2025-10-08T11:42:32-05:00 2024-12-31 562306396 BEACH FREEMAN LIM & CLELAND LLP 861 PARKVIEW DR N SUITE 200 EL SEGUNDO CA 90245 990 2024-01-01 953080947 NATIONAL HEALTH LAW PROGRAM INC NATI 3102046010 3701 WILSHIRE BLVD 315 LOS ANGELES CA 90010 ELIZABETH TAYLOR EXECUTIVE DIRECTOR 3102046010 2025-10-01 1 0 DOUGLAS BEACH P00367149 3104471234 2024 2025-03-06 01:10:19Z ELIZABETH TAYLOR 3701 WILSHIRE BLVD 315 LOS ANGELES CA 90010 14433551 0 X WWW.HEALTHLAW.ORG X 1976 CA TO PROTECT AND ADVANCE THE HEALTH RIGHTS OF LOW INCOME AND UNDERSERVED INDIVIDUALS. 12 12 59 11 0 0 8293724 11384817 655406 216686 734964 985572 69703 56796 9753797 12643871 976243 1148500 0 0 7499012 8504836 0 0 737893 1744679 1552182 10219934 11205518 -466137 1438353 26323333 27881784 2035717 1598591 24287616 26283193 X SEE SCHEDULE O.THE NATIONAL HEALTH LAW PROGRAM PROTECTS AND ADVANCES THE HEALTH CARE RIGHTS AND RELATED CIVIL RIGHTS OF LOW-INCOME INDIVIDUALS, FAMILIES, AND UNDERSERVED COMMUNITIES. OUR ADVOCACY STRIVES TO GIVE VOICE TO LOW-INCOME PEOPLE AND FAMILIES IN FEDERAL AND STATE POLICY MAKING. THE NATIONAL HEALTH LAW PROGRAM LITIGATES TO ENSURE THAT LOW-INCOME PEOPLE AND UNDERSERVED COMMUNITIES CAN OBTAIN QUALITY HEALTH CARE TO WHICH THEY ARE ENTITLED BECAUSE OF VARIOUS FEDERAL AND STATE LAWS, SUCH AS MEDICAID, THE AFFORDABLE CARE ACT, AMERICANS WITH DISABILITIES ACT, THE CHILDREN'S HEALTH INSURANCE PROGRAM, THE CIVIL RIGHTS ACT OF 1964 AND MANY OTHER LAWS AND POLICIES. 0 0 4213129 1148500 76393 SEE SCHEDULE O.LITIGATION:PARTNERING WITH STATE AND LOCAL ADVOCATES ACROSS THE COUNTRY, ATTORNEYS FOR THE NATIONAL HEALTH LAW PROGRAM REPRESENTED LOW-INCOME INDIVIDUALS AND FAMILIES IN LITIGATION TO ENFORCE PROVISIONS OF THE MEDICAID ACT AND OTHER FEDERAL AND STATE HEALTH AND CIVIL RIGHTS LAWS.FOR EXAMPLE, IN 2024, THE ORGANIZATION CONCLUDED SUCCESSFUL LITIGATION WITH ONE OF OUR STATE PARTNERS TO PREVENT A STATES FROM UNLAWFULLY DROPPING PEOPLE FROM THE MEDICAID ROLLS. WE ALSO CONTINUED LITIGATION TO ENSURE TRANSPARENCY AND ACCOUNTABILITY, DUE PROCESS, AND ACCESS TO SERVICES, INCLUDING SEVERAL CASES TO ENSURE THAT MEDICALLY FRAGILE CHILDREN RECEIVE THE SERVICES THAT ARE GUARANTEED THEM UNDER MEDICAID'S EARLY AND PERIODIC SCREENING, DIAGNOSTIC AND TREATMENT PROVISIONS AND CASES TO ENFORCE THE ANTI-DISCRIMINATION PROVISIONS OF THE AFFORDABLE CARE ACT. WE FILED AMICUS BRIEFS IN CASES RAISING SIGNIFICANT