2024-07-31T14:18:07-05:00 2023-09-30 381357951 PLANTE & MORAN PLLC 10 S RIVERSIDE PLAZA 9TH FLOOR CHICAGO IL 60606 990 2022-10-01 363385581 COVENANT LIVING AT WINDSOR PARK COVE 6306824377 124 WINDSOR PARK DRIVE CAROL STREAM IL 60188 JEAN E JUSTIE CFO 7738782294 2024-07-23 1 0 SAMANTHA L BECKER P01344887 3122071040 2024-07-23 2022 2024-08-08 14:25:15Z DAVID ERICKSON C/O CLCS - 5700 OLD ORCHARD RD SKOKIE IL 60077 38254263 0 X WWW.COVLIVING.ORG X 1985 IL CARE FOR SENIOR ADULTS. 19 16 387 16 0 0 1345482 1110467 29495678 35020305 1215400 1917702 289366 194416 32345926 38242890 0 0 0 0 13079728 13633442 0 0 30036 18447614 22004401 31527342 35637843 818584 2605047 83569105 85913841 113711821 112663163 -30142716 -26749322 X AS A MINISTRY OF THE EVANGELICAL COVENANT CHURCH, COVENANT LIVING COMMUNITIES AND SERVICES CELEBRATES GOD'S GIFT OF LIFE IN CHRISTIAN COMMUNITY. WE FOLLOW THE GREAT COMMANDMENT TO LOVE AND SERVE GOD AND ONE ANOTHER AS TAUGHT BY JESUS CHRIST. (SEE SCHEDULE O) 0 0 12286290 18608918 RESIDENTIAL LIVING:THE NUMBER OF PERSONS WHO BENEFITED FROM THE SERVICES WE PROVIDED FOR THE YEAR ENDED SEPTEMBER 30, 2023 WERE AS FOLLOWS:THERE WERE A TOTAL OF 491 RESIDENTS, OCCUPYING 375 APARTMENTS AT 09/30/2023. RESIDENCY FOR THE FISCAL YEAR TOTALED 140,284 RESIDENT DAYS. 5251084 5732123 ASSISTED LIVING: THE NUMBER OF PERSONS WHO BENEFITED FROM THE SERVICES WE PROVIDED FOR THE YEAR ENDED SEPTEMBER 30, 2023 WERE AS FOLLOWS:THERE WERE A TOTAL OF 53 ASSISTED LIVING RESIDENTS AT 09/30/2023. ASSISTED LIVING RESIDENCY FOR THE FISCAL YEAR TOTALED 18,229 RESIDENT DAYS.ASSISTED LIVING MEMORY SUPPORT: THE NUMBER OF PERSONS WHO BENEFITED FROM THE SERVICES WE PROVIDED FOR THE YEAR ENDED SEPTEMBER 30, 2023 WERE AS FOLLOWS: THERE WERE A TOTAL OF 17 ASSISTED LIVING MEMORY SUPPORT RESIDENTS AT 09/30/2023. ASSISTED LIVING MEMORY SUPPORT RESIDENCY FOR THE FISCAL YEAR TOTALED 6,447 RESIDENT DAYS. 9793566 10873680 SKILLED NURSING:THE NUMBER OF PERSONS WHO BENEFITED FROM THE SERVICES WE PROVIDED FOR THE YEAR ENDED SEPTEMBER 30, 2023 WERE AS FOLLOWS:THERE WERE A TOTAL OF 59 SKILLED CARE RESIDENTS AT 09/30/2023. SKILLED CARE RESIDENCY FOR THE FISCAL YEAR TOTALED 21,442 RESIDENT DAYS. 27330940 1 1 0 1 0 0 0 0 1 1 1 1 0 0 1 0 0 1 0 0 0 0 0 0 0 0 0 0 0 1 0 0 0 0 0 0 0 0 0 0 0 0 0 1 0 0 0 1 46 0 1 387 1 0 0 0 0 0 0 0 0 0 0 0 0 X 19 16 0 1 0 0 1 0 1 1 1 1 0 1 1 1 1 1 1 0 1 0 IL X JEAN E JUSTIE 7738782294 C/O CLCS 5700 OLD ORCHARD RD SKOKIE IL 60077 TERRI S CUNLIFFE DIRECTOR/CLCS PRESIDENT/CEO 1.00 59.00 X X 0 934218 35015 TODD SLECHTA DIRECTOR/EX-OFFICIO 0.10 