2021-11-15T09:15:49-06:00 2020-12-31 PRICEWATERHOUSECOOPERS LLP 101 SEAPORT BLVD SUITE 500 BOSTON MA 02210 990 2020-10-26 455399218 ONECARE VERMONT ACCOUNTABLE CARE ORGANIZATION LLC % THOMAS BORYS ONEC 8028477220 356 MOUNTAIN VIEW DRIVE STE 301 COLCHESTER VT 05446 THOMAS BORYS VP OF FINANCE-ACO 8028477220 2021-11-13 true THOMAS BORYS 999009999 PAUL J TANIS P01441612 6175305000 2021-11-12 3 2020 2022-09-23 18:48:47Z X THOMAS BORYS 356 MOUNTAIN VIEW DRIVE STE 301 COLCHESTER VT 05446 4160652 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.) 17 17 0 0 0 0 0 22613 0 3974363 0 163676 0 0 0 4160652 0 182060 0 0 0 1474274 0 0 0 0 3395475 0 5051809 0 -891157 59285490 95970985 52707904 90284556 6577586 5686429 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 3276909 182060 735685 DRIVE POPULATION HEALTH STRATEGY - NETWORK PERFORMANCE MANAGEMENT (SEE SCHEDULE O). 580687 0 987282 IMPLEMENTATION OF ACO FINANCIAL AND CLINICAL GOALS - DATA AND ANALYTICS (SEE SCHEDULE O). 335955 0 2251396 IMPLEMENTATION OF ACO FINANCIAL AND CLINICAL GOALS - PAYMENT REFORM (SEE SCHEDULE O). 4193551 true true 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 X 173 0 true 0 false false false false false false false false false false false false X 17 17 true false false false true true false true true false false true true true true true true false false false VT X THOMAS BORYS 8028477220 356 MOUNTAIN VIEW DRIVESUITE 301 COLCHESTER VT 05446 VICTORIA LONER CHIEF EXECUTIVE OFFICER 50.0 0.0 X 377819 0 43317 NORMAN WARD CHIEF MEDICAL OFFICER 50.0 0.0 X 303792 0 25828 SARA BARRY VP & CHIEF OPERATING OFFICER 50.0 0.0 X 284491 0 26210 THOMAS BORYS VP OF FINANCE, ACO 50.0 0.0 X 238571 0 33832 JOAN ZIPKO DIRECTOR ACO OPERATIONS 50.0 0.0 X 175401 0 36026 MARTITA GIARD DIRECTOR ACO STRATEGY&PLANNING 50.0 0.0 X 172230 0 34189 TYLER GAUTHIER DIRECTOR VALUE BASED CARE 50.0 0.0 X 185926 0 8842 GREGORY DANIELS CHIEF COMPLIANCE OFFICER 50.0 0.0 X 152876 0 36382 SUSAN SHANE MEDICAL DIRECTOR 20.0 0.0 X 172926 0 12892 AMY BODETTE DIRECTOR PUBLIC AFFAIRS 50.0 0.0 X 136716 0 39257 JODI FREI MANAGER ACO CLINICAL PROGRAMS 50.0 0.0 X 139006 0 12600 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 BETSEY DAVIS TRUSTEE 2.0 0.0 X 0 0 0 THOMAS DEE TRUSTEE 2.0 0.0 X 0 0 0 STEVEN GORDON TRUSTEE 2.0 0.0 X 0 0 0 JOSEPH HADDOCK TRUSTEE UNTIL 11/20 2.0 0.0 X 0 0 0 TOMASZ JANKOWSKI TRUSTEE UNTIL 11/20 2.0 0.0 X 0 0 0 TODD KEATING TRUSTEE 2.0 0.0 X 0 0 0 COLEEN KOHAUT TRUSTEE 2.0 0.0 X 0 0 0 SALLY KRAFT TRUSTEE 2.0 0.0 X 0 0 0 STEPHEN LEBLANC TRUSTEE 2.0 0.0 X 0 0 0 STEPHEN LEFFLER TRUSTEE UNTIL 10/20 2.0 0.0 X 0 0 0 SIERRA LOWELL TRUSTEE 2.0 0.0 X 0 0 0 PAMELA PARSONS TRUSTEE 2.0 0.0 X 0 0 0 JOSEPH PERRAS CO-CHAIRMAN 2.0 0.0 X 0 0 0 JUDY PETERSON TRUSTEE UNTIL 11/20 2.0 0.0 X 0 0 0 TOBY SADKIN TRUSTEE 2.0 0.0 X 0 0 0 JOHN SAYLES TRUSTEE 2.0 0.0 X 0 0 0 CLAUDIO FORT TRUSTEE AS OF 04/20 2.0 0.0 X 0 0 0 ROBERT PIERATTINI TRUSTEE AS OF 12/20 2.0 0.0 X 0 0 0 JOHN BRUMSTED BOARD AND EXEC COMM CHAIRMAN 2.0 0.0 X X 0 0 0 2339754 0 309375 17 false true false HEALTH CATALYST INC DEPT CH 17917 PALATINE IL 60055 SOFTWARE MAINTENANCE 870546 VERMONT INDEPENDENT TECHNOLOGY LEAD 1 MILL STREET SUITE 249 BURLINGTON VT 05401 SOFTWARE MAINTENANCE 832288 INTRAPRISE HEALTH 19 W COLLEGE AVENUE SUITE 500 YARDLEY PA 19067 SOFTWARE MAINTENANCE 495928 DINSE PC 209 BATTERY STREET BURLINGTON VT 05402 LEGAL 358464 PRICEWATERHOUSECOOPERS LLP PO BOX 7247-8001 PHILADELPHIA PA 19170 TAX/AUDITING 319600 7 0 0 0 0 0 22613 0 22613 PROGRAM REVENUES 900099 1529092 1529092 0 0 DELIVERY SYSTEM RELATED (DSR) REVENUES 900099 2500313 2500313 0 0 SETTLEMENT INCOME 900099 32986 32986 0 0 QUALITY INITIATIVES 900099 17000 17000 0 0 PARTICIPATION FEES 900099 -105028 -105028 0 0 3974363 163676 163676 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 4160652 3974363 0 163676 182060 182060 0 0 0 0 0 0 260106 13496 246610 0 0 0 0 0 944552 759505 185047 0 22573 10134 12439 0 225627 128904 96723 0 21416 11319 10097 0 0 0 0 0 25359 0 25359 0 241950 0 241950 0 11000 11000 0 0 0 0 0 0 0 0 442870 442870 0 0 21553 20397 1156 0 -171658 -129246 -42412 0 377039 372527 4512 0 0 0 0 0 66151 0 66151 0 -27757 -20745 -7012 0 0 0 0 0 -63652 -63695 43 0 7251 0 7251 0 0 0 0 0 2085 0 2085 0 -100135 0 -100135 0 POPUL. HEALTH PROVIDER PYMTS 2455025 2455025 0 0 GREEN MTN CARE BOARD ASSESSMNT 91528 0 91528 0 MISC EXPENSES 16866 0 16866 0 5051809 4193551 858258 0 0 0 48842741 39545587 0 0 8922485 56166677 0 0 0 0 0 0 0 0 1477438 217980 59501 18760 42826 40741 0 0 0 0 0 0 0 0 0 0 59285490 95970985 32355300 86242815 0 0 20352604 4041741 0 0 0 0 0 0 0 0 0 0 0 0 52707904 90284556 X 0 0 0 0 6577586 5686429 6577586 5686429 59285490 95970985 -891157 X false true X true false X 0 0 0 0 22613 22613 0 0 0 0 0 0 0 0 22613 22613 0 22613 163676 163676 0 0 0 186289 3974363 X SCHEDULE A, PART II, LINE 12 THE ORGANIZATION'S CURRENT 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. RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED 0 0 11000 0 11000 0 4182551 0 4193551 0 359678 0 89920 0 0 0 false 359678 359678 539517 11000 11000 89920 89920 134880 0 0 0 0 0 0 0 0 0 9953 8143 1810 0 49548 10617 38931 40741 30847693 0 0 0 26687041 26687041 4160652 0 0 0 4160652 30847693 0 0 0 25795884 25795884 5051809 0 0 0 5051809 PART XI LINE 2D THE ORGANIZATION'S AUDITED FINANCIAL STATEMENTS ARE PRESENTED FOR THE CALENDAR YEAR 2020 WHILE THIS RETURN IS FOR THE MONTHS OF APPROXIMATELY NOVEMBER AND DECEMBER 2020. THIS RETURN EXCLUDES REVENUE AND EXPENSES EARNED AND INCURRED DURING THE MONTHS OF JANUARY-OCTOBER. REVENUE EXCLUDED IS $26,687,041. PART XII LINE 2D THE ORGANIZATION'S AUDITED FINANCIAL STATEMENTS ARE PRESENTED FOR THE CALENDAR YEAR 2020 WHILE THIS RETURN IS FOR THE MONTHS OF APPROXIMATELY NOVEMBER AND DECEMBER 2020. THIS RETURN EXCLUDES REVENUE AND EXPENSES EARNED AND INCURRED DURING THE MONTHS OF JANUARY-OCTOBER. EXPENSES EXCLUDED ARE $25,795,884. true ORANGE SOUTHWEST UNIFIED UNION SCHOOL DISTRICT 64 CENTRAL ST RANDOLPH VT 05060 813996367 GOVT 8855 AMPLIFY GRANT FOR COMMUNITY PROJECTS WITH GOAL OF PREVENATIVE HEALTH. UNIVERSITY OF VERMONT MEDICAL CENTER 111 COLCHESTER AVE BURLINGTON VT 05401 030219309 501(C)(3) 75390 INNOVATION FUNDING TO SUPPORT PROJECTS WHICH WILL FURTHER THE CORE ACTIVITIES OF THE ACO. NORTHWESTERN MEDICAL CENTER 133 FAIRFIELD ST SAINT ALBANS VT 05478 030266986 501(C)(3) 80538 INNOVATION FUNDING TO SUPPORT PROJECTS WHICH WILL FURTHER THE CORE ACTIVITIES OF THE ACO. THE HOWARD CENTER 208 FLYNN AVE BURLINGTON VT 05401 030179433 501(C)(3) 17277 INNOVATION FUNDING TO SUPPORT PROJECTS WHICH WILL FURTHER THE CORE ACTIVITIES OF THE ACO. PLUS VBIF GRANT FOR SPECIAL PROJECTS. 4 0 SCHEDULE I PART IV PROCEDURES FOR MONITORING GRANT FUNDS ANNUALLY ONE CARE STAFF REPORTS TO LEADERS THE POOLS OF MONEY RESERVED FOR VARIOUS GRANT TYPES. GRANTS ARE AWARDED BASED UPON IDENTIFIED NEEDS. ALL GRANT TYPES STEM FROM ACTIVITIES DEEMED TO FURTHER HEALTH CARE REFORM. PROVIDERS ARE CONTACTED AND ENCOURAGED TO SUBMIT APPLICATIONS. UPON REVIEW AND APPROVAL OF GRANT APPLICATIONS SUBMITTED TO ONE CARE, AWARDS ARE MADE. SOME GRANTS ARE A ONE TIME PAYMENT TO RECIPIENT WHILE OTHERS ARE PAID IN INCREMENTS UPON SUBMISSION OF INVOICES AND APPROVAL OF CONTRACTUAL DELIVERABLES. X false false true false false false false false false false false VICTORIA LONER CHIEF EXECUTIVE OFFICER 367962 0 0 0 9857 0 10864 0 32453 0 421136 0 0 0 THOMAS BORYS VP OF FINANCE, ACO 180450 0 0 0 58121 0 6206 0 27626 0 272403 0 0 0 GREGORY DANIELS CHIEF COMPLIANCE OFFICER 152094 0 0 0 782 0 7153 0 29229 0 189258 0 0 0 NORMAN WARD CHIEF MEDICAL OFFICER 303792 0 0 0 21425 0 4403 0 329620 0 0 0 SARA BARRY VP & CHIEF OPERATING OFFICER 279371 0 0 0 5120 0 12921 0 13289 0 310701 0 0 0 TYLER GAUTHIER DIRECTOR VALUE BASED CARE 156172 0 0 0 29754 0 6751 0 2091 0 194768 0 0 0 JOAN ZIPKO DIRECTOR ACO OPERATIONS 169414 0 0 0 5987 0 7946 0 28080 0 211427 0 0 0 MARTITA GIARD DIRECTOR ACO STRATEGY&PLANNING 165488 0 0 0 6742 0 13088 0 21101 0 206419 0 0 0 SUSAN SHANE MEDICAL DIRECTOR 141432 0 0 0 31494 0 9404 0 3488 0 185818 0 0 0 JODI FREI MANAGER ACO CLINICAL PROGRAMS 137034 0 0 0 1972 0 8974 0 3626 0 151606 0 0 0 AMY BODETTE DIRECTOR PUBLIC AFFAIRS 136155 0 0 0 561 0 6383 0 32874 0 175973 0 0 0 SCHEDULE J ALL ONECARE STAFF ARE EMPLOYED BY UVMC, AN UNRELATED ORGANIZATION. ONECARE VERMONT REIMBURSES UVMC FOR THE FULL ECONOMIC COST OF THE EMPLOYEES' EFFORTS. SCHEDULE J, PART III, LINE 2 - 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 4A - SEVERANCE COMPENSATION AMOUNTS SHOWN ON FORM 990, PART VII, SECTION A AND ON SCHEDULE J, PART II INCLUDE $5,499 SEVERANCE PAID TO SUSAN SHANE, A FORMER ASSISTANT MEDICAL DIRECTOR. SCHEDULE J PART I LINE 3 - CEO COMP METHOD ONECARE VERMONT RELIES ON UNIVERSITY OF VERMONT HEALTH NETWORK TO ESTABLISH CEO COMPENSATION VIA PERIODIC MARKET ANALYSIS AND COMPENSATION COMMITTEE REVIEW. FORM 990, PART III, LINE 1 INNOVATIVE PAYMENTS MADE (MISSION CON'T) DURING THIS SHORT TAX PERIOD, PAYMENTS MADE TO PROVIDERS FOSTERING INNOVATION AND BETTER OUTCOMES INCLUDE FIXED PROSPECTIVE PAYMENTS OF $66M AND MEDICARE BLUEPRINT FUNDING OF $1.4M WHICH ARE NETTED OUT ENTIRELY ON THIS RETURN FOR PURPOSES OF FOLLOWING US GAAP. INNOVATIVE PAYMENTS TO THE NETWORK REPORTED ON THIS RETURN INCLUDE POPULATION HEALTH MANAGEMENT PAYMENTS OF $1.6M, COMPLEX CARE COORDINATION PROGRAM OF $1.1M, VALUE BASED INCENTIVE FUND OF $456K, AND PRIMARY PREVENTION PROGRAMS AND GRANTS OF $391K (SEE SCHEDULE I FOR DETAILS). FORM 990, PART III, LINE 4A NETWORK PERFORMANCE MANAGEMENT FURTHERED THE DEVELOPMENT OF FRAMEWORK FOR SUCCESSFUL CLINICAL PROGRAMS. ONECARE CLINICAL LEADERSHIP RAPIDLY PIVOTED FOCUS TO SUPPORT PROVIDERS WITH SCALE UP AND DEPLOYMENT OF TELE HEALTH SERVICES WHEN THE COVID-19 PANDEMIC SHUT DOWN IN PERSON CARE. PROVIDED CONTENT EXPERTISE AND WORKED WITH PAYERS AND ASSOCIATES TO CLARIFY RULES, DISSEMINATE INFORMATION AND TRAIN PROVIDERS. CONDUCTED FOCUSED AUDITS OF THE QUALITY OF PARTICIPATION ACROSS THE ENTIRE SPECTRUM OF CARE IN NEWLY DEVELOPED VALUE BASED CARE PROGRAM. AUDITS OCCURRED IN Q3 & Q4 AND INFORMED PROGRAM DESIGN CHANGES CONCURRENTLY AS WELL AS FOR FUTURE PROGRAM YEARS. CONCURRENTLY AS WELL AS FOR FUTURE PROGRAM YEARS. 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. ANALYZED AND CREATED VISUALIZATION AIDS WHICH PROVIDED RISK BEARING ENTITIES ACTIONABLE FINANCIAL REPORTS WITH WHICH THEY COULD IDENTIFY THEIR INDIVIDUAL FINANCIAL PERFORMANCE UNDER THE ALL PAYER MODEL. DEVELOPED DASHBOARDS IN SUPPORT OF MONITORING PERFORMANCE OBLIGATIONS. UTILIZED INFORMATION PROVIDED ALONGSIDE PARTICIPANT LED GOVERNANCE BODIES TO DISCUSS WAYS TO PROVIDE INCENTIVES WHICH WOULD BE MOST LIKELY TO IMPROVE PERFORMANCE. HELD STRATEGIC PLANNING RETREATS TO PROVIDE INSIGHTS AND INFORM FUTURE REPORTING. FORM 990, PART III, LINE 4C PAYMENT REFORM PROVIDED STRUCTURE NECESSARY TO ALLOW FOR FURTHERANCE OF THE ACO MODEL OF CARE WHICH INCLUDES BOTH CLINICAL AND FINANCIAL ACCOUNTABILITIES. SUCCESSFUL IN MODIFICATION OF PARTICIPANT CONTRACTS TO ENSURE ALIGNMENT OF FINANCIAL AND CLINICAL ACCOUNTABILITIES. MODIFIED 2020 AND 2021 RISK CORRIDORS GIVEN UNCERTAINTY DUE TO THE IMPACT OF COVID-19 ON PROVIDERS. WORKED TO INFORM PAYER DECISIONS TO MITIGATE OR IN SOME CASES ELIMINATE THE FINANCIAL RISK PROVIDERS WOULD SUFFER DUE TO COVID-19. SECURED CARES ACT FUNDS TO OFFSET IMPACT OF MEDICARE RECONCILIATION SO THAT THE BENEFIT OF REFORM EFFORTS WOULD NOT BE ERODED BY PANDEMIC. IMPLEMENTATION OF A NEWLY DEVELOPED VALUE BASED CARE PAYMENT MODEL THAT ALLOWED PAYMENT TO MOVE FROM CAPACITY BUILDING PHASE TO REWARDING ACTUAL CARE MANAGEMENT PERFORMED. WORKED WITH SEVEN HOME HEALTH PROVIDERS TO PILOT A LONGITUDINAL CARE PROGRAM DESIGNED TO DELIVER IN HOME SERVICES AT RISK OF RE-HOSPITALIZATION. PROGRAM WAS DESIGNED TO INCLUDED PATIENT POPULATIONS, REGARDLESS OF WHETHER OR NOT THE PATIENT WAS ATTRIBUTED TO ONE CARE. DATA WAS COLLECTED AND EVALUATED COMPARING EMERGENCY DEPARTMENT AND INPATIENT UTILIZATION PRE AND POST PROGRAM ENROLLMENT. FOR THOSE PATIENTS ATTRIBUTED TO ONE CARE, INPATIENT UTILIZATION REDUCED BY 64%, ED UTILIZATION BY 36%. FOR THOSE NOT ATTRIBUTED TO ONE CARE, INPATIENT UTILIZATION WAS REDUCED BY 42% AND ED UTILIZATION DECREASED BY 64%. THE RESULTS SHOWED POSITIVE PROGRESS AND WILL BE CONTINUED INTO 2021. FORM 990, PART VI, SECTION A, LINE 6 MEMBERS ONECARE VERMONT IS A LIMITED LIABILITY CORPORATION, FOUNDED IN 2012. ONECARE HAS TWO MEMBERS, THE UNIVERSITY OF VERMONT HEALTH NETWORK, AND DARTMOUTH HITCHCOCK HEALTH. FORM 990, PART VI, SECTION A, LINE 7A MEMBER APPOINTMENTS TO GOVERNING BODY EACH MEMBER OF ONE CARE 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, SECTION B, LINE 11B RETURN PREPARATOIN ONECARE VERMONT'S FORM 990 IS PREPARED BY ONECARE STAFF AND REVIEWED BY PRICEWATERHOUSECOOPERS (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 BOARD OF MANAGERS PRIOR TO BEING FILED WITH THE IRS. FORM 990, PART VI, SECTION B, 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, SECTION B, 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, SECTION C, 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 FO 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. FORM 990, PART VI, LINE 2 BUSINESS RELATIONSHIPS DR. JOHN BRUMSTED AND TODD KEATING SERVED AS DIRECTORS AND OFFICERS AT THE UNIVERSITY OF VERMONT HEALTH NETWORK, AN UNRELATED ORGANIZATION, WHERE DR. STEVE LEFFLER SERVED AS A KEY EMPLOYEE. DR. JOHN BRUMSTED AND DR. STEVE LEFFLER SERVED AS DIRECTORS AND OFFICERS AT THE UNIVERSITY OF VERMONT MEDICAL CENTER, AN UNRELATED ORGANIZATION, WHERE TODD KEATING SERVED AS A KEY EMPLOYEE. ALL ONECARE STAFF ARE EMPLOYED BY UVMC, AN UNRELATED ORGANIZATION. ONECARE VERMONT REIMBURSES UVMC FOR THE FULL ECONOMIC COST OF THE EMPLOYEES' EFFORTS. TWO EXCEPTIONS TO THIS ARE DR. NORMAN WARD AND DR. SUSAN SHANE WHO ARE ALSO EMPLOYED PART TIME AS PHYSICIANS WITHIN THE UNIVERSITY OF VERMONT HEALTH NETWORK MEDICAL GROUP. FORM 990, PART X - COLUMN A ONECARE WAS ESTABLISHED IN 2012 AS AN LLC AND ELECTED TAX TREATMENT AS A PARTNERSHIP. THE IRS RECOGNIZED OCV AS A TAX-EXEMPT ORGANIZATION AS OF OCTOBER 26, 2020. FOR THIS REASON, THERE ARE BEGINNING YEAR BALANCES IN THE BALANCE SHEET DESPITE BEING AN INITIAL YEAR RETURN. FORM 990, PART XI, LINE 3 THE FINANCIAL INFORMATION REFLECTS REVENUE AND EXPENSE FOR THE PERIOD COVERED BY THE RETURN. LOSS REPORTED ON THIS LINE IS NOT REPRESENTATIVE OF THE ENTIRE YEAR DUE TO YEAR-END ADJUSTMENTS.