ISSUES AFFECTING THE MEDICAID PROGRAM AND THE AFFORDABLE CARE ACT. 1331646 63900 SEE SCHEDULE O.NATIONAL POLICY:THE NATIONAL HEALTH LAW PROGRAM'S HEALTH POLICY WORK ADVOCATES FOR PROTECTION AND EXPANSION OF HEALTH AND CIVIL RIGHTS OF LOW-INCOME INDIVIDUALS AND FAMILIES AND UNDERSERVED COMMUNITIES. THE NATIONAL HEALTH LAW PROGRAM'S HEALTH POLICY EFFORTS IN 2024 INCLUDED BUT WERE NOT LIMITED TO THE FOLLOWING: (1) ADVOCATING TO PROTECT THE MEDICAID PROGRAM FROM ANTICIPATED EFFORTS TO CUT FUNDING AND IMPOSE BARRIERS TO ENROLLMENT AND ACCESS TO SERVICES; (2) WORKING TO PREVENT DAMAGE CAUSED BY THE END OF THE PUBLIC HEALTH EMERGENCY, THROUGH ADVOCACY AT THE FEDERAL LEVEL AND SUPPORT TO ADVOCATES AT THE STATE LEVEL; (3) PROVIDING LEGAL AND POLICY SUPPORT TO NATIONAL AND STATE BASED COALITIONS WORKING TO PROTECT, AND WHERE POSSIBLE, EXPAND ACCESS TO HEALTH CARE FOR LOW-INCOME INDIVIDUALS, FAMILIES AND UNDERSERVED COMMUNITIES; (4) PROVIDING LEGAL SUPPORT AND PROBLEM-SOLVING EXPERTISE TO POLICYMAKERS, ADVOCATES, AND PROVIDERS AS LEGAL ISSUES ARISE AT THE ADMINISTRATIVE (REGULATORY) AND STATE IMPLEMENTATION LEVELS; (5) PROVIDING LEGAL SUPPORT TO POLICYMAKERS TO CONSIDER NEW MODELS FOR PROVIDING HEALTH CARE TO ALL.DURING 2024 THE NATIONAL HEALTH LAW PROGRAM AGAIN INCREASED ITSSUBSTANTIAL EFFORTS TO COUNTER HEALTH CARE DISPARITIES AND DEFEND CIVIL RIGHTS LAWS, INCLUDING BY ADVOCATING FOR STRONG REGULATIONS TO ENFORCE SECTION 1557, THE ANTI-DISCRIMINATION PROVISION OF THE AFFORDABLE CARE ACT.IN 2024, NATIONAL HEALTH LAW PROGRAM STAFF PROVIDED STATE AND FEDERAL HEALTH CARE ADVOCATES LEGAL ASSISTANCE FOR MYRIAD POLICY AND LEGAL CONCERNS OF LOW-INCOME INDIVIDUALS AND FAMILIES. STAFF MEMBERS WERE ALSO INVOLVED IN AND/OR FEATURED IN SCORES OF CONFERENCES AND TRAINING EVENTS. STAFF ALSO PRODUCED NUMEROUS FACT SHEETS, ISSUE BRIEFS, Q&A'S, AND ADDITIONAL RESOURCES THAT WERE SHARED VIA LISTSERVS, EMAIL, SOCIAL MEDIA PLATFORMS, PRESS OUTREACH, AND OTHER MEANS. MUCH OF THIS WORK PRODUCT WAS ALSO POSTED ON THE ORGANIZATION'S WEBSITE. 1171289 83573 SEE SCHEDULE O.CALIFORNIA POLICY:IN 2024, NHELP ENGAGED IN SIGNIFICANT EFFORTS TO HELP DEVELOP AND IMPLEMENT IMPROVEMENTS TO CALIFORNIA'S PUBLICLY FUNDED HEALTH CARE SYSTEM. SOME OF THE KEY EFFORTS INCLUDED: WORKING WITH THE STATE TO IMPLEMENT A NEW LAW EXPANDING FULL-SCOPE MEDI-CAL TO ALL ADULTS REGARDLESS OF IMMIGRATION STATUS; ADVOCATING FOR AND