2012-03-30T08:09:42-05:00 2011-03-31 PLANTE & MORAN PLLC 600 E FRONT STREET SUITE 300 TRAVERSE CITY MI 49686 990 2010-04-01 381459366 CHARLEVOIX AREA HOSPITAL CHAR 2315474024 14700 LAKESHORE DRIVE CHARLEVOIX MI 49720 WILLIAM JACKSON 2315474024 2012-03-29 1 2319477800 2010 2016-02-24 21:20:13Z WILLIAM JACKSON 14700 LAKESHORE DRIVE CHARLEVOIX MI 49720 35768104 0 X WWW.CAH.ORG X 1919 MI PROVIDE HEALTHCARE TO THE RESIDENTS OF CHARLEVOIX AND NORTHERN ANTRIM COUNTIES. 14 12 350 72 202107 36772 231547 391054 31448335 34048433 2191088 143210 116985 68546 33987955 34651243 14129 0 0 0 19208506 19028228 0 0 47429 13562763 15058132 32785398 34086360 1202557 564883 27657672 27826701 9659203 9218503 17998469 18608198 X DEPEND ON US FOR EXCELLENT HEALTH CARE 0 0 6409226 4730310 PHYSICIAN OFFICES 5030183 11121156 OPERATING ROOM SERVICES - SURGERIES: 2,424 3690543 2450043 ROUTINE INPATIENT - DAYS OF CARE: 3,157 13896317 15480680 OUTPATIENT CARE, DIAGNOSTIC AND LABORATORY SERVICES, EMERGENCY ROOM SERVICES, AND OTHER GENERAL HEALTHCARE SERVICES. PATIENTS SEEN IN THE EMERGENCY ROOM TOTAL 11,600. 13896317 15480680 29026269 1 1 0 1 0 0 0 0 0 1 1 0 0 1 0 0 1 0 0 0 0 0 0 0 0 1 1 0 0 1 0 0 0 0 0 1 0 0 0 0 0 0 0 1 1 1 0 0 1 43 0 1 350 1 1 1 0 0 0 0 0 0 0 0 0 X 14 12 0 0 0 0 0 0 0 1 1 0 0 0 1 1 1 1 1 1 0 0 X TABITHA RUDOLPH 2315478508 14700 LAKE SHORE DRIVE CHARLEVOIX MI 49720 STEVE HUFFORD OD 1.00 X X 0 0 0 SCOTT BEATTY 1.00 X X 0 0 0 MARY JASON 1.00 X X 0 0 0 RICHARD FISH DDS 1.00 X 0 0 0 MARC LAME MD 1.00 X 0 0 0 REBECCA HANEY 1.00 X 0 0 0 HAROLD NORM PERKINS 1.00 X 0 0 0 STEVE WEBER 1.00 X X 0 0 0 MARK GROENINK 1.00 X 0 0 0 WILLIAM JACKSON 40.00 X X 154139 0 20956 MELODIE BROWN MD 1.00 X 0 0 0 RICHARD KRUEGER 1.00 X 0 0 0 JOHN KURTZ 1.00 X 0 0 0 CHRIS UNBEHAUN 1.00 X 0 0 0 MICHAEL ORTWINE 1.00 X 0 0 0 MARILYN DUMBAULD 1.00 X 0 0 0 KATHY WEBER 1.00 X 0 0 0 JOSEPH SCHODDE 40.00 X 109071 0 19362 JAMES JEAKLE MD 40.00 X 303245 0 22040 RODERIC TINNEY MD 40.00 X 230525 0 19040 MARY IVEY MD 40.00 X 343425 0 18621 WILLIAM MOSHER III MD 40.00 X 218198 0 9519 BRIAN DISHINGER MD 40.00 X 336220 0 17185 GERALYN DOSKOCH MD 40.00 X 121340 0 16222 1816163 0 142945 21 1 1 0 PINE RIVER MEDICAL ASSOCIATES 14734 PARK AVENUE CHARLEVOIX MI 49720 ER PHYSICIAN COVERAGE 1300687 FLOYD & TODD WRIGHT BUILDERS INC 216 RAY STREET BOYNE CITY