42.00 X 0 288273 47925 TAMMY SWANSON-DRAHEIM DIRECTOR/EX-OFFICIO 0.10 42.00 X 0 62214 45946 JANET CREANEY DIRECTOR/CHAIR 0.10 2.00 X X 0 0 0 LORENE FLEWELLEN DIRECTOR/VICE CHAIR 0.10 2.00 X X 0 0 0 JANET GOELZ HOFFMAN DIRECTOR/SECRETARY 0.10 2.00 X X 0 0 0 SARAH BENTLEY DIRECTOR 0.10 2.00 X 0 0 0 KATHY BUETTNER DIRECTOR 0.10 2.00 X 0 0 0 PAMELA CHRISTENSEN DIRECTOR 0.10 2.00 X 0 0 0 ARTHUR DEROOY DIRECTOR/EX-OFFICIO 0.10 2.00 X 0 0 0 JOHN FREDRICKSON DIRECTOR 0.10 2.00 X 0 0 0 KURT KINCANON DIRECTOR 0.10 2.00 X 0 0 0 ROBERT MARTIN DIRECTOR 0.10 2.00 X 0 0 0 JENNIFER MEANS DIRECTOR 0.10 2.00 X 0 0 0 LOANN PETERSON DIRECTOR 0.10 2.00 X 0 0 0 SUSAN POSTON DIRECTOR/EX-OFFICIO 0.10 2.00 X 0 0 0 DIXIE REPPE DIRECTOR 0.10 2.00 X 0 0 0 ANDREW VANOVER DIRECTOR 0.10 2.00 X 0 0 0 MARY PALMER DIRECTOR 0.10 2.00 X 0 0 0 JEAN E JUSTIE CFO/TREASURER/ASST SECRETARY 1.00 59.00 X 0 410044 82847 DAVID G ERICKSON SR VP & GEN COUNSEL/ASST SECRETARY 1.00 59.00 X 0 388258 103279 WILLIAM RABE SR VP ENTERPRISE OPS/ASST SECRETARY 1.00 59.00 X 0 414211 57438 EMILY WARNYGORA ASSISTANT SECRETARY 1.00 59.00 X 0 92734 5579 JAY PRINCE SVP, COMMUNITY OPS/ASST SECRETARY 1.00 59.00 X 0 0 0 ANDREW REESE-CLAUSON ASSOCIATE VICE PRESIDENT, OPERATIONS 1.00 49.00 X 0 257250 30739 SHELLY SMITH EXECUTIVE DIRECTOR 40.00 0.00 X 219705 0 20996 HILDE SAGER ASSOCIATE VICE PRESIDENT, OPERATIONS 1.00 47.00 X 0 228615 45753 TANDERIA BROWN SVP OF HUMAN RESOURCES 40.00 20.00 X 0 224975 47440 JANET CANNON DIRECTOR OF SALES 40.00 0.00 X 146148 0 28226 BETTYANN CICHON NURSE, RN 40.00 0.00 X 147095 0 13809 CIARRA HARLEY HEALTHCARE ADMINSTRATOR 40.00 0.00 X 144963 0 9624 DANIELLE SISTO HEALTHCARE NAVIGATOR 40.00 0.00 X 146509 0 13602 ASHA STANI ASSISTANT DIRECTOR OF NURSING 40.00 0.00 X 163913 0 14058 AMY LACROIX FORMER SVP COMMUNITY OPS 0.00 0.00 X 0 348336 49634 CORY STERN FORMER INTERIM FINANCE LEAD/TREAS. 0.00 0.00 X 0 226287 31007 968333 3875415 682917 11 1 1 0 LEOPARDO COMPANIES INC 5200 PRAIRIE STONE PARKWAY HOFFMAN ESTATES IL 60192 CONSTRUCTION/RENOVATION 11259007 SNOWY NIGHT SIERRA OWENS 26WL52 GRAND AVE WHEATON IL 60187 CONSTRUCTION/RENOVATION 2209685 HEALTHPRO REHABILITATION PO BOX 69268 BALTIMORE MD 21264 THERAPY 1028825 CLIPBOARD HEALTH PO BOX 103125 PASADENA CA 91189 MEDICAL SERVICES/STAFFING 601733 SODEXO INC & AFFILIATES PO BOX 360170 PITTSBURGH PA 15251 DINING SERVICES 565592 19 245616 864851 1110467 ROUTINE SERVICES 623000 21478830 21478830 ENTRANCE FEE 623000 6300251 6300251 ANCILLARY SERVICES 623000 4048751 4048751 MEDICARE/MEDICAID 623000 2936821 2936821 MEALS 623000 255652 255652 35020305 1650692 1650692 278383 0 11373 278383 -11373 267010 267010 APARTMENT UPGRADES 623000 99653 99653 SUPPORT SERVICES 623000 51313 51313 SERVICES TO RESIDENTS 623000 34509 34509 8941 8941 194416 38242890 35214721 0 1917702 230947 230947 11767561 9844812 1920642 2107 226191 174618 48755 2818 600915 488526 117933 -5544 807828 701536 99708 6584 155416 155416 28964 28964 12188 12188 1673 1673 2905617 2859953 45664 182787 2822 178070 1895 1418578 1186483 232051 44 681898 403 681495 2073986 1480968 593018 6912 2581 4331 80411 4763 75648 3586798 2750743 833032 3023 5990297 4594006 1391243 5048 421408 421408 RELATED PARTY ACTIVITY 2336011 2336011 DINING SERVICES 1446289 1446289 MAINT. FOR RESIDENTS 978883 978883 BAD DEBT 101168 101168 -404883 236730 -655674 14061 35637843 27330940 8276867 30036 9380 7011 9268 4294 38822 177550 1309912 1262926 19242 9270 134361975 72174741 59308841 62187234 12107215 10849732 8990697 9651271 1775728 1764553 83569105 85913841 356401 358875 36320131 38994961 47147317 44428032 83347 233299 29804625 28647996 113711821 112663163 X -33085697 -30136226 2942981 3386904 -30142716 -26749322 83569105 85913841 X 2605047 800767 -12420 X 0 1 X 1 1 1 X 258018 1100105 2546628 1345482 1110467 6360700 18646666 28152734 27615765 29785044 35214721 139414930 18904684 29252839 30162393 31130526 36325188 145775630 0 0 0 145775630 685146 1212382 1055635 1280317 1650692 5884172 685146 1212382 1055635 1280317 1650692 5884172 11443 10361 19065 40869 19601273 30475582 31218028 32429908 37975880 151700671 0.96090 0.96380 0.03880 0.03590 X SCHEDULE A, PART III, LINE 12, EXPLANATION OF OTHER INCOME: FUNDRAISING INCOME PART III: BECAUSE OF THE SHORT YEAR-END FILING, THE COLUMNS IN SCHEDULE A PART III CORRESPOND TO THE FOLLOWING TAX YEARS: 2018 = SHORT YEAR-END 9/30/19 2019 = FYE 9/30/20 2020 = FYE 9/30/21 2021 = FYE 9/30/22 2022 = FYE 9/30/23 RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED 0 0 0 0 0 0 0 0 1 1673 1673 0 PART II-B, LINE 1: A PORTION OF MEMBERSHIP DUES PAID TO LEADING AGE ARE USED FOR LOBBYING PURPOSES 0 1 X 1775728 -11175 1764553 2118392 -342664 1775728 1869921 248471 2118392 1885360 -15439 1869921 1797063 88297 1885360 0.00000 1.00000 0.00000 0 1 1 1281659 1281659 98057529 56072018 41985511 27137832 14379827 12758005 7884955 1722896 6162059 62187234 MORTGAGES 115783 F DOMESTIC EQUITY 3913950 F INTERNATIONAL EQUITY 3103127 F HEDGE FUNDS & DERIVATIVES 2037870 F PRIVATE EQUITY 480541 F 9651271 REFUNDABLE CONTRACT LIABILITIES 15392584 ACCRUED PROPERTY TAXES 468028 INTER-COMPANY ADVANCE ACCOUNTS 10941490 OTHER LIABILITIES 1845894 28647996 PART IV, LINE 2B: RESIDENT ENTRANCE FEE ACCOUNT: PROSPECTIVE RESIDENTS PAY AN APPLICATION FEE DEPOSIT WHICH IS CARRIED IN AN ESCROW ACCOUNT. AT MOVE IN, THE DEPOSIT IS APPLIED AGAINST THE TOTAL ENTRANCE FEE AMOUNT AND THE REMAINDER OF THE MONEY IS COLLECTED AND PUT IN THIS ACCOUNT. AT THE END OF THE MONTH THE RESIDENT HAS MOVED IN, ALL MONEY IS TRANSFERRED OUT OF THE ESCROW ACCOUNT. 0 1 0 0 0 0 0 1 0 TERRI S CUNLIFFE DIRECTOR/CLCS PRESIDENT/CEO 0 572627 0 184727 0 176864 0 9150 0 25982 0 969350 0 20847 JEAN E JUSTIE CFO/TREASURER/ASST SECRETARY 0 289279 0 58752 0 62013 0 48359 0 42790 0 501193 0 0 DAVID G ERICKSON SR VP & GEN COUNSEL/ASST SECRETARY 0 329475 0 0 0 58783 0 69031 0 40985 0 498274 0 32820 WILLIAM RABE SR VP ENTERPRISE OPS/ASST SECRETARY 0 268100 0 62715 0 83396 0 44342 0 18757 0 477310 0 26335 AMY LACROIX FORMER SVP COMMUNITY OPS 0 229927 0 55080 0 63329 0 35170 0 20269 0 403775 0 0 TODD SLECHTA DIRECTOR/EX-OFFICIO 0 240108 0 17175 0 30990 0 24368 0 24636 0 337277 0 0 ANDREW REESE-CLAUSON ASSOCIATE VICE PRESIDENT, OPERATIONS 0 208889 0 10350 0 38011 0 30739 0 387 0 288376 0 0 HILDE SAGER ASSOCIATE VICE PRESIDENT, OPERATIONS 0 159220 0 31773 0 37622 0 22446 0 23639 0 274700 0 0 TANDERIA BROWN SVP OF HUMAN RESOURCES 0 194086 0 0 0 30889 0 29447 0 18019 0 272441 0 0 CORY STERN FORMER INTERIM FINANCE LEAD/TREAS. 0 150599 0 15548 0 60140 0 22098 0 9215 0 257600 0 14048 SHELLY SMITH EXECUTIVE DIRECTOR 161054 0 24938 0 33713 0 20996 0 317 0 241018 0 0 0 ASHA STANI ASSISTANT DIRECTOR OF NURSING 152054 0 3400 0 8459 0 5011 0 9210 0 178134 0 0 0 JANET CANNON DIRECTOR OF SALES 81936 0 51100 0 13112 0 4669 0 23697 0 174514 0 0 0 BETTYANN CICHON NURSE, RN 140434 0 2000 0 4661 0 4491 0 9451 0 161037 0 0 0 DANIELLE SISTO HEALTHCARE NAVIGATOR 59147 0 77650 0 9712 0 4556 0 9199 0 160264 0 0 0 CIARRA HARLEY HEALTHCARE ADMINSTRATOR 124758 0 2500 0 17705 0 9624 0 238 0 154825 0 0 0 PART I, LINE 3 SEE SCHEDULE O EXPLANATION FOR FORM 990 PART VI SECTION B LINE 15 FOR THE METHODS USED TO DETERMINE CEO COMPENSATION. THE REVIEW AND APPROVAL PROCESS IS DESIGNED TO SATISFY AND QUALIFY FOR THE REBUTTABLE PRESUMPTION OF REASONABLENESS UNDER THE INTERNAL REVENUE CODE SECTION 4958. PART I, LINE 4B EXECUTIVE BENEFIT PLAN COVENANT MINISTRIES OF BENEVOLENCE (CMB), A RELATED ORGANIZATION, PROVIDES CERTAIN SUPPLEMENTAL RETIREMENT BENEFITS TO ITS OFFICERS AND KEY EMPLOYEES. THESE BENEFITS ARE PROVIDED THROUGH A NONQUALIFIED DEFERRED COMPENSATION PLAN, UNDER WHICH A PORTION OF THE BENEFITS BEING EARNED