WORKING WITH THE STATE TO IMPROVE ACCESS TO BEHAVIORAL HEALTH CARE THROUGHT THE MEDI-CAL PROGRAM; INSURING CONTINUITY OF CARE FOR PEOPLE TRANSITIONING FROM ONE MANAGED CARE PLAN TO ANOTHER; CONTINUING ONGOING EFFORTS TO EXPAND ACCESS TO SEXUAL AND REPRODUCTIVE HEALTH CARE, INCLUDING DOULA AND CONTRACEPTIVE SERVICES; AND IMPLEMENTING CHANGES TO MEDI-CAL THROUGH THE CALIFORNIA ADVANCING AND INNOVATING MEDI-CAL (CALAIM) INITIATIVE. 2044375 THE NATIONAL HEALTH LAW PROGRAM ENGAGED IN A NUMBER OF TARGETED PROJECTS TO SUPPORT OUR PRIMARY GOALS. 2044375 8760439 1 1 0 1 0 0 0 0 0 0 1 0 0 0 1 1 1 0 0 0 0 0 0 0 0 0 0 1 0 1 0 0 0 0 0 0 0 0 1 0 0 0 0 0 0 0 0 1 60 0 1 59 1 0 0 0 0 0 0 0 0 0 0 X 12 12 0 0 0 0 0 0 0 1 1 0 1 1 1 1 1 1 1 1 1 1 0 CA X RSM US LLP 2022932200 1250 H ST NW 700 WASHINGTON DC 20005 MARC FLEISCHAKER GENERAL COUNSEL 5.00 X 0 0 0 JANE PREYER BOARD MEMBER 5.00 X 0 0 0 ARIAN JUNE BOARD MEMBER 5.00 X 0 0 0 REP HENRY WAXMAN SENIOR ADVISOR TO THE BOAR 5.00 X 0 0 0 ANN KAPPLER CHAIR 5.00 X 0 0 0 SHAMINA SNEED SECRETARY 5.00 X 0 0 0 NICK SMIRENSKY TREASURER 5.00 X 0 0 0 RON L WISOR JR BOARD MEMBER 5.00 X 0 0 0 MICHELE JOHNSON BOARD MEMBER 5.00 X 0 0 0 WILLIAM B SCHULTZ VICE CHAIR 5.00 X 0 0 0 LOURDES A RIVERA BOARD MEMBER 5.00 X 0 0 0 DONALD B VERRILLI JR BOARD MEMBER 5.00 X 0 0 0 LD BRITT BOARD MEMBER 5.00 X 0 0 0 JEANNA CULLINS BOARD MEMBER 5.00 X 0 0 0 STEPHEN WILLIAMS BOARD MEMBER 5.00 X 0 0 0 JOEL FERBER BOARD MEMBER 5.00 X 0 0 0 ELIZABETH TAYLOR EXECUTIVE DIRECTOR 45.00 X 325481 0 10138 JORGE ADRIAN NARANJO CHIEF OPERATING OFFICER 45.00 X 237278 0 66550 KIMBERLY LEWIS MANAGING ATTORNEY 45.00 X 204568 0 37244 MARA YOUDELMAN MANAGING ATTORNEY 45.00 X 219977 0 7719 JANE PERKINS LEGAL DIRECTOR 45.00 X 276671 0 32497 SARAH SOMERS MANAGING ATTORNEY 45.00 X 218383 0 26775 1482358 0 180923 6 0 1 0 RSM LLP 5155 PAYSPHERE CIRCLE CHICAGO IL 606740051 ACCOUNTING & CONSULTING 156640 THE NEBO COMPANY 5115 MACARHUR BLVD WASHINGTON DC 20016 COACHING/CONSULTING 132825 2 11384817 1789681 11384817 ATTORNEY FEES 541100 152786 152786 CONFERENCE FEES & HONORARIUM 611430 36691 36691 PUBLICATIONS 513120 27209 27209 216686 994572 994572 40616 0 40616 40616 40616 1780680 1789680 -9000 -9000 -9000 MISCELLANEOUS REVENUE 900099 16180 16180 16180 12643871 223866 0 1035188 1148500 1148500 562759 437697 79627 45435 53979 41983 7638 4358 6308987 4906945 892682 509360 166230 128154 24774 13302 857378 660991 127780 68607 555503 428262 82790 44451 200496 136911 61565 2020 78516 48938 29026 552 213061 109200 103566 295 118046 62871 44025 11150 46822 26928 16313 3581 40592 28954 10235 1403 PROFESSIONAL SERVICES 491550 335661 150938 4951 OFFICE SUPPLIES 86277 64333 21652 292 OUTSIDE SERVICES 47287 47287 DUE AND MEMBERSHIPS 47108 30429 2751 13928 182427 116395 51824 14208 11205518 8760439 1707186 737893 2065384 1071033 2431895 3903069 312246 239653 45573 142685 12661 12661 0 0 20615886 21768066 852349 757278 26323333 27881784 1158221 826248 877496 772343 2035717 1598591 X 17577246 20325943 6710370 5957250 24287616 26283193 26323333 27881784 X 1438353 669005 519745 -631526 X 0 1 X 1 0 X 8513015 11148747 10734416 8293724 11384817 50074719 8513015 11148747 10734416 8293724 11384817 50074719 19107016 30967703 241529 194759 206798 809284 1035189 2487559 8250 2503 60 16180 26993 52589271 1361047 0.58890 0.45410 X RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED 25 80860 80885 11644379 11725264 736263 184066 0 0 623682 669503 701188 736263 2730636 4095954 80553 57033 92765 80885 311236 155921 167376 175297 184066 682660 1023990 3031 25 3056 12661 12661 0 0 LEASE LIABILITIES 772343 772343 X 13720841 669005 519746 1188751 12532090 111781 111781 12643871 11725264 519746 519746 11205518 0 11205518 PART X, LINE 2: THE ENTITY EVALUATES UNCERTAIN TAX POSITIONS WHEREBY THE EFFECT OF THE UNCERTAINTY WOULD BE RECORDED IF THE TAX POSITIONS WERE MORE LIKELY THAN NOT TO BE SUSTAINED UPON EXAMINATION. AS OF YEAR-END, THE ENTITY HAD NO UNCERTAIN TAX POSITIONS REQUIRING ACCRUAL OR DISCLOSURE. PART XI, LINE 2D - OTHER ADJUSTMENTS: IN-KIND/PRO BONO SERVICES 519,746. PART XI, LINE 4B - OTHER ADJUSTMENTS: INVESTMENT INCOME 111,781. PART XII, LINE 2D - OTHER ADJUSTMENTS: IN-KIND/PRO BONO EXPENSES 519,746. 1 ACADIANA LEGAL SERVICE CORPORATION 1020 SURREY STREET LAFAYETTE LA 70501 951869805 10000 0 USDA DFAP ATLANTA LEGAL AID SOCIETY 54 ELLIS STREET NE ATLANTA GA 30303 580568691 63000 0 MEDICAID MONITORING BIRTH IN COLOR RVA FOUNDATION 115 EAST BROAD STREET UNIT 1A RICHMOND VA 23219 833221701 18000 0 CONTRACEPTIVE EQUITY CHARLOTTE CENTER FOR LEGAL ADVOCACY (CCLA) 1431 ELIZABETH AVENUE CHARLOTTE NC 28204 561202940 29500 0 CONTRACEPTIVE EQUITYUSDA DFAP COLORADO CENTER OF LAW & POLICY (CCLP) 789 N SHERMAN ST STE 300 DENVER CO 80203 841264154 45000 0 HEALTH LAW PARTNERSHIP COMMUNITY LEGAL AID SOCIETY INC (CLASI) 100 WEST 10TH STREET WILMINGTON DE 19801 516000158 45000 0 HEALTH LAW PARTNERSHIP DISABILITY RIGHTS CONNECTICUT (DRC) 864 WETHERSFIELD AVENUE HARTFORD CT 06114 813156636 45000 0 HEALTH LAW PARTNERSHIP FAMILY VOICES OF CALIFORNIA 1663 MISSION STREET SAN FRANCISCO CA 94103 850430800 5500 0 CALIFORNIA CHILDREN'S SERVICE FLORIDA HEALTH JUSTICE PROJECT (FHJP) 3793 IRVINGTON AVENUE MIAMI FL 33133 823397515 63000 0 MEDICAID MONITORING GEORGETOWN UNIVERSITY SPONSORED ACCOUNTING OFFICE P O BOX 571164 WASHINGTON DC 20057 530196603 40000 0 ADMIN ADVOCACY GEORGIA LEGAL SERVICES PROGRAM INC 104 MARIETTA STREET NW SUITE 250 ATLANTA GA 30303 581111590 10000 0 USDA DFAP INDIANA JUSTICE PROJECT (IJP) 6101 NORTH KEYSTONE AVENUE INDIANAPOLIS IN 46220 861217450 45000 0 HEALTH LAW PARTNERSHIP LEGAL AID OF ARKANSAS 1200 WEST WALNUT STREET SUITE 3101 ROGERS AR 72756 710439977 73000 0 MEDICAID MONITORINGUSDA DFAP LEGAL AID OF NORTH CAROLINA 319 CHAPANOKE ROAD SUITE 104 RALEIGH NC 27603 311784161 63000 0 MEDICAID MONITORING LEGAL AID SERVICES OF OKLAHOMA 3800 NORTH CLASSEN BOULEVARD SUITE 230 OKLAHOMA CITY OK 73118 731022203 10000 0 USDA DFAP LEGAL AID SOCIETY OF SAN DIEGO (LASSD) 110 EUCLID AVENUE SAN DIEGO CA 92114 951869806 10000 0 USDA DFAP LEGAL COUNCIL FOR HEALTH JUSTICE (LCHJ) 17 N STATE STREET SUITE 900 CHICAGO IL 60602 363563802 73000 0 MEDICAID MONITORINGUSDA DFAP LEGAL SERVICES ALABAMA PO BOX 20787 MONTGOMERY AL 36120 630743038 25000 0 USDA DFAP LEGAL SERVICES OF EASTERN MISSOURI (LSEM) 4232 FOREST PARK AVE SAINT LOUIS MO 63108 430816805 63000 0 MEDICAID MONITORING MISSISSIPPI CENTER FOR JUSTICE 5 OLD RIVER PLACE SUITE 203 JACKSON MS 39202 134203234 48500 0 CONTRACEPTIVE EQUITYHEALTH LAW PARTNERSHIP MISSISSIPPI CENTER FOR LEGAL SERVICES CORP 111 EAST FRONT STREET PO DRAWER 1728 HATTIESBURG MS 39403 640621891 10000 0 USDA DFAP NEW MEXICO CENTER ON LAW & POVERTY 301 EDITH BOULEVARD NORTHEAST ALBUQUERQUE NM 87102 850437960 40000 0 HEALTH LAW PARTNERSHIP NORTH MISSISSIPPI RURAL LEGAL SERVICES 93 RYLAND WAY OXFORD MS 38655 640581747 10000 0 USDA DFAP PONTIFICAL CATHOLIC UNIVERSITY OF PUERTO RICO 2250 BLVD LUIS A FERRE AGUAYO SUITE 523 PONCE PR 00717 660191965 40000 0 HEALTH LAW PARTNERSHIP SOUTH CAROLINA APPLESEED LEGAL JUSTICE CENTER 1518 WASHINGTON STREET COLUMBIA SC 29201 571035023 73000 0 MEDICAID MONITORINGUSDA DFAP TENNESSEE JUSTICE CENTER 211 7TH AVENUE NORTH STE 100 NASHVILLE TN 37219 621630417 143000 0 HEALTH LAW PARTNERSHIPMEDICAID MONITORINGUSDA DFAP WILLIAM E MORRIS INSTITUTE FOR JUSTICE 3707 NORTH 7TH STREET 300 PHOENIX AZ 85014 860817170 50000 0 HEALTH LAW PARTNERSHIP YELLOWHAMMER FUND PO BOX 610250 BIRMINGHAM AL 35261 821822204 18000 0 CONTRACEPTIVE EQUITY X X X 0 0 0 0 0 0 0 0 0 ELIZABETH TAYLOR EXECUTIVE DIRECTOR 325481 0 0 0 0 0 8678 0 1460 0 335619 0 0 0 JANE PERKINS LEGAL DIRECTOR 276671 0 0 0 0 0 8301 0 24196 0 309168 0 0 0 JORGE ADRIAN NARANJO CHIEF OPERATING OFFICER 237278 0 0 0 0 0 7546 0 59004 0 303828 0 0 0 SARAH SOMERS MANAGING ATTORNEY 218383 0 0 0 0 0 6572 0 20203 0 245158 0 0 0 KIMBERLY LEWIS MANAGING ATTORNEY 204568 0 0 0 0 0 6000 0 31244 0 241812 0 0 0 MARA YOUDELMAN MANAGING ATTORNEY 219977 0 0 0 0 0 6259 0 1460 0 227696 0 0 0 X 2 1789681 MARKET PRICE 0 0 0 FORM 990, PART VI, SECTION B, LINE 11B THE FINANCE COMMITTEE OF THE BOARD SHALL HAVE THE RESPONSIBILITY FOR REVIEWING THE ORGANIZATION'S FORM 990 (INCLUDING ALL PERTINENT SCHEDULES) BEFORE IT IS FILED WITH THE INTERNAL REVENUE SERVICE. A DRAFT OF THE FORM 990 SHOULD BE READY FOR REVIEW BY THE FINANCE COMMITTEE OF THE BOARD PRIOR TO THE FILING DEADLINE. IF THE NEXT FINANCE COMMITTEE OF THE BOARD MEETING IS NOT SCHEDULED SOON ENOUGH, THE DRAFT WILL BE SENT TO ALL THE BOARD MEMBERS VIA EMAIL. BOARD MEMBERS CAN THEN ASK OR MAKE QUESTIONS, COMMENTS, AND SUGGESTED REVISIONS. IN CONDUCTING THEIR REVIEW OF THE DRAFT OF THE FORM 990, IT IS PREFERRED THAT THE FINANCE COMMITTEE OF THE BOARD SHALL CONDUCT A TOP-LEVEL OR BIG-PICTURE TYPE OF REVIEW. HOWEVER, IF THE FINANCE COMMITTEE OF THE BOARD DESIRES OR DEEMS IT NECESSARY TO CONDUCT A MORE DETAILED REVIEW OF THE FORM 990, THEN THEY SHOULD CONTACT THE PREPARER OF THE FORM 990 TO REQUEST COPIES OF THE RELEVANT DETAILED TAX RETURN WORKPAPERS WHICH THEY WOULD LIKE TO SEE. ONCE THE FINANCE COMMITTEE OF THE BOARD HAS COMPLETED ITS INITIAL REVIEW OF THE FORM 990, THE FINANCE COMMITTEE WILL APPROVE THE REVIEW VIA EMAIL TO THE COO. THE PREPARER OF THE FORM 990 SHOULD MAKE ANY REVISIONS TO THE FORM 990 AS SOON AS FEASIBLY POSSIBLE TO ENSURE THAT THE FORM 990 IS FILED WITH THE INTERNAL REVENUE SERVICE ON A TIMELY BASIS. ALL OF THE QUESTIONS, COMMENTS, AND SUGGESTED REVISIONS SET FORTH BY THE FINANCE COMMITTEE OF THE BOARD SHOULD BE DOCUMENTED, ALONG WITH ANY RESPONSES FROM THE PREPARER OF THE FORM 990, IF