MI 49712 CONSTRUCTION SERVICES 184374 QUEST DIAGNOSTICS 4444 GIDDINGS ROAD AUBURN HILLS MI 48326 LABORATORY SERVICES 171616 MICHIGAN NEUROLOGY ASSOCIATES 1500 WEST PARK DRIVE SUITE 390 WESTBOROUGH MA 01581 MOBILE MRI SERVICES 141300 MUNSON SUPPORT SERVICES 1105 SIXTH STREET TRAVERSE CITY MI 49685 LAUNDRY SERVICES 108007 6 344985 45069 1000 11398 391054 HEALTH SERVICES 622110 27020725 26818618 202107 OTHER RELATED REVENUE 622110 7027708 7027708 34048433 103259 103259 151667 215804 -64137 -64137 -64137 937708 3300 901057 36651 3300 39951 39951 CAFETERIA SALES 722210 132683 132683 132683 34651243 33782189 202107 275893 315006 315006 15035766 13045272 1953047 37447 259219 215287 43595 337 2400352 2061457 335425 3470 1017885 859779 155294 2812 17559 17559 78810 78810 2542103 2223632 318309 162 147023 147023 80172 52983 27189 122644 122644 81882 65523 16359 317065 258019 58642 404 2004033 1601527 399755 2751 277123 277123 SUPPLIES 4409768 4069054 340669 45 NORTHERN HEALTH PLAN 1282260 1282260 PROVISION FOR BAD DEBTS 821461 821461 UTILITIES 707463 707463 QAAP TAX 591388 591388 1577378 1171164 406213 1 34086360 29026269 5012662 47429 38222 114692 2700727 1497058 45429 33597 2455563 3149189 7000 396747 482447 640179 642669 498002 567894 44869270 28127427 16422382 16741843 2612066 2430012 1337969 1672938 503386 494362 27657672 27826701 2472189 2620093 5631016 4890396 1172998 1357011 383000 351003 9659203 9218503 X 16970320 17350568 1028149 1257630 17998469 18608198 27657672 27826701 X 564883 44846 X X 0 1 1 X 0 X RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED 0 0 0 0 0 0 0 0 1 4116 4116 0 EXPLANATION OF OTHER LOBBYING ACTIVITIES: PART II-B, LINE 1I: PORTION OF ANNUAL DUES TO MICHIGAN HEALTH & HOSPITAL ASSOCIATION AND AMERICAN HOSPITAL ASSOCIATION THAT ARE USED TOWARD LOBBYING ACTIVITIES. 898861 898861 28901182 16678444 12222738 13914542 11448983 2465559 1154685 1154685 16741843 INVESTMENT IN CHARLEVOIX NURSING HOME 729740 F INVESTMENT IN CHARLEVOIX FOUNDATION 943198 F 1672938 COST REPORT SETTLEMENT PAYABLE 351003 351003 1 1 X 1 X 1 X 1 1 0 1 1 513563 419725 93838 0.00280 4128162 2278166 1849996 0.05560 4641725 2697891 1943834 0.05840 100435 3873 96562 0.00290 100435 3873 96562 0.00290 4742160 2701764 2040396 0.06130 0 588280 146316 9448181 9362388 85793 X 1 1 1 1 CHARLEVOIX AREA HOSPITAL