ARE SUBJECT TO A "SUBSTANTIAL RISK OF FORFEITURE." THE SUPPLEMENTAL RETIREMENT BENEFITS ARE STRUCTURED TO PROVIDE A RETENTION INCENTIVE THAT HAS BEEN DETERMINED BY THE EXECUTIVE COMPENSATION COMMITTEE OF CMB'S BOARD ("COMMITTEE") TO BE OF SUBSTANTIAL VALUE TO THE ORGANIZATION. THE COMMITTEE APPROVES ALL RETIREMENT BENEFITS, TOGETHER WITH ALL OTHER FORMS OF COMPENSATION AND BENEFITS FOR THESE AND OTHER EXECUTIVES, IN A MANNER INTENDED TO QUALIFY FOR THE REBUTTABLE PRESUMPTION OF REASONABLENESS UNDER THE INTERMEDIATE SANCTION'S RULES OF FEDERAL INCOME TAX LAW. THE FOLLOWING ARE PARTICIPANTS IN THE PLAN: AMY LACROIX ANDREW REESE-CLAUSON CORY STERN DAVID ERICKSON HILDE SAGER JEAN JUSTIE TERRI CUNLIFFE TODD SLECHTA WILLIAM RABE CIARRA HARLEY SHELLY SMITH IN 2022, THESE INDIVIDUALS VESTED IN THE PLAN IN THE FOLLOWING AMOUNTS: TERRI CUNLIFFE - $112,308 DAVID ERICKSON - $32,820 WILLIAM RABE - $26,335 CORY STERN - $14,048 IN 2022, THESE INDIVIDUALS RECEIVED DISTRIBUTIONS FROM THE PLAN IN THE FOLLOWING AMOUNTS: DAVID ERICKSON - $12,779 PART I, LINE 7 THE FOLLOWING APPLIES TO CERTAIN INDIVIDUALS LISTED ON PART VII WHOSE COMPENSATION IS PAID FROM RELATED ORGANIZATIONS: THE EXECUTIVE COMPENSATION COMMITTEE (OF CMB'S BOARD) FOLLOWS A PRESCRIBED METHOD FOR CALCULATING INCENTIVE COMPENSATION AWARDS. THE CALCULATION IS BASED ON MEASURABLE TARGETS DETERMINED AT THE BEGINNING OF THE YEAR. THE COMMITTEE HAS THE ABILITY TO ADJUST THE DOLLAR VALUE OF THE CALCULATED AWARDS BY UP TO 10%. THE ADJUSTMENT CAN BE AN UPWARD OR DOWNWARD ADJUSTMENT BASED ON VARIOUS PERFORMANCE FACTORS OR ON FACTORS THAT WILL ASSURE THAT FINAL INCENTIVE COMPENSATION AWARDS ARE IN THE BEST INTEREST OF THE ORGANIZATION AND APPROPRIATELY REFLECT THE PERFORMANCE OF THE ORGANIZATION. REFER TO ADDITIONAL INFORMATION ON THE COMMITTEE INCLUDED IN SCHEDULE O. PART II, COLUMN B (II): BONUS AND INCENTIVE COMPENSATION - CERTAIN KEY PERSONS EMPLOYED BY COVENANT LIVING AND CMB ARE ELIGIBLE FOR INCENTIVE COMPENSATION AS DETERMINED BY THE EXECUTIVE COMPENSATION COMMITTEE OF EITHER THE COVENANT LIVING OR CMB'S BOARD BASED ON WHERE THESE INDIVIDUALS ARE EMPLOYED. INCENTIVES RELATED TO THE ACHIEVEMENT OF TARGETS FOR THE TWELVE MONTHS ENDED 9/30/21 WERE PAID OUT IN 2022 FOR CLCS AND RELATED ENTITIES. INCENTIVES RELATED TO CMB'S ACHIEVEMENT OF TARGETS FOR THE TWELVE-MONTHS ENDED 9/30/22 WERE PAID OUT IN 2022. PART II, COLUMN D: NONTAXABLE BENEFITS INCLUDE HEALTH INSURANCE PREMIUMS PAID BY THE EMPLOYER AND EMPLOYEE. FORM 990, PART III, LINE 1: AS A MINISTRY OF THE EVANGELICAL COVENANT CHURCH, COVENANT LIVING COMMUNITIES AND SERVICES CELEBRATES GOD'S GIFT OF LIFE IN CHRISTIAN COMMUNITY. WE FOLLOW THE GREAT COMMANDMENT TO LOVE AND SERVE GOD AND ONE ANOTHER AS TAUGHT BY JESUS CHRIST. THAT COMPELS US TO AFFIRM THE DIGNITY OF EACH PERSON AND TO PURSUE EXCELLENCE AND FINANCIAL INTEGRITY IN ALL THAT WE DO. AS WE PROVIDE A BROAD RANGE OF RESOURCES, SERVICES AND PROGRAMS TO ENHANCE INDIVIDUAL AND COMMUNITY WELLNESS, WE COLLABORATE WITH RESIDENTS AND FAMILIES TO ACHIEVE THE BEST POSSIBLE RESULTS. WHILE SEEKING TO FOSTER INDEPENDENCE, WE RESPOND TO EACH INDIVIDUAL'S EVOLVING NEEDS IN ORDER TO PROVIDE THE SECURITY THAT ASSURES PEACE OF MIND. IN LIVING OUT THE MISSION, THE COMMUNITY PROVIDES A COMPLETE CONTINUUM OF CARE FROM RESIDENTIAL LIVING THROUGH SKILLED NURSING. SUCH SERVICES ARE GUIDED BY A SERIES OF VALUES AND GOALS ADDRESSING RESIDENT NEEDS, PRIVACY, SAFETY AND DIGNITY, INCLUDING APPROPRIATE ACCESS TO SERVICES. IN CARRYING OUT THE MISSION STATEMENT OF COVENANT LIVING, WINDSOR PARK MANOR PROVIDED $224,125 FREE OR DISCOUNTED SERVICES TO THOSE RESIDENTS UNABLE TO PAY ALL OR A PORTION OF THEIR CHARGES, AND WHO MEET CERTAIN ELIGIBILITY REQUIREMENTS. COVENANT LIVING AT WINDSOR PARK ALSO PROVIDES SERVICES TO MEDICAID RECIPIENTS AT A COST GREATER THAN THE REIMBURSEMENT PROVIDED. IN THE YEAR ENDED SEPTEMBER 30, 2023, THE AMOUNT OF COST IN EXCESS OF MEDICAID REIMBURSEMENT WAS $685,018. ADDITIONALLY, COVENANT LIVING AT WINDSOR PARK PROVIDES OTHER BENEFITS TO THE COMMUNITY, INCLUDING HOSTING MEETINGS FOR LOCAL ORGANIZATIONS FOR FREE. RESIDENTS OF COVENANT LIVING AT WINDSOR PARK VOLUNTEER AT MANY ORGANIZATIONS BOTH IN AND OUTSIDE OF THE COMMUNITY. FORM 990, PART IV, LINE 24A: TAX-EXEMPT BONDS THE ORGANIZATION HAS TAX-EXEMPT BONDS ISSUED AFTER DECEMBER 31, 2002 WITH AN OUTSTANDING PRINCIPAL OF MORE THAN $100,000. THE BONDS ARE REPORTED ON SCHEDULE K OF THE PARENT ORGANIZATION. FORM 990, PART VI, SECTION A, LINE 3 WINDSOR PARK MANOR DELEGATED CONTROL OVER MANAGEMENT DUTIES TO COVENANT LIVING COMMUNITIES AND SERVICES, ITS PARENT ORGANIZATION. FORM 990, PART VI, SECTION A, LINE 6 THE SOLE MEMBER IS COVENANT LIVING COMMUNITIES AND SERVICES. FORM 990, PART VI, SECTION A, LINE 7B S 2.4 OF BYLAWS INCLUDE RESERVED POWERS TO THE [INDIVIDUAL] MEMBERS SUCH AS APPOINTMENT OF PRESIDENT OF COVENANT LIVING COMMUNITIES AND SERVICES, CHANGES TO MISSION AND STRATEGIC PLAN, APPROVAL OF CERTAIN ACQUISITIONS, DISPOSITIONS AND FINANCINGS, CHANGES TO ARTICLES AND BYLAWS. FORM 990, PART VI, SECTION B, LINE 11B MANAGEMENT REVIEW: THE DRAFT FORM 990 WAS REVIEWED BY MULTIPLE LEVELS OF MANAGEMENT INCLUDING THE CHIEF FINANCIAL OFFICER AND OTHER KEY EXECUTIVES. BOARD REVIEW: PRIOR TO FILING, THE 990 PROCESS WAS REVIEWED WITH THE BOARD OF DIRECTORS AT THE BOARD MEETING AND THE FINAL FORM 990 WAS PROVIDED TO EACH BOARD MEMBER. FORM 990, PART VI, SECTION B, LINE 12C COVENANT LIVING COMMUNITIES AND SERVICES HAS AN ADMINISTRATIVE POLICY ON CONFLICT OF INTEREST, IDENTIFYING THE PARAMETERS OF A CONFLICT OF INTEREST AND THE REQUIREMENT TO DISCLOSE ANY SUCH CONFLICT OF INTEREST. THE COVENANT LIVING POLICY IS DISTRIBUTED ANNUALLY TO COVENANT LIVING BOARD MEMBERS AND OFFICERS. THEY ARE ASKED TO SIGN ACKNOWLEDGING RECEIPT OF THE POLICY AND TO DISCLOSE IF THEY HAVE ANY CONFLICT OF INTERESTS. IF SOMEONE IS ABSENT FROM THE MEETING OR FAILS TO RETURN THE ACKNOWLEDGMENT, THERE IS A FOLLOW-UP WITH THE INDIVIDUAL UNTIL THE SIGNED ACKNOWLEDGMENT IS PROVIDED. IN ADDITION TO THE ABOVE, A SEPARATE AND MORE COMPREHENSIVE QUESTIONNAIRE IS SENT TO THE BOARD MEMBERS, OFFICERS, KEY EMPLOYEES AND OTHER INTERESTED PERSONS. THE COMPLETED QUESTIONNAIRES ARE REVIEWED BY COVENANT LIVING'S LEGAL COUNSEL TO DETERMINE IF ANY ACTUAL OR POTENTIAL CONFLICTS EXIST. IF A PERSON BECOMES AN INTERESTED PERSON, HE OR SHE MAY BE CONSIDERED IN DETERMINING WHETHER A QUORUM IS PRESENT. THE INTERESTED PERSON MAY MAKE A SHORT STATEMENT RELATING TO THE TRANSACTION OR ARRANGEMENT IN QUESTION, BUT SHALL NOT BE PRESENT DURING THE DISCUSSION AND SHALL NOT VOTE ON THE MOTION ADDRESSING THE ACTUAL OR POTENTIAL CONFLICT. FORM 990, PART VI, SECTION B, LINE 15B COVENANT LIVING COMMUNITIES AND SERVICES' BOARD OF DIRECTORS HAS DULY APPOINTED AN EXECUTIVE COMPENSATION COMMITTEE (THE "COMMITTEE"), WHICH IS RESPONSIBLE FOR THE REVIEW AND APPROVAL OF ALL COMPENSATION AND BENEFITS PROVIDED TO COVENANT LIVING'S EXECUTIVE MANAGEMENT. THE COMMITTEE HAS ADOPTED A WRITTEN EXECUTIVE COMPENSATION PHILOSOPHY STATEMENT AND AN EXECUTIVE COMPENSATION COMMITTEE CHARTER GOVERNING THE WORK AND REVIEW PROCESS OF THE COMMITTEE. THE COMMITTEE FOLLOWS THE PROCEDURES DESCRIBED IN THE PHILOSOPHY STATEMENT AND THE CHARTER WHEN IT REVIEWS AND APPROVES THE COMPENSATION AND EMPLOYEE BENEFITS PROVIDED TO THE COVENANT LIVING'S SENIOR MANAGEMENT. THE COMMITTEE'S REVIEW ANALYZES EVERY ELEMENT OF COMPENSATION, INCLUDING CURRENT AND DEFERRED COMPENSATION, AND BENEFITS, INCLUDING QUALIFIED AND NON-QUALIFIED BENEFITS. THE COMMITTEE CONDUCTS ITS REVIEW AND APPROVAL PROCESS AT LEAST ANNUALLY, AND APPROVES COMPENSATION AND BENEFITS ONLY TO THE EXTENT THAT THE COMMITTEE HAS CONCLUDED THAT THE COMPENSATION AND BENEFITS CONSTITUTE NO MORE THAN REASONABLE COMPENSATION FOR EACH EXECUTIVE. THE COMMITTEE CONSISTS ENTIRELY OF DISINTERESTED MEMBERS OF THE BOARD, AND THE COMMITTEE WORKS WITH AN INDEPENDENT COMPENSATION CONSULTANT TO PREPARE AND REVIEW IN ADVANCE COMPREHENSIVE DATA SHOWING THE COMPENSATION PROVIDED BY SIMILARLY SITUATED ORGANIZATIONS FOR FUNCTIONALLY SIMILAR POSITIONS. THE COMMITTEE ALSO PREPARES A TIMELY AND THOROUGH WRITTEN RECORD OF ITS DELIBERATIONS AND CONCLUSIONS. AS A RESULT, THE COMMITTEE'S REVIEW PROCESS IS DESIGNED TO SATISFY THE PROCEDURAL CRITERIA NECESSARY TO QUALIFY FOR THE REBUTTABLE PRESUMPTION OF REASONABLENESS UNDER THE FEDERAL INCOME TAX LAW INTERMEDIATE SANCTIONS RULES. THE RESOURCES UTILIZED BY THE COMPENSATION COMMITTEE INCLUDE: 1) INDEPENDENT COMPENSATION CONSULTANT; 2) COMPENSATION SURVEY OR STUDY; 3) APPROVAL BY THE BOARD OR COMPENSATION COMMITTEE. FORM 990, PART VI, SECTION C, LINE 19 THE GOVERNING DOCUMENTS, CONFLICT OF INTEREST POLICY AND FINANCIAL STATEMENTS ARE AVAILABLE UPON REQUEST BY CONTACTING THE COVENANT LIVING COMMUNITIES AND SERVICES FINANCE DEPARTMENT AT 773-878-2294. FORM 990, PART VI, LINE 9: CONTACT INFO FOR DIRECTORS & OFFICERS ALL OF THE ORGANIZATION'S DIRECTORS AND OFFICERS CAN BE CONTACTED AT THIS ADDRESS: COVENANT LIVING COMMUNITIES AND SERVICES - 5700 OLD ORCHARD ROAD, SKOKIE, IL 60077. FORM 990, PART XI, LINE 9: CHANGE IN PRESENT VALUE OF IRREVOCABLE TRUSTS -12,420. 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COVENANT INITIATIVES FOR CARE INC 4055 W PETERSON AVE SUITE 106 CHICAGO IL 60646 271841721 MANAGEMENT/SUPPORT SERVICES IL 501(C)(3) LINE 12B, II COVENANT MINISTRIES OF BENEVOLENCE 0 COVENANT LIVING AT THE HOLMSTAD 700 W FABYAN PARKWAY BATAVIA IL 60510 362835154 CONTINUING CARE RETIREMENT COMMUNITY IL 501(C)(3) LINE 10 COVENANT LIVING COMMUNITIES AND SERVICES 0 COVENANT LIVING COMMUNITIES AND SERVICES 5700 OLD ORCHARD RD SKOKIE IL 60077 363478388 MANAGEMENT/SUPPORT SERVICES IL 501(C)(3) LINE 12B, II EVANGELICAL COVENANT CHURCH 0 COVENANT LIVING OF BIXBY INC 5700 OLD ORCHARD RD SKOKIE IL 60077 320419173 CONTINUING CARE RETIREMENT COMMUNITY IL 501(C)(3) LINE 10 COVENANT LIVING SERVICES INC 0 COVENANT LIVING OF COLORADO 9153 YARROW STREET WESTMINSTER CO 80021 841084331 CONTINUING CARE RETIREMENT COMMUNITY CO 501(C)(3) LINE 10 COVENANT LIVING COMMUNITIES AND SERVICES 0 COVENANT LIVING OF CROMWELL INC 52 MISSIONARY ROAD CROMWELL CT 06416 131740015 CONTINUING CARE RETIREMENT COMMUNITY CT 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