOMAS BORYS VP OF FINANCE-ACO 8028477220 2023-10-26 true THOMAS BORYS 999009999 PAUL J TANIS P01441612 6175305000 2 2022 2023-04-26 12:10:37Z THOMAS BORYS 356 MOUNTAIN VIEW DRIVE301 COLCHESTER VT 05446 24067959 false X WWW.ONECAREVT.ORG X LLC 2012 VT ONECARE PARTNERS WITH LOCAL HEALTH CARE PROVIDERS TO TRANSFORM VERMONT'S HEALTH CARE SYSTEM TO ONE THAT FOCUSES ON HEALTH GOALS. (SEE SCHEDULE O.) 18 18 0 21 0 0 58176 0 27293833 23795568 32786 272391 0 0 27384795 24067959 147061 94757 0 0 7836071 7612936 0 0 0 18108244 15459461 26091376 23167154 1293419 900805 43985225 57110714 37005377 49230061 6979848 7880653 X ONECARE PARTNERS WITH LOCAL HEALTH CARE PROVIDERS TO TRANSFORM VERMONT'S HEALTH CARE SYSTEM TO ONE THAT FOCUSES ON HEALTH GOALS BY PROVIDING ACTIONABLE DATA AND INNOVATIVE PAYMENTS THAT FOSTER BETTER OUTCOMES FOR ALL (SEE SCHEDULE O). false false 12250662 94757 20435129 DRIVE POPULATION HEALTH STRATEGY - NETWORK PERFORMANCE MANAGEMENT (SEE SCHEDULE O). 3739705 0 0 IMPLEMENTATION OF ACO FINANCIAL AND CLINICAL GOALS - DATA AND ANALYTICS (SEE SCHEDULE O). 2483903 0 3360439 IMPLEMENTATION OF ACO FINANCIAL AND CLINICAL GOALS - PAYMENT REFORM (SEE SCHEDULE O). 18474270 true false false true false false false false false true false false false false false true false false false false false false false false false false true false true false false false false false false false false false false false false false false false false false true 121 0 true 0 false false false false false false false false false false false false X 18 18 true false false false true true false true true false false true true true true true true false false false VT X X THOMAS BORYS 8028477220 356 MOUNTAIN VIEW DRIVESUITE 301 COLCHESTER VT 05446 VICTORIA LONER CHIEF EXECUTIVE OFFICER 50.0 0.0 X 484306 0 54100 SARA BARRY VP & CHIEF OPERATING OFFICER 50.0 0.0 X 358310 0 34941 THOMAS BORYS VP OF FINANCE, ACO 50.0 0.0 X 267445 0 39381 CARRIE WULFMAN MD CHIEF MEDICAL OFFICER 25.0 0.0 X 253249 0 32459 JOAN ZIPKO DIRECTOR ACO OPERATIONS 50.0 0.0 X 204190 0 45786 MARTITA GIARD DIRECTOR ACO STRATEGY&PLANNING 50.0 0.0 X 193971 0 43743 JOSIAH MUELLER DIRECTOR VALUE-BASED CARE 50.0 0.0 X 182504 0 41554 GREGORY DANIELS CHIEF COMPLIANCE OFFICER 50.0 0.0 X 181667 0 40669 AMY BODETTE DIRECTOR PUBLIC AFFAIRS 50.0 0.0 X 159751 0 43056 DEREK RAYNES DIRECTOR PAYMENT REFORM 50.0 0.0 X 