14700 LAKE SHORE DRIVE CHARLEVOIX MI 49720

X X X NOT REQUIRED 1 6 BOYNE AREA MEDICAL CENTER

223 N PARK BOYNE CITY MI 49712

OUTPATIENT PHYSICIAN OFFICE CHARLEVOIX WOMEN'S HEALTH CARE

14651 W UPRIGHT STREET CHARLEVOIX MI 49720

OUTPATIENT PHYSICIAN OFFICE BOYNE REHABILITATION CENTER

197 STATE STREET BOYNE CITY MI 49712

REHABILITATION CLINIC JORDAN VALLEY REHABILITATION CENTER

100 MAIN STREET EAST JORDAN MI 49727

REHABILITATION CLINIC CHARLEVOIX SURGEONS

14695 PARK AVENUE CHARLEVOIX MI 49720

OUTPATIENT PHYSICIAN OFFICE PHYSICIAN CLINIC OF CHARLEVOIX

14705 W UPRIGHT STREET CHARLEVOIX MI 49720

OUTPATIENT PHYSICIAN OFFICE PART I, LINE 3C: IN ADDITION TO USE OF THE FEDERAL POVERTY GUIDELINES, PATIENTS MUST ALSO SATISFY AN ASSET TEST LIMIT OF $62,000. FURTHERMORE, TOTAL MEDICAL DEBT WILL BE CONSIDERED ON A CASE BY CASE BASIS AS AN ADDITIONAL ELEMENT IN DETERMINING THE AMOUNT OF FINANCIAL ASSISTANCE. PART I, LINE 6A: N/A PART I, LINE 7: A COST TO CHARGE RATIO, DERIVED FROM WORKSHEET 2, IS USED. PART I, LINE 7G: THE HOSPITAL DID NOT REPORT SUBSIDIZED HEALTH SERVICES. PART I, L7 COL(F): THE BAD DEBT EXPENSE INCLUDED ON FORM 990, PART IX, LINE 24C - BUT SUBTRACTED FOR PURPOSES OF CALCULATING THIS SCHEDULE H, PART I, COLUMN F PERCENTAGE EQUALS $821,461. PART II: N/A - THE HOSPITAL DID NOT LIST ANY COMMUNITY BUILDING ACTIVITIES ON SCHEDULE H. PART III, LINE 4: ACCOUNTS RECEIVABLE FINANCIAL STATEMENT FOOTNOTE:AN ALLOWANCE FOR UNCOLLECTIBLE ACCOUNTS IS ESTABLISHED ON AN AGGREGATE BASIS BY USING HISTORICAL WRITE-OFF RATE FACTORS APPLIED TO UNPAID ACCOUNTS BASED ON AGING. LOSS RATE FACTORS ARE BASED ON HISTORICAL LOSS EXPERIENCE AND ADJUSTED FOR ECONOMIC CONDITIONS AND OTHER TRENDS AFFECTING THE HOSPITAL'S ABILITY TO COLLECT OUTSTANDING AMOUNTS. UNCOLLECTIBLE AMOUNTS ARE WRITTEN OFF AGAINST THE ALLOWANCE FOR DOUBTFUL ACCOUNTS IN THE PERIOD THEY ARE DETERMINED TO BE UNCOLLECTIBLE. AN ALLOWANCE FOR CONTRACTUAL ADJUSTMENTS AND INTERIM PAYMENT ADVANCES IS BASED ON EXPECTED PAYMENT RATES FROM PAYORS BASED ON CURRENT REIMBURSEMENT METHODOLOGIES. THIS AMOUNT ALSO INCLUDES AMOUNTS RECEIVED AS INTERIM PAYMENTS AGAINST UNPAID CLAIMS BY CERTAIN PAYORS.THE RATIO OF PATIENT CARE COST TO CHARGES IS APPLIED TO BAD DEBT EXPENSE, NET OF RECOVERIES, TO ARRIVE AT THE ESTIMATED COST OF BAD DEBT $588,280.THE HOSPITAL PROVIDES CARE TO ALL INDIVIDUALS REGARDLESS OF THEIR ABILITY TO PAY. WHILE THE HOSPITAL MAKES EVERY EFFORT TO IDENTIFY ALL CANDIDATES WHO WOULD QUALIFY UNDER ITS FINANCIAL ASSISTANCE POLICY, THERE ARE CIRCUMSTANCES UNDER WHICH THAT DETERMINATION CANNOT BE MADE. AS SUCH, IT IS OUR BELIEF THAT $146,316 OF BAD DEBT IS ESTIMATED TO BE ATTRIBUTABLE TO PATIENTS ELIGIBLE UNDER THE HOSPITAL'S CHARITY CARE POLICY AND SHOULD BE INCLUDED AS COMMUNITY BENEFIT. BASED ON AN ANALYSIS OF SELF PAY ENCOUNTERS WHOSE GROSS CHARGES EXCEEDED $1,000 AND THEREFORE WERE AUTOMATICALLY SENT A FINANCIAL ASSISTANCE APPLICATION, IT WAS DETERMINED THAT APPROXIMATELY 46% QUALIFIED FOR FINANCIAL ASSISTANCE. THIS PERCENTAGE WAS THEN APPLIED TO TOTAL SELF PAY BAD DEBT AND THEN CONVERTED TO COST THROUGH APPLICATION OF THE RATIO OF PATIENT CARE COST TO CHARGES. PART III, LINE 8: THE AMOUNTS REPORTED FOR MEDICARE ARE FROM THE MEDICARE COST REPORT, WHICH DO NOT SHOW A SHORTFALL. THIS IS BASED ON THE METHODOLOGY REQUIRED FOR COMPLETING THE MEDICARE COST REPORT. PART III, LINE 9B: THE HOSPITAL DOES NOT PURSUE COLLECTION OF AMOUNTS FROM PATIENTS DETERMINED TO QUALIFY FOR FINANCIAL ASSISTANCE. PART VI, LINE 2: CHARLEVOIX AREA HOSPITAL HAS PARTICIPATED IN NEEDS ASSESSMENT SURVEYS CONSISTENTLY DURING THE PAST 10 YEARS, TYPICALLY IN COOPERATION WITH OTHER ORGANIZATIONS BUT AT TIMES SPECIFICALLY DRIVEN BY OUR HOSPITAL. IN ADDITION TO DATA PROCURED THROUGH THESE SURVEYS, OUR HOSPITAL HAS ALSO USED MICHIGAN DEPARTMENT OF COMMUNITY HEALTH HEALTH DATA, STATE OF MICHIGAN CENSUS DATA, AND DATA FROM THE ECONOMIC DEVELOPMENT COUNCIL TO ASSESS THE ONGOING HEALTHCARE NEEDS OF OUR COMMUNITY. THE SURVEYS HAVE RESULTED IN MANY JOINT EFFORTS TO ADDRESS OUR COMMUNITY'S HEALTH CARE NEEDS (FLU CLINICS IN COOPERATION WITH LOCAL MDCH, GRANT PROCUREMENT FOR PACS AND DIGITAL MAMMOGRAPHY, AND FITKIDS). ADDITIONALLY, THE HOSPITAL HAS SOLELY SPONSORED WELLNESS WEDNESDAY'S, FREE MAMMOGRAPHY, AND SPORTS PHYSICALS FOR STUDENT ATHLETES. PART VI, LINE 3: INFORMATION REGARDING THE AVAILABILITY OF FINANCIAL ASSISTANCE IS POSTED IN THE HOSPITAL'S ADMISSIONS AREAS. IF, DURING THE REGISTRATION PROCESS, IT BECOMES APPARENT THAT A PATIENT HAS NEED FOR POSSIBLE FINANCIAL OR DISCOUNTED ASSISTANCE, A REFERRAL IS MADE TO THE HOSPITAL'S FINANCIAL COUNSELOR OR SOCIAL WORKER. DURING THIS ASSESSMENT, ELIGIBILITY FOR ASSISTANCE UNDER EXISTING FEDERAL, STATE OR LOCAL GOVERNMENT PROGRAMS IS FIRST EXPLORED. SHOULD THE PATIENT FAIL TO QUALIFY FOR EXISTING PROGRAMS, THE HOSPITAL'S FINANCIAL ASSISTANCE APPLICATION IS MADE AVAILABLE. IN THE EVENT THE PATIENT'S NEED IS NOT IDENTIFIED DURING REGISTRATION, ADDITIONAL OPPORTUNITIES TO INQUIRE ABOUT FINANCIAL ASSISTANCE ARE MADE AVAILABLE. FOR EXAMPLE, THE PHONE NUMBER FOR INQUIRIES INTO FINANCIAL ASSISTANCE ARE PRINTED ON ANY STATEMENTS SENT TO THE PATIENT. FURTHERMORE, PATIENTS WHO DO NOT HAVE INSURANCE COVERAGE AND HAVE AN ENCOUNTER BALANCE THAT EXCEEDS $1,000 ARE AUTOMATICALLY SENT AN APPLICATION. PART VI, LINE 4: CHARLEVOIX AREA HOSPITAL SERVES THE RESIDENTS OF CHARLEVOIX AND NORTHERN ANTRIM COUNTIES, AS WELL AS THE SEASONAL RESIDENTS THAT FLOOD THE AREA DURING THE SUMMER MONTHS. THIS SMALL, RURAL COMMUNITY IS HOME TO APPROXIMATELY 26,000 RESIDENTS, WITH A PER CAPITA INCOME OF APPROXIMATELY $40,000. BASED ON 2008 ESTIMATES, 11.2% OF THE POPULATION HAD INCOMES BELOW THE POVERTY LEVEL. SIMILARLY, MEDICAID RECIPIENTS ACCOUNTED FOR APPROXIMATELY 12% OF THE HOSPITAL'S GROSS PATIENT CHARGES. IN ADDITION, PATIENTS REFERRED FROM NEIGHBORING EAST JORDAN FAMILY HEALTH CENTER, A FEDERALLY QUALIFIED RURAL HEALTH CLINIC, WERE AMONG THOSE SERVED BY THE HOSPITAL. PART VI, LINE 6: THE BOARD OF DIRECTORS IS COMPRISED OF MEDICAL AND BUSINESS PROFESSIONALS, ALMOST ALL OF WHOM RESIDE IN THE HOSPITAL'S PRIMARY SERVICE AREA. THIS VOLUNTARY BOARD PROVIDES COUNTLESS HOURS OF SERVICE TO THE HOSPITAL IN THEIR OVERSIGHT ROLE. THEY ARE INVOLVED IN THE COMMUNITY NEEDS ASSESSMENT PROCESS, IN FUNDRAISING, AND IN GENERAL STEWARDSHIP. PART VI, LINE 7: N/A - THE HOSPITAL IS NOT PART OF AN AFFILIATED HEALTH CARE SYSTEM. REPORTS FILED WITH STATES PART VI, LINE 7 MI X X 0 0 0 1 0 0 0 0 0 WILLIAM JACKSON 147965 0 0 0 6174 0 3092 0 17864 0 175095 0 0 0 JAMES JEAKLE MD 206174 0 96680 0 391 0 4212 0 17828 0 325285 0 0 0 RODERIC TINNEY MD 145302 0 84848 0 375 0 2960 0 16080 0 249565 0 0 0 MARY IVEY MD 209772 0 133352 0 301 0 4212 0 14409 0 362046 0 0 0 WILLIAM MOSHER III MD 210392 0 5244 0 2562 0 4212 0 5307 0 227717 0 0 0 BRIAN DISHINGER MD 299979 0 36000 0 241 0 3008 0 14177 0 353405 0 0 0 GERALYN DOSKOCH MD 118889 0 0 0 2451 0 2403 0 13819 0 137562 0 0 0 PART I, LINE 5 EMPLOYED PHYSICIANS ARE PAID AN INCENTIVE BONUS BASED ON THE GROSS VALUE OF PROFESSIONAL SERVICE CHARGES RENDERED TO ANY AND ALL PATIENTS, REGARDLESS OF THE PATIENTS' ABILITY TO PAY. NET REVENUE COLLECTED ON THE PRO CHARGES IS NOT CONSIDERED WHEN CALCULATING THE INCENTIVE BONUS. ALL INCENTIVE BONUS AGREEMENTS HAVE OVERALL CAPS ON TOTAL COMPENSATION FOR WHICH THE PHYSICIAN IS ELIGIBLE IN A TWELVE MONTH TIME PERIOD. MARC LAME MD CURRENT VOTING BOARD MEMBER OF THE HOSPITAL 129720 RENTAL OF SPACE AND OFFICE STAFF FOR HOSPITAL EMPLOYED SURGEON HOUSED AT THE PRIVATE PHYSICIAN PRACTICE OF MARC LAME, MD ($93,720). RENTAL OF PHYSICIAN OFFICE BUILDING TO MARC LAME BY THE HOSPITAL ($36,000). 0 FORM 990, PART VI, SECTION B, LINE 11 AN INFORMAL REVIEW OF THE 990 IS PERFORMED BY THE ADMINISTRATIVE TEAM AND BY MEMBERS OF THE EXECUTIVE COMMITTEE OF THE BOARD BEFORE THE RETURN IS FILED. THIS REVIEW IS NOT DOCUMENTED. FORM 990, PART VI, SECTION B, LINE 12C ALL INDIVIDUALS SERVING ON THE BOARD ARE REQUIRED TO COMPLETE A CONFLICT OF INTEREST DISCLOSURE STATEMENT AND ARE PERIODICALLY REMINDED OF THEIR OBLIGATION TO REPORT ANY POTENTIAL CONFLICTS OF INTEREST THAT MAY ARISE AS PART OF INTERRELATIONSHIPS RESULTING FROM THEIR PROFESSIONAL CAREERS, THEIR FAMILIES, THEIR PERSONAL ACQUAINTANCES WITH KEY EMPLOYEES OF THE HOSPITAL, AND THEIR DUTIES AS A BOARD MEMBER. MONITORING IS CONDUCTED ON AN ONGOING BASIS, WITH THE EXPECTATION THAT BOARD MEMBERS WILL MEET THEIR AFFIRMATIVE OBLIGATION TO REPORT CONFLICTS OF INTEREST PRIOR TO THE EXECUTION OF BOARD TRANSACTIONS INVOLVING SUCH CONFLICTS. CHARLEVOIX AREA HOSPITAL CONSISTENTLY MONITORS AND ENFORCES COMPLIANCE WITH ITS CONFLICT OF INTEREST POLICY BY DISTRIBUTING AN ANNUAL CONFLICT OF INTEREST QUESTIONNAIRE TO BOARD MEMBERS, EMPLOYED PHYSICIANS, AND KEY EMPLOYEES, WHICH INCLUDES QUESTIONS RELATED TO EACH POLICY PROVISION. RESPONSES ARE THOROUGHLY REVIEWED AND ANY APPARENT CONFLICTS ARE THOROUGHLY INVESTIGATED. IN THE EVENT THAT A POTENTIAL CONFLICT IS IDENTIFIED PRIOR TO ACTION ON A CONTRACT OR TRANSACTION, THE CONFLICTED PERSON IS NOT ALLOWED TO PARTICIPATE IN DISCUSSIONS ON THE MATTER, NOT ALLOWED TO VOTE ON THE MATTER, AND NOT ALLOWED TO BE PRESENT DURING VOTING ON THE MATTER. FORM 990, PART VI, SECTION B, LINE 15A THE HIGHEST PAID EMPLOYEES ