2017-10-16T12:55:29-05:00 2016-12-31 GRANT THORNTON LLP 757 THIRD AVENUE 3RD FLOOR NEW YORK NY 100172013 990 2016-01-01 111874383 Center for Developmental Disabilities % MARY BETH LICHTNEGER CENT 6318788900 72 south woods road woodbury NY 11797 MARY BETH LICHTNEGER cfo 6318788900 2017-10-16 true Scott Thompsett P00741490 2125990100 2017-10-16 38.84.128.189 26377520172895000064 2017-10-16 P 0AE51D185F2B8DBE64241C7507ECC047D5915589 BB689B47C4810116FFAF734305B3B6F212C66569 2016 2021-01-29 14:40:06Z WALTER STOCKTON 221 NORTH SUNRISE SERVICE RD MANORVILLE NY 11949 33602103 false X www.centerfordd.com X 1958 NY TO HELP CHILDREN & ADULTS WITH DIFFERING ABILITIES ACHIEVE THEIR DREAMS BY OVERCOMING BARRIERS TO LIVING, WORKING AND LEARNING IN THE COMMUNITY OF THEIR CHOICE 15 14 728 20 0 691941 788175 31661248 32563396 4357 11634 33491 -7780 32391037 33355425 0 0 0 0 25705997 25235587 0 0 0 7458807 7448017 33164804 32683604 -773767 671821 19096695 17096142 17940440 15242449 1156255 1853693 X THE CENTER'S MISSION IS TO HELP CHILDREN AND ADULTS WITH DIFFERING ABILITIES ACHIEVE THEIR DREAMS BY OVERCOMING BARRIERS TO LIVING, WORKING, LEARNING & ENJOYING RECREATIONAL OPPORTUNITIES IN THE COMMUNITY OF THEIR CHOICE. false false 15001665 0 17899177 The Centers Adult Residence Program consists of seven Intermediate Care Facilities (ICFs), which are the more traditional type of group homes governed by the New York State Office for People with Developmental Disabilities (OPWDD). Intermediate Care Facilities Our Intermediate Care Facilities are The Centers larger residential facilities, with 8-12 people with developmental and intellectual disabilities living in a co-ed private home in diverse communities in Nassau County. These homes are staffed 24 hours a day, and generally have a full-time House Manager and Assistant House Manager assigned for oversight and day-to-day operational purposes. The Center strives to make each residence a true, home-like environment while actively providing programming to each person on an individualized basis. The Treatment Team approach is used to assess a persons capabilities and needs for medical and clinical areas, as well as independent living, and community integration skills. Goals are developed to assist each person in achieving the maximum level of independence possible, which, in turn, may help the person be able to move to a less-restrictive environment in the future. The QIDP (Qualified Intellectual Disabilities Professional) is charged with the development and monitoring of the persons overall plan of care, ensuring that a persons needs are met adequately and in a timely manner. The person-centered model of administering a treatment plan consisting of individualized goals and programming, ensures that the person is an active part of the planning process to the extent that s/he is capable or wants to participate. Clinical Services, such as Psychology and Speech Services, as well as Nursing services, are part of the multi-faceted approach to the life-long learning and support offered in an ICF setting. Family members are an integral part of the Treatment Team and are encouraged to be actively involved in the planning, and the everyday execution of the treatment plan. Consistency is key to an individuals success, therefore, the participation of family, especially while a loved one is on home visits, increases the success rate of the person. The staffing ratio in an ICF is typically a 1:3 (1 staff to 3 residents) model, with variations based on the needs of the individuals living in the home. In addition, there is a 24-hour on-call system for staff to reach program and nursing administrators in the event that additional supports are required. The programs administration team has a combined experience of over 100 years, serving 68 men and women who live in the Centers ICFs. Leadership skills are an essential part of the success of the program, which has gained notoriety for attaining several "perfect" surveys conducted by the NYS Division of Quality Management during the past five years. The Adult Residence Program provides opportunities to our residents that are "normalized", yet may have never been available in the past, as we strive for community inclusion in the neighborhoods in which we live and work. Seeking ideas and input from all people, a wide variety of choices are provided to encourage and introduce new and diverse interests. The Adult Residence Program strives to involve each and every person and their family members in all aspects of the persons life: seeking a higher overall quality of life through community inclusion and skill acquisition, while maintaining quality programming. The never-ending quest for helping people with developmental / intellectual disabilities and autism in reaching increased levels of independence serves as an incentive for all staff, whether Direct Support or Administration, to provide limitless support in a caring, home environment. 8258300 0 8466882 The Childrens Day Program, a division of the Center for Developmental Disabilities, Inc., is a 12 month educational program serving children ages 5-21 who have educational classifications of Autism (A), Intellectual Disability (ID) or Multiple Disabilities (MD). Students are referred to the program through their home school district when their IEP goals and educational needs cannot be met in their current placements. We presently serve students living in Nassau and Suffolk Counties as well as New York City. Classrooms have staffing ratios of either 6:1:2 or 9:1:3. Our goal is to provide quality educational programming in order to increase every students level of independence so he or she is able to participate more effectively in the community. The classroom curriculum covers academic subjects such as English Language Arts, Mathematics, Science and Social Studies, while also fostering the development of each students daily living skills and social skills. Students receive direct instruction in each area and are provided with opportunities to demonstrate their skills in real and simulated situations. Computer and technology education are a part of each classrooms weekly schedule. Students have the opportunity to visit the computer lab where they can improve upon their attention to task, their ability to type and access computer programs and academics. At times, students also use the computer as a means to engage in appropriate recreational activities. Students are also provided opportunities to participate in engaging, interactive lessons presented on SMART Boards and a SMART Table. Additionally, classrooms also have access to iPads and Prox Talkers to be used as educational tools. 5640659 0 6197337 The Centers Adult Day Services Division located in Hicksville N.Y. offers adults 21 and older with autism and other developmental disabilities a variety of day habilitation and employment services using a person centered framework. We recognize that all adults regardless of ability need meaningful work, positive social interactions and opportunities to experience and learn new things. Our primary goal is to provide a pathway for independence and community involvement for all of our program participants throughout the course of their adult lives. Employment Services Supported Employment is a vocational community placement and training program serving over 50 adults with developmental disabilities who have demonstrated the skills and desire necessary to work in competitive employment. Its goal is to provide the training and supports necessary for these individuals to successfully secure and maintain community based employment, and to become a valued member of an employers stable workforce. The program provides; vocational counseling and assessment, job development, on the job training, work place advocacy, sensitivity training to employers and co-workers, and assistance with maintaining social security benefits through various work incentive programs. This program is funded through the New York State Education Department: Adult Career and Continuing Education Services Vocational Rehabilitation (ACCES-VR) and New York States Office for People With Developmental Disabilities (OPWDD). Eligibility for services through ACCES-VR and/or OPWDD is required. Pathways to Employment is a service that assists individuals graduating from school with limited employment experience. This individual would be on the cusp for Supported Employment. We work with individuals on up to four different job sites in order to see what type of work they enjoy. Then we work on interviewing skills and creating a resume. At the end of one year, we have a good understanding of what type of work each individual is suited for and know how to proceed in our Supported Employment program. Day Habilitation Services The Centers Day Habilitation Services help the person learn new skills, have new experiences and receive the supports necessary to pursue personal goals. These services are flexible and can be provided almost anywhere. The Center currently provides day habilitation services to over 175 adults with developmental disabilities through four distinct programs. Through our day habilitation programs each individual will have the opportunity to participate in activities based on their likes, interests and personal strengths. Programs are structured to provide the supports needed to function as independently as possible, with no more supports provided than is needed by the person to be a successful fully engaged member of society. Clinical support in nursing, psychology, speech and music therapy are on site at our Hicksville Campus on a daily basis. 743801 0 0 FAMILY SUPPORT GRANTS 197469 0 0 TRANSPORTATION 185650 0 0 OTHER PROGRAMs (Less Nassacu Center Resid.) 1126920 0 0 30027544 true true false false false false false false true false true false false true true true false true true false false false false false true true false false false true false false false false false false true false false false false false false true true false false false true 48 0 true 728 true false false false false false true true false false false false X 15 14 false false true false true true true true true false false true true true true true true true false NY X MARY BETH LICHTNEGER 6318788900 72 SOUTH WOODS ROAD woodbury NY 11797 X MARIO P OBERTIS PRESIDENT (THRU 4/16) 1.0 0.0 X X 0 0 0 MSR THOMAS J HARTMAN 1ST VICE PRES. (deceased 2/16) 1.0 0.0 X X 0 0 0 PATRICIA C MONTGOMERIE 2ND VICE PRES. (THRU 4/16) 1.0 0.0 X X 0 0 0 GAIL STADLER 3RD VICE PRES. (THRU 4/16) 1.0 0.0 X X 0 0 0 JOSEPH GRACI TREASURER (THRU 4/16) 1.0 0.0 X X 0 0 0 E CHRISTOPHER MURRAY SECRETARY (THRU 4/16) 1.0 0.0 X X 0 0 0 ELEANORE GORDON BASS DIRECTOR (THRU 4/16) 1.0 0.0 X 0 0 0 PAUL BREUER DIRECTOR (THRU 4/16) 1.0 0.0 X 0 0 0 KENNETH R BUSH DIRECTOR (THRU 4/16) 1.0 0.0 X 0 0 0 LOUIS F CASSARA DIRECTOR (THRU 4/16) 1.0 0.0 X 0 0 0 DAVID F CHINTZ DIRECTOR (THRU 4/16) 1.0 0.0 X 0 0 0 STEVEN A MALITO DIRECTOR (THRU 4/16) 1.0 0.0 X 0 0 0 KATHLEEN PISANI DIRECTOR (THRU 4/16) 1.0 0.0 X 0 0 0 HONORABLE PAUL PONTIERI PRESIDENT (AS OF 4/16) 2.0 0.0 X X 0 0 0 CHRIS MCCANN VICE PRESIDENT (AS OF 4/16) 2.0 0.0 X X 0 0 0 DR JOSEPH MORRIS SECRETARY (AS OF 4/16) 2.0 0.0 X X 0 0 0 JANET FERNANDEZ TREASURER (AS OF 4/16) 2.0 0.0 X X 0 0 0 BRIAN BOYLE TRUSTEE (AS OF 4/16) 2.0 0.0 X 0 0 0 THOMAS CULLEN TRUSTEE (AS OF 4/16) 2.0 0.0 X 0 0 0 KEVIN DWYER TRUSTEE (AS OF 4/16) 2.0 0.0 X 0 0 0 JOHN FALLON TRUSTEE (AS OF 4/16) 2.0 0.0 X 0 0 0 NELLA HAHN TRUSTEE (AS OF 4/16) 2.0 0.0 X 0 0 0 DONNA LODUCA TRUSTEE (AS OF 4/16) 2.0 0.0 X 0 0 0 DR GEORGE RUGGIERO TRUSTEE (AS Of 4/16) 2.0 0.0 X 0 0 0 MICHAEL SIMONSON TRUSTEE (AS OF 4/16) 2.0 0.0 X 0 0 0 BERNADETTE ZIMMERMANN TRUSTEE (AS OF 4/16) 2.0 0.0 X 0 0 0 JAY ZUCKERMAN TRUSTEE (AS OF 4/16) 2.0 0.0 X 0 0 0 MICHELE KNAPP TRUSTEE (AS OF 4/16) 2.0 0.0 X 0 0 0 ROBERT DELVECCHIO TRUSTEE (FROM 4/16 THRU 11/16) 2.0 0.0 X 0 0 0 NICK BOBA CHIEF EXECUTIVE DIRECTOR 35.0 1.0 X 250873 0 26368 WALTER STOCKTON CEO 0.5 39.5 X 0 1100699 38611 MARY BETH LICHTNEGER CFO 1.0 39.0 X 0 239599 40473 DEBORAH PATEY DIRECTOR OF DEVELOPMENT 35.0 0.0 X 129776 0 11087 SHARON THOMPSON DIRECTOR OF QA (THRU 8/16) 35.0 0.0 X 104232 0 6664 VICTORIA PREW DIRECTOR, HUMAN RESOURCES 35.0 0.0 X 114738 0 10716 JEANINE STUTZ DIRECTOR OF CHILDREN DAY SVCS 35.0 0.0 X 100404 0 19869 700023 1340298 153788 5 false true false RIDES UNLIMITED OF NY 191 SWEET HOLLOW RD OLD BETHPAGE NY 11804 TRANSPORTATION 626725 TEAM OCCUPATIONAL THERAPY PC 342 SOUNDVIEW DR ROCKY POINT NY 11778 THERAPISTS 209484 XYZ CLEANING CO 44 NEWTOWN PLAZA PLAINVIEW NY 11803 CLEANING SERVICE 148280 BAKER TILLY VIRCHOW KRAUSE LLP 125 BAYLIS RD MELVILLE NY 11747 AUDITOR 138800 HORIZON HEALTHCARE 20 JERULSALEM AVE 3RD FL HICKSVILLE NY 11801 SPEECH THERAPISTS 126643 6 153615 535071 99489 788175 ADULT RESIDENCE PROGRAM 611600 17899177 17899177 CHILDREN'S DAY PROGRAM 611600 8466882 8466882 ADULT DAY SERVICES DIVISION 611600 6197337 6197337 32563396 5027 5027 0 0 0 0 0 6607 6607 6607 6607 120584 153615 239535 -118951 -118951 29075 7143 21932 21932 0 0 0 MISCELLANEOUS REVENUE 900099 89239 89239 89239 33355425 32563396 3854 0 0 0 0 277241 277241 0 18659934 17852908 807026 95220 89628 5592 0 4725787 4448256 277531 1477405 1390641 86764 0 83091 83091 131981 131981 0 0 0 1202419 890127 312292 7798 2167 5631 246949 185135 61814 0 0 513166 492718 20448 740675 729804 10871 0 7986 2950 5036 299364 257748 41616 0 831967 818243 13724 355321 219200 136121 HOUSEHOLD AND PROGRAM SUPPLIES 889840 863260 26580 NYS RECOUPMENT 550478 550478 REPAIRS AND MAINTENANCE 513684 497351 16333 EQUIPMENT LEASE 245795 229602 16193 827503 507328 320175 32683604 30027544 2656060 0 1642742 1637523 200904 690514 137885 52318 3578606 4255590 0 0 0 0 0 0 0 0 65351 123537 23828786 13743582 10407500 10085204 92075 117692 0 0 0 0 0 0 2971632 133764 19096695 17096142 3062064 3116225 0 0 4078862 4415604 5743000 3503569 88944 92611 0 0 1883443 2757910 0 0 3084127 1356530 17940440 15242449 X 871046 1764185 285209 89508 0 0 1156255 1853693 19096695 17096142 671821 25617 X false true X true false X RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED true 88944 112966 109299 92611 false X 1545040 1545040 14883400 9123002 5760398 5828460 3790890 2037570 630171 365976 264195 941715 463714 478001 10085204 0 DUE TO GOVERNMENTAL AGENCY 849214 DUE TO AFFILIATES 507316 1356530 X PART IV, LINE 2B THE FUNDS BELONG TO THE RESIDENTS IN THE GROUP HOMES AND THE ORGANIZATION HOLDS THE FUNDS ON THEIR BEHALF. PART X, LINE 2 The Organization follows guidance that clarifies the accounting for uncertainty in tax positions taken or expected to be taken in a tax return, including issues relating to financial statement recognition and measurement. This guidance provides that the tax effects from an uncertain tax position can only be recognized in the financial statements if the position is "more likely than not" to be sustained if the position were to be challenged by a taxing authority. The assessment of the tax position is based solely on the technical merits of the position, without regard to the likelihood that the tax position may be challenged. The Organization is exempt from federal income tax under IRC Section 501(c)(3), though it is subject to tax on income unrelated to its exempt purpose, unless that income is otherwise excluded by the Code. The Organization has processes presently in place to ensure the maintenance of its tax-exempt status, to identify and report unrelated income; to determine its filing and tax obligations in jurisdictions for which it has nexus; and to identify and evaluate other matters that may be considered tax positions. The Organization has determined that there are no material uncertain tax positions that require recognition or disclosure in the combined financial statements for the year ending December 31, 2016. true true true true true true true false false false false false false false false true false true SCHEDULE E, PART 1, LINE 3 The Center publishes its non-discriminatory policy in all publications, brochures and advertisements shared with the public. SCHEDULE E, PART I, LINE 6 The Center for Developmental Disabilities, Inc. receives governmental funding from the New York State Office for People with Developmental Disabilities; this represents the largest part of its governmental funding. In addition, the Center receives funding from a variety of school districts (instrumentalities of governmental entities). This funding enables the Center provide much needed support to assist in the education of developmentally disabled individuals. The following Long Island school districts supported the Center in calendar year 2016. Amityville Brentwood Carle Place East Meadow East Islip East Northport Garden City Great Neck Harborfields Hempstead Herricks Hicksville Lawrence Levittown Lindenhurst Massapequa Mineola New Hyde Park New York City North Shore North Babylon Plainview-Old Bethpage Rockville Centre Seaford Sewanhaka Smithtown South Huntington Syosset Three Village Valley Stream Wantagh golf event 171675 98745 72930 37521 93774 dinner dance 99510 51856 47654 16188 91382 2 3014 3014 670 274199 153615 120584 53709 185826 239535 -118951 29075 7143 29075 7143 7143 21932 NY true false false false 0.00000 1.00000 DEBBIE PATEY 72 SOUTH WOODS ROAD WOODBURY NY 11797 false Debbie Patey Development Director Supervision/Oversight of Gaming Activities X false Form 990, Schedule G - Gaming Manager The Center does not have an employee designated to the role of Gaming Manager. The Development Director, Debbie Patey, oversees the organization's gaming activities but does so as part of her overall job rresponsibilites. She is not separately compensated for this role and thus no compensation has been reported in Schedule G. X X X X X false false false false false false false false false NICK BOBA CHIEF EXECUTIVE DIRECTOR 246921 0 0 0 3952 0 1246 0 25122 0 277241 0 0 0 WALTER STOCKTON CEO 0 320754 0 25540 0 754405 0 20417 0 18194 0 1139310 0 685439 MARY BETH LICHTNEGER CFO 0 181359 0 27083 0 31157 0 13044 0 27429 0 280072 0 0 0 Janet Fernandez Board Member 162224 See Schedule L, Part V false Form 990, Schedule L, Part IV Transactions The Spouse of Board of Trustees Member, Janet Fernandez, is a partner in a financial consulting firm that provides fiscal consulting services to IGHL (to help negotiate rates with New York State). In calendar year 2016, IGHL paid $352,137 in consulting fees to this firm. The fees paid represent amounts that IGHL paid both for itself ($189,913) and for related party, the Center for Developmental Disabilities ($162,224). IGHL was reimbured by the related party for its share of these fees. The Services that IGHL and CDD received were for rate analysis and management consultation for OPWDD and SED programs, as well as work related to executive and management compensation. In 2016, the firm was also engaged to perform consulting services related to mergers and program acquisitions, including the due diligence work for the IGHL/CDD acquisition (via a Member Substitution Agreement). These services, as well as other one-time only non-recurring services provided to both companies, accounted for approximately $155,898 of the fees paid in calendar year 2016. FORM 990, PART VI, SECTION A, LINE 4 In April of 2016, The Center for Developmental Disabilities was acquired by the Independent Group Home Living Program. As a result of that acquisition, the organizations bylaws were amended to reflect that Independent Group Home Living Program is the Centers sole corporate member and has certain powers reserved to it as the sole corporate member (see below narrative to Form 990, Part VI, Lines 7a and 7b). FORM 990, PART VI, SECTION A, LINE 6 The Center for Developmental Disabilities sole corporate member is its parent organization, the Independent Group Home Living Program. FORM 990, PART VI, SECTION A, LINE 7A PURSUANT TO THE CDD'S BYLAWS, THE SOLE CORPORATE MEMBER, INDEPENDENT GROUP HOME LIVING PROGRAM, HAS THE SOLE POWER TO APPOINT AND/OR REMOVE ALL OF THE CDD'S BOARD OF DIRECTORS. FORM 990, PART VI, SECTION A, LINE 7B PURSUANT TO THE CDD'S BYLAWS, THE SOLE CORPORATE MEMBER, INDEPENDENT GROUP HOME LIVING PROGRAM, IS RESERVED THE POWER TO: - CHANGE CDD'S CHARITABLE MISSION. - AMEND THE BYLAWS AND ARTICLES OF INCORPORATION. - APPROVE ANY TRANSACTION PROVIDING FOR THE SALE, MORTGAGE OF DISPOSITION OF CDD ASSETS. - APPROVE ANY CAPITAL EXPENDITURE OF $100K OR MORE. - APPROVE ANY BORROWING OR OTHER INCURRENCE OF DEBT. - APPROVE STRATEGIC PLANS. - SET BUDGETS. - APPOINT A CEO OF THE CORPORATION. - ADOPT A PLAN OF DISSOLUTION. FORM 990, PART VI, SECTION B, LINE 11 THE FORM 990 WAS PREPARED BY AN INDEPENDENT ACCOUNTING FIRM IN CONJUNCTION WITH THE ORGANIZATION'S FINANCIAL DEPARTMENT. A COPY OF THE DRAFT FORM 990 WAS CIRCULATED TO THE FULL BOARD OF TRUSTEES IN EITHER PAPER OR ELECTRONIC FORM FOR DISCUSSION AND COMMENT. EACH BOARD MEMBER WAS PROVIDED AMPLE OPPORTUNITY TO COMMENT ON THE INFORMATION CONTAINED IN THE 990 PRIOR TO ITS FILING WITH THE INTERNAL REVENUE SERVICE. FORM 990, PART VI, SECTION B, LINE 12C THE POLICY AND ANNUAL DISCLOSURE FORMS ARE DISTRIBUTED TO ALL BOARD MEMBERS, OFFICERS AND MANAGEMENT STAFF. EACH INDIVIDUAL IS REQUIRED TO SIGN AND REVIEW THE DISCLOSURE FORM AND PROVIDE INFORMATION ABOUT ANY RELATIONSHIPS THEY MAY HAVE WITH CDD, OTHER EMPLOYEES, AND/OR VENDORS THAT CONDUCT BUSINESS WITH CDD. ALL SUBMISSIONS ARE REVIEWED BY HUMAN RESOURCES TO DETERMINE IF A CONFLICT EXISTS; WHEN A CONFLICT ARISES, THE INDIVIDUALS AFFECTED ARE PROHIBITED FROM PARTICIPATING IN THE DECISION-MAKING PROCESS RELATED TO ANY TRANSACTION OCCURRING WITH THE CONFLICTED ORGANIZATION. FORM 990, PART VI, SECTION B, LINE 15A Since CDD was acquired by the Independent Group Home Living Program, it now abides by that organization's internal policies and procedures, including its compensation procedures. IGHL UNDERTAKES A THOROUGH PROCESS TO ENSURE THAT THE COMPENSATION IT PAYS TO ITS OFFICERS IS COMMENSURATE WITH COMPENSATION PAID BY OTHER ENTITIES IN THE SAME INDUSTRY. THE ORGANIZATION USES AN OUTSIDE INDEPENDENT ACCOUNTING FIRM WITH EXPERTISE IN THE NOT-FOR-PROFIT INDUSTRY TO PERFORM COMPENSATION ANALYSES FOR ITS CORPORATE OFFICERS. THE COMPENSATION ANALYSES INCLUDE COMPENSATION SURVEYS FOR EACH POSITION BASED UPON THE COMPENSATION AND FRINGE BENEFITS REPORTED ON THE IRS 990 TAX RETURNS FOR COMPARABLE AGENCIES IN THE INDUSTRY. THE RESULTS OF THESE COMPENSATION ANALYSES ARE PRESENTED TO THE BOARD OF DIRECTORS, WHO REVIEW THE ANALYSES TO DETERMINE APPROPRIATE COMPENSATION LEVELS AND ENSURE COMPLIANCE WITH THE DUE DILIGENCE GUIDELINES AS OUTLINED IN IRC 4958. THE BASIS FOR ITS DETERMINATION AND ALL DECISIONS MADE ARE CONTEMPORANEOUSLY DOCUMENTED IN MEETING MINUTES. THE ORGANIZATION COMMISSIONS AN INDEPENDENT COMPENSATION STUDY EVERY YEAR; THE LAST SURVEY WAS COMPLETED IN 2016. THE ORGANIZATION COMMISSIONS AN INDEPENDENT COMPENSATION STUDY EVERY YEAR; THE LAST SURVEY WAS COMPLETED IN 2016. FORM 990, PART VI, SECTION C, LINE 19 CDD makes its form 990 available to the public by retaining a copy at its place of business and on its website, www.CENTERFORDD.org. The form 990 is likewise published on the internet at www.guidestar.org. The ORGANIZATION financial statements are made available in its annual report and on its website. The ORGANIZATION's governing documents and conflict of interest policy are not ordinarily made available to the public, but, if requested, will be provided at management's discretion. 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