APPLICABLE. FORM 990, PART VI, SECTION B, LINE 12C THE ORGANIZATION REQUIRES ALL BOARD MEMBERS TO COMPLETE AN ANNUAL QUESTIONNAIRE TO VERIFY THERE ARE NO CONFLICTS OF INTEREST OR THAT ANY CONFLICTS OF INTEREST ARE DOCUMENTED. FORM 990, PART VI, SECTION B, LINE 15 THE ORGANIZATION FOLLOWS THE PROCEDURES BELOW IN DETERMINING INSIDER COMPENSATION: THE INSIDERS OF THE ORGANIZATION ARE DEEMED AS FOLLOWS: -ANY MEMBER OF THE BOARD OF DIRECTORS -ANY OFFICER OF THE ORGANIZATION -EXECUTIVE DIRECTOR -ANY FAMILY MEMBER FOR ANY OF THE AFOREMENTIONED DEFINITION OF COMPENSATION - ALL-INCLUSIVE, INCLUDING ALL COMPENSATORY BENEFITS RECEIVED (OTHER THAN NONTAXABLE FRINGE BENEFITS); INCLUDES SALARIES, BONUSES, TAXABLE FRINGE BENEFITS, RETIREMENT PLAN CONTRIBUTIONS, LOAN AGREEMENTS, AND DEFERRED COMPENSATION AMOUNTS. DEFINITION OF REASONABLE COMPENSATION - AMOUNT OF COMPENSATION A SIMILAR ENTERPRISE, WHETHER TAXABLE OR TAX-EXEMPT, WOULD PAY FOR SIMILAR SERVICES UNDER SIMILAR CIRCUMSTANCES; REASONABLENESS OF COMPENSATION CAN BE ESTABLISHED BY INDEPENDENT COMPENSATION SURVEYS AND ACTUAL WRITTEN OFFERS FROM SIMILAR INSTITUTIONS. WHEN DETERMINING THE ANNUAL COMPENSATION FOR ANY INSIDER, THE ORGANIZATION SHALL ALWAYS UNDERTAKE AND SATISFY ALL THREE PRONGS OF THE REBUTTABLE PRESUMPTION SET FORTH IN THE INTERNAL REVENUE CODE REGARDING INTERMEDIATE SANCTIONS (SECTION 4958). 1. COMPENSATION ARRANGEMENT APPROVED IN ADVANCE BY INDEPENDENT MEMBERS OF THE ORGANIZATION'S GOVERNING BODY (BOARD OF DIRECTORS OR A SUBCOMMITTEE THEREOF) THAT IS COMPOSED OF PERSONS WHO DO NOT HAVE A CONFLICT OF INTEREST WITH RESPECT TO THE COMPENSATION ARRANGEMENT. 2. BEFORE MAKING THE REASONABLE COMPENSATION DETERMINATION, THE GOVERNING BODY (OR SUBCOMMITTEE THEREOF) RELIED UPON COMPARABILITY DATA (COMPARABILITY DATA INCLUDES COMPENSATION PAID BY COMPARABLE AND SIMILARLY SITUATED ENTITIES) IN DECIDING WHETHER TO APPROVE THE COMPENSATION. 3. GOVERNING BODY CONTEMPORANEOUSLY DOCUMENTS ITS BASIS FOR MAKING A REASONABLE COMPENSATION DETERMINATION, AS FOLLOWS: A. TERMS OF THE APPROVED COMPENSATION AND THE DATE APPROVED BY THE BOARD, B. MEMBERS OF THE BOARD PRESENT DURING DEBATE ON THE COMPENSATION AMOUNT AND THOSE WHO VOTED ON IT AND HOW THEY VOTED ON IT, C. DESCRIPTION OF THE COMPARABILITY DATA OBTAINED AND RELIED UPON AND HOW SUCH DATA WAS OBTAINED, D. ANY ACTIONS BY A BOARD MEMBER HAVING A CONFLICT OF INTEREST (E.G. DISCLOSURE OF THE CONFLICT OF INTEREST; RECUSAL FROM THE DISCUSSION), E. DOCUMENTATION OF THE BASIS FOR THE COMPENSATION DETERMINATION BEFORE THE LATER OF THE NEXT BOARD MEETING OR 60 DAYS AFTER THE FINAL ACTIONS OF THE AUTHORIZED BODY ARE TAKEN. IT IS ESSENTIAL THAT ANY INDIVIDUAL WHOSE COMPENSATION IS BEING DISCUSSED NOT BE PRESENT DURING SUCH DISCUSSIONS. ALL IDENTIFIED PAYMENTS OF UNREASONABLE COMPENSATION TO AN INSIDER SHOULD BE CORRECTED (UNDOING OF THE UNREASONABLE COMPENSATION TO THE EXTENT POSSIBLE) AS SOON AS FEASIBLY POSSIBLE; FOR EXAMPLE, THE INSIDER SHOULD PAY BACK TO THE ORGANIZATION THE UNREASONABLE COMPENSATION AMOUNTS PLUS INTEREST TO PUT THE ORGANIZATION IN A FINANCIAL POSITION NO WORSE THAN THAT IN WHICH IT WOULD BE IF THE INSIDER WERE DEALING UNDER THE HIGHEST FIDUCIARY STANDARDS. THE REASONABLE COMPENSATION DISCUSSION SHOULD BE UNDERTAKEN BY THE BOARD AT LEAST ANNUALLY. THE ORGANIZATION SHALL REFRAIN, WHENEVER POSSIBLE, FROM PAYING CONTINGENT COMPENSATION TO INSIDERS AND ALSO AVOID THE PAYMENT OF GOLDEN PARACHUTE PAYMENTS TO INSIDERS. FORM 990, PART VI, SECTION C, LINE 19 PROCEDURES FOR PUBLIC INSPECTION OF DOCUMENTS THE FOLLOWING ORGANIZATIONAL DOCUMENTS OF THE ORGANIZATION WILL BE AVAILABLE (FOR INSPECTION OR COPYING) AT THE ORGANIZATION'S MAIN OFFICE DURING NORMAL BUSINESS HOURS AT NO CHARGE: - TAX EXEMPTION APPLICATION (FORM 1023) - INTERNAL REVENUE SERVICE DETERMINATION LETTER - ARTICLES OF INCORPORATION - BY-LAWS THE FOLLOWING DOCUMENTS OF THE ORGANIZATION WILL BE AVAILABLE ONLINE AT HEALTHLAW.ORG: - PUBLIC INSPECTION COPY OF THE FORM 990 FOR THE PREVIOUS THREE YEARS - AUDITED FINANCIAL STATEMENTS THE PUBLIC INSPECTION COPY OF THE FORM 990 WILL NOT INCLUDE SCHEDULE A - EXCESS CONTRIBUTORS OR SCHEDULE B - NAMES AND ADDRESSES OF CONTRIBUTORS. THE ORGANIZATION WILL MAKE BEST EFFORTS TO ENSURE THAT THE FORMS 990 HELD AT THEIR MAIN OFFICE ARE THE MOST UPDATED VERSIONS OF SUCH. FOR EXAMPLE, IN THE INSTANCE WHERE A FORM 990 HAS BEEN AMENDED, THE AMENDED VERSION OF THE FORM 990 SHOULD BE THE ONE AVAILABLE FOR PUBLIC INSPECTION. WHEN RESPONDING TO A PUBLIC INSPECTION REQUEST FOR ANY ORGANIZATIONAL DOCUMENT OR FORM 990 BY ANYONE, THE ORGANIZATION SHALL FULFILL SUCH REQUEST IN A TIMELY FASHION WITHOUT INQUIRING AS TO THE REASON FOR THE PUBLIC INSPECTION REQUEST. FORM 990, PART XI, LINE 9: IN-KIND/PRO BONO SERVICES -519,745. INVESTMENT INCOME -111,781.