180049 0 12420 KIMBERLEY DOUGLAS DIRECTOR ACO FINANCE & ACCNTG 50.0 0.0 X 145688 0 45237 BETSY DAVIS TRUSTEE 2.0 0.0 X 1650 0 0 SIERRA LOWELL TRUSTEE 2.0 0.0 X 1200 0 0 CYNTHIA TURNER TRUSTEE UNTIL 05/22 2.0 0.0 X 450 0 0 DANIEL BENNETT TRUSTEE, AUDIT COMMITTEE CHAIR 2.0 0.0 X 0 0 0 MICHAEL COSTA TRUSTEE 2.0 0.0 X 0 0 0 THOMAS DEE TRUSTEE 2.0 0.0 X 0 0 0 STEVEN GORDON TRUSTEE UNTIL 02/22 2.0 0.0 X 0 0 0 COLEEN CONDON TRUSTEE (formerly KOHAUT) 2.0 0.0 X 0 0 0 STEPHEN LEBLANC TRUSTEE 2.0 0.0 X 0 0 0 TOBY SADKIN MD TRUSTEE 2.0 0.0 X 0 0 0 JOHN SAYLES TRUSTEE 2.0 0.0 X 0 0 0 CLAUDIO FORT TRUSTEE UNTIL 12/22 2.0 0.0 X 0 0 0 JOHN BRUMSTED MD BOARD & EXEC CHAIRMAN TIL 4/22 2.0 0.0 X X 0 0 0 ROBERT BICK TRUSTEE 2.0 0.0 X 0 0 0 JEN GILWEE MD TRUSTEE 2.0 0.0 X 0 0 0 TOM HUEBNER BOARD VICE CHAIRMAN 2.0 0.0 X 0 0 0 STUART MAY TRUSTEE 2.0 0.0 X 0 0 0 ADRIANE TROUT MD TRUSTEE 2.0 0.0 X 0 0 0 RICK VINCENT TRUSTEE UNTIL 06/22 2.0 0.0 X 0 0 0 TERESA FAMA MD TRUSTEE AS OF 08/22 2.0 0.0 X 0 0 0 ANYA RADER WALLACK BOARD CHAIR AS OF 05/22 2.0 0.0 X X 0 0 0 SHAWN TESTER TRUSTEE AS OF 07/22 2.0 0.0 X 0 0 0 KRISTI CROSS TRUSTEE AS OF 02/22 2.0 0.0 X 0 0 0 2614430 0 433346 15 false true true HEALTH CATALYST INC DEPT CH 17917 PALATINE IL 60055 SOFTWARE MAINTENANCE 1192848 VERMONT INDEPENDENT TECHNOLOGY LEAD 1 MILL STREET SUITE 249 BURLINGTON VT 05401 SOFTWARE MAINTENANCE 430000 INTRAPRISE HEALTH 19 W COLLEGE AVENUE SUITE 500 YARDLEY PA 19067 SOFTWARE MAINTENANCE 408850 DINSE PC 209 BATTERY STREET BURLINGTON VT 05402 LEGAL 356743 MILLIMAN 463 7TH AVENUE 19TH FLOOR NEW YORK NY 10018 ACTUARIAL 272654 10 0 PROGRAM REVENUES 900099 3360439 3360439 PARTICIPATION FEES 900099 20435129 20435129 23795568 272391 0 0 272391 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 24067959 23795568 0 272391 94757 94757 0 0 0 0 0 0 1730781 855130 875651 0 0 0 0 0 4123952 3368564 755388 0 145656 85643 60013 0 1455795 903862 551933 0 156752 91741 65011 0 0 0 0 0 427460 235683 191777 0 1023679 0 1023679 0 53400 0 53400 0 0 0 0 0 0 0 1058749 925803 132946 0 29831 7057 22774 0 78131 45066 33065 0 2293489 2249067 44422 0 0 0 0 0 280108 101297 178811 0 9283 4705 4578 0 0 0 0 0 42863 27699 15164 0 0 0 0 0 0 0 0 0 8086 2924 5162 0 207711 16537 191174 0 POPUL. HEALTH PROVIDER PYMTS 9458735 9458735 GREEN MTN CARE BOARD ASSESSMNT 487936 487936 23167154 18474270 4692884 0 0 0 18483212 33497335 0 0 25111907 23182026 0 0 0 0 0 0 0 0 352405 406578 59502 34727 37701 24775 0 0 0 0 0 0 0 0 0 0 43985225 57110714 35090241 47129842 0 0 1915136 2100219 0 0 0 0 0 0 0 0 0 0 0 0 37005377 49230061 X 6979848 7880653 0 0 6979848 7880653 43985225 57110714 900805 X false true X true false X 0 0 22613 58176 0 80789 0 0 0 0 22613 58176 0 80789 0 80789 163676 32786 272391 468853 0 0 549642 55063764 X SCHEDULE A, PART II THE ORGANIZATION'S 2020 TAX YEAR REFLECTS OCTOBER 26, 2020 THROUGH DECEMBER 31, 2020 ACTIVITY (A SHORT PERIOD). THIS IS DUE TO 2020 BEING THE ORGANIZATION'S INITIAL 990 RETURN. 2021 IS THE FIRST REPORTED YEAR REFLECTING A FULL TWELVE MONTHS. 0 0 53400 0 53400 0 18397892 0 18451292 0 1000000 0 250000 0 0 0 false 359678 1000000 1000000 2359678 3539517 11000 52660 53400 117060 89920 250000 250000 589920 884880 0 0 0 0 SCHEDULE C, PART II-A, LINE 2 TAX YEAR 2020 WAS ONECARE'S INITIAL RETURN THEREFORE THERE IS NOT FIVE YEARS WORTH OF HISTORY TO FILL OUT ALL COLUMNS. THE ORGANIZATION FIRST MADE ITS 5768 ELECTION FOR TAX YEAR ENDING 12/31/2020 AND THE ELECTION HAS NOT BEEN REVOKED. 9953 9953 0 49549 24774 24775 24775 24067959 24067959 24067959 23167154 23167154 23167154 true UNIVERSITY OF VERMONT MEDICAL CENTER 111 COLCHESTER AVE BURLINGTON VT BURLINGTON VT 05401 030219309 501(c)(3) 54236 OCCULAR TELEHEALTH PROGRAM NORTHWESTERN MEDICAL CENTER 133 FAIRFIELD STREET ST ALBANS VT 05478 030266986 501(C)3 6000 CHRONIC PAIN LEARNING COLLABORATIVE 2 SCHEDULE I PART IV PROCEDURES FOR MONITORING GRANT FUNDS IN THE NORMAL COURSE OF BUSINESS, POOLS OF MONEY BECOME AVAILABLE TO FUND VARIOUS QUALITY INITIATIVE PROJECTS. SOME OF THESE FUNDS HAVE BEEN AWARDED IN THE FORM OF GRANTS BASED UPON IDENTIFIED NEEDS. ALL GRANT TYPES STEM FROM ACTIVITIES DEEMED TO FURTHER HEALTH CARE REFORM. PROVIDERS WERE CONTACTED AND ENCOURAGED TO SUBMIT APPLICATIONS. UPON REVIEW AND APPROVAL OF GRANT APPLICATIONS SUBMITTED TO ONECARE, AWARDS WERE MADE. SOME GRANTS WERE A ONE TIME PAYMENT TO RECIPIENT WHILE OTHERS WERE PAID IN INCREMENTS UPON SUBMISSION OF INVOICES AND APPROVAL OF CONTRACTUAL DELIVERABLES. ONECARE IS NO LONGER AWARDING GRANT PAYMENTS. X false false false false false false false false false true false VICTORIA LONER CHIEF EXECUTIVE OFFICER 378316 0 96094 0 9896 0 21350 0 32750 0 538406 0 0 0 THOMAS BORYS VP OF FINANCE, ACO 218732 0 44084 0 4629 0 15617 0 23764 0 306826 0 0 0 GREGORY DANIELS CHIEF COMPLIANCE OFFICER 155521 0 16189 0 9957 0 11515 0 29154 0 222336 0 0 0 SARA BARRY VP & CHIEF OPERATING OFFICER 294297 0 58834 0 5179 0 20758 0 14183 0 393251 0 0 0 JOAN ZIPKO DIRECTOR ACO OPERATIONS 171061 0 17715 0 15414 0 16127 0 29659 0 249976 0 0 0 MARTITA GIARD DIRECTOR ACO STRATEGY&PLANNING 169736 0 17380 0 6855 0 20980 0 22763 0 237714 0 0 0 AMY BODETTE DIRECTOR PUBLIC AFFAIRS 144408 0 15034 0 309 0 10682 0 32374 0 202807 0 0 0 DEREK RAYNES DIRECTOR PAYMENT REFORM 163334 0 16214 0 501 0 11390 0 1030 0 192469 0 0 0 CARRIE WULFMAN MD CHIEF MEDICAL OFFICER 192161 0 58275 0 2813 0 18493 0 13966 0 285708 0 0 0 JOSIAH MUELLER DIRECTOR VALUE-BASED CARE 165153 0 17000 0 351 0 11934 0 29620 0 224058 0 0 0 KIMBERLEY DOUGLAS DIRECTOR ACO FINANCE & ACCNTG 133470 0 0 0 12218 0 12939 0 32298 0 190925 0 0 0 SCHEDULE J PART I, LINE 1A PERSONAL SERVICE COMPENSATION CERTAIN ONECARE OFFICERS AND KEY EMPLOYEES RECEIVED COMPENSATION OF $1,400 TO COVER PREPARATION AND FINANCIAL ADVISORY SERVICES. WHILE THERE IS NO ORGANIZATION-WIDE WRITTEN POLICY REGARDING PAYMENT, THE AMOUNT IS INCLUDED IN THE RESPECTIVE INDIVIDUAL'S EMPLOYMENT CONTRACT WHICH IS DETERMINED THROUGH ANNUAL REVIEW (AS DISCUSSED IN SCHEDULE O). PERSONAL SERVICE COMPENSATION IS A FLAT AMOUNT INCLUDED IN THE INDIVIDUAL'S RESPECTIVE FORM W-2 AS TAXABLE INCOME. NO REIMBURSEMENT IS MADE UNDER AN ACCOUNTABLE PLAN, THEREFORE SUBSTANTIATION OF EXPENSE IS UNNECESSARY. SCHEDULE J PART I, LINE 3 CEO COMPENSATION METHOD ONECARE VERMONT RELIES ON UNIVERSITY OF VERMONT HEALTH NETWORK TO ESTABLISH CEO COMPENSATION VIA PERIODIC MARKET ANALYSIS AND COMPENSATION COMMITTEE REVIEW. SCHEDULE J, PART I, LINE 7 NONFIXED PAYMENTS ONECARE VERMONT LEVERAGES THE UVM MEDICAL CENTER'S COMPENSATION PROCESS WHICH RESULTS IN PAID AWARDS TO CERTAIN MEMBERS OF UPPER MANAGEMENT (DIRECTORS, VICE PRESIDENTS AND SENIOR EXECUTIVES) THROUGH ITS ANNUAL VARIABLE PAY PLAN, AS THE PLAN'S PERFORMANCE MEASURES ARE MET. MEASURES, WHICH INCLUDE FINANCIAL, POPULATION HEALTH & QUALITY, AND OPERATIONAL ELEMENTS, ARE REVIEWED AND APPROVED BY ONECARE'S BOARD OF MANAGERS. FORM 990, PART III, LINE 1 INNOVATIVE PAYMENTS MADE (MISSION CON'T) DURING THIS TAX PERIOD, PAYMENTS MADE TO PROVIDERS FOSTERING INNOVATION AND BETTER OUTCOMES INCLUDE FIXED PROSPECTIVE PAYMENTS TO HOSPITALS AND CERTAIN PRIMARY CARE PROVIDERS OF $445M; POPULATION HEALTH MGMT PAYMENTS OF $7.3M; AND MEDICARE BLUEPRINT FUNDING OF $9.1M. ALL OF THESE PAYMENTS ARE NETTED OUT ENTIRELY ON THIS RETURN FOR PURPOSES OF FOLLOWING US GAAP. INNOVATIVE PAYMENTS TO THE NETWORK REPORTED ON THIS RETURN INCLUDE COMPLEX CARE COORDINATION PROGRAM PAYMENTS OF $3.9M; VARIOUS NETWORK REFORM PROJECT PAYMENTS TOTALING $702K; VALUE BASED INCENTIVE FUND PAYMENTS OF $1.5M; RISK SETTLEMENT PAYMENTS OF $328K; AND PRIMARY PREVENTION PROGRAMS AND GRANTS OF $95K (SEE SCHEDULE I FOR DETAILS). FORM 990, PART III, LINE 4A NETWORK PERFORMANCE MANAGEMENT EFFORTS TAKEN TO FURTHER THE DEVELOPMENT OF FRAMEWORK FOR SUCCESSFUL CLINICAL PROGRAMS INCLUDE THE FOLLOWING: POPULATION HEALTH COMMITTEES WERE RESTRUCTURED AND REVITALIZED TO PROVIDE STATEWIDE INPUT; PREVENTION EFFORTS WERE REFOCUSED TO SUPPORT HEALTH EQUITY AND FOOD INSECURITY; AND POPULATION HEALTH PAYMENTS WERE SIMPLIFIED AND MADE TO ALIGN WITH INDIVIDUAL AND ACO ACCOUNTABILITIES. ONECARE SAW 100% RETENTION IN NETWORK PARTICIPANTS, WHICH REPRESENT 14 HOSPITALS, NINE FEDERALLY QUALIFIED HEALTH CENTERS, AND 27 INDEPENDENT PRIMARY CARE PRACTICES. ONECARE EXPERIENCED GROWTH IN BOTH COMMERCIAL AND COMPREHENSIVE PAYMENT REFORM ("CPR") PROGRAM PARTICIPATION. IN 2022, THE ONECARE NETWORK DEMONSTRATED IMPROVEMENT IN 75% OF FOCUSED QUALITY IMPROVEMENT AREAS. 2022 IS PROJECTED TO HAVE $6.4M IN NETWORK-WIDE SHARED SAVINGS, OF WHICH $1.3M IS TO BE DISTRIBUTED TO PRIMARY CARE PROVIDERS THROUGH THE ACCOUNTABILITY POOL. FORM 990, PART III, LINE 4B DATA AND ANALYTICS FURTHERED USAGE OF CROSS PAYER/PROVIDER DATA SETS UNIQUE TO ACO TO CONSIDER NEEDS OF NETWORK STRIVING TO SHIFT TO A POPULATION HEALTH MODEL. ONECARE CREATED A NEW MEDICARE BENCHMARKING TOOL TO IDENTIFY STRENGTHS AND OPPORTUNITIES FOR THE ORGANIZATION. ONECARE PROCURED A NEW MEANS FOR DATA ANALYTICS SUPPORT, ANCHORED BY A NEW POPULATION HEALTH ANALYTICS PLATFORM, SCHEDULED TO GO LIVE IN LATE 2023. THROUGHOUT 2022, ONECARE CONTINUED ITS ANALYTICS SUPPORT FOR THE ACO, WHICH INCLUDES SELF-SERVICE TOOLS, AD HOC DATA SUPPORT, RECURRING STANDARDIZED REPORTING, AND COMMUNITY/HSA-LEVEL SHARING OF RESULTS. ONECARE SUCCESSFULLY HOSTED COMMUNITY/HSA-LEVEL FORUMS TO ENGAGE HEALTHCARE PROVIDERS ACROSS THE STATE. FORM 990, PART III, LINE 4C PAYMENT REFORM ONECARE CONTINUES TO OFFER AN UNRECONCILED FIXED PAYMENT FOR HOSPITALS IN THE MEDICAID PROGRAM. THE COMPREHENSIVE PRIMARY CARE (CPR) PROGRAM EXPERIENCED CONTINUOUS YEAR OVER YEAR GROWTH IN PROGRAM PARTICIPATION. THE PROGRAM NOW INCLUDES FLAT, PREDICTABLE PER MEMBER PER MONTH (PMPM) PAYMENTS AND ABOVE MARKET PAYMENTS FOR SOME MENTAL HEALTH SERVICES. IN 2022, PRACTICES EARNED ON AVERAGE 26% MORE REIMBURSEMENT THAN FEE FOR SERVICE WOULD HAVE PROVIDED. MEDICARE FIXED PAYMENTS ARE EXPECTED TO CONTINUE TO RECONCILE TO FEE FOR SERVICE UNTIL 2025. FORM 990, PART VI, LINE 2 BUSINESS RELATIONSHIPS DR. JOHN BRUMSTED AND RICHARD VINCENT SERVED AS DIRECTORS AND OFFICERS AT THE UNIVERSITY OF VERMONT HEALTH NETWORK, AN UNRELATED ORGANIZATION. DR. JOHN BRUMSTED SERVED AS DIRECTOR AND OFFICER AT THE UNIVERSITY OF VERMONT MEDICAL CENTER (UVMC), AN UNRELATED ORGANIZATION, WHERE RICHARD VINCENT IS AN EMPLOYEE. ALL ONECARE STAFF ARE EMPLOYED BY UVMC, AN UNRELATED ORGANIZATION. ONECARE VERMONT REIMBURSES UVMC FOR THE FULL ECONOMIC COST OF THE EMPLOYEES' EFFORTS. AN EXCEPTION TO THIS IS UNIVERSITY OF VERMONT HEALTH NETWORK EMPLOYEES WHO WORK PART TIME FOR ONECARE VERMONT EFFORTS UNDER A MASTER SERVICE AGREEMENT BETWEEN THE COMPANIES. UNDER THAT AGREEMENT, ONECARE REIMBURSEES THE UNIVERSITY OF VERMONT HEALTH NETWORK FOR THE APPLICABLE PERCENTAGE OF THE SALARY AND BENEFITS COST INCURRED. FORM 990, PART VI, LINE 6 MEMBERS ONECARE VERMONT IS A LIMITED LIABILITY CORPORATION, FOUNDED IN 2012. ON SEPTEMBER 30, 2021, THE UNIVERSITY OF VERMONT MEDICAL CENTER ("UVMMC") TRANSFERRED ITS MEMBERSHIP STATUS TO ITS PARENT ORGANIZATION, UVM HEALTH NETWORK. AS OF OCTOBER 1, 2021, UVM HEALTH NETWORK BECAME THE SOLE CORPORATE MEMBER OF ONECARE. FORM 990, PART VI, LINES 7A MEMBER APPOINTMENTS TO GOVERNING BODY UVM HEALTH NETWORK, THE SOLE MEMBER OF ONECARE HAS THE RIGHT TO APPOINT THREE MEMBERS OF THE GOVERNING BODY. THE GOVERNING BODY IS COMPRISED OF UP TO TWENTY-ONE MEMBERS IN TOTAL. OTHER MEMBERS OF THE GOVERNING BODY REPRESENT SPECIFIC PROVIDER TYPES REPRESENTED IN ONECARE'S PROVIDER NETWORK, AS SET OUT IN THE ORGANIZATION'S OPERATING AGREEMENT. FORM 990, PART VI, LINE 11B RETURN PREPARATION ONECARE VERMONT'S FORM 990 IS PREPARED BY ONECARE STAFF AND REVIEWED BY PWC US Tax LLP (PWC). FOLLOWING PWC'S REVIEW, THE RETURN IS REVIEWED BY ONECARE'S SENIOR LEADERSHIP. FINALLY, ONECARE'S MANAGEMENT PRESENTS THE FORM 990 TO THE FINANCE COMMITTEE FOR REVIEW AND COMMENT. THE COMPLETED FORM 990 IS PROVIDED TO ALL MEMBERS OF THE ONECARE GOVERNING BOARD PRIOR TO BEING FILED WITH THE IRS. FORM 990, PART VI, LINE 12C MONITORING OF THE CONFLICT OF INTEREST POLICY THE ORGANIZATION REGULARLY MONITORS AND ENFORCES COMPLIANCE WITH ITS CONFLICT OF INTEREST POLICY. IN ACCORDANCE WITH THE POLICY, BOARD OF TRUSTEES, OFFICERS AND CERTAIN OTHER INDIVIDUALS ARE REQUIRED TO COMPLETE A CONFLICT OF INTEREST DISCLOSURE AND CERTIFICATION UPON HIRING, AT LEAST ANNUALLY, PRIOR TO PARTICIPATING IN ANY DECISION THAT MAY BE AFFECTED BY A PERSONAL INTEREST, AND WHENEVER A POTENTIALLY CONFLICTING INTEREST FIRST ARISES. THE CONFLICT OF INTEREST POLICY IS ENFORCED BY THE ONECARE COMPLIANCE TEAM, WHO REPORTS AT LEAST ANNUALLY ON CONFLICT OF INTEREST ISSUES TO THE AUDIT COMMITTEE OF THE BOARD OF MANAGERS. CONFLICTS OF INTEREST ARE MANAGED IN ACCORDANCE WITH THE POLICY, WHICH PROVIDES FOR A VARIETY OF REMEDIES TO ADDRESS CONFLICTS OF INTEREST. REMEDIES TO ADDRESS CONFLICTS OF INTEREST MAY INCLUDE THE FOLLOWING: RECUSAL FROM DECISION MAKING, DISCLOSURE TO APPROPRIATE PARTIES, COMMITTEE PARTICIPATION LIMITS AND REQUESTED DIVESTITURE. AN APPEALS PROCESS EXISTS SHOULD THE INDIVIDUAL REQUEST A SECONDARY REVIEW BE PERFORMED. FORM 990, PART VI, LINES 15A AND 15B COMPENSATION DETERMINATION POLICY ONECARE UTILIZES THE SERVICES OF THE UNIVERSITY OF VERMONT HEALTH NETWORK (THE 'HEALTH NETWORK') IN THE SETTING OF ALL COMPENSATION. COMPENSATION DETERMINATION IS SUBJECT TO THE HEALTH NETWORK'S COMPENSATION FRAMEWORK, WHICH INVOLVES UTILIZATION OF NATIONAL AND REGIONAL PEER GROUPS, TARGETING THE 50TH PERCENTILE, WITH PERFORMANCE BASED VARIABLE PAY OPPORTUNITIES. FORM 990, PART VI, LINE 19 DOCUMENT DISCLOSURE GOVERNANCE DOCUMENTS CONSIST OF THE ORGANIZATION'S ARTICLES OF INCORPORATION AND OPERATING AGREEMENT. THE ARTICLES OF INCORPORATION ARE FILED WITH THE VERMONT SECRETARY OF STATE AND ARE PUBLICLY AVAILABLE THROUGH THAT OFFICE. THE OPERATING AGREEMENT IS NOT PUBLICLY POSTED, BUT A COPY WOULD BE FURNISHED TO ANY MEMBER OF THE PUBLIC WHO REQUESTED ONE. THE CONFLICT OF INTEREST POLICY IS PROVIDED TO GREEN MOUNTAIN CARE BOARD (GMCB) AND DEPT OF VERMONT HEALTH ACCESS (DVHA), BOTH OF WHICH ARE SUBJECT TO PUBLIC RECORD REQUESTS. ONECARE'S ANNUAL AUDITED FINANCIAL STATEMENTS ARE POSTED TO ONECARE'S WEBISTE AS WELL AS PROVIDED TO GMCB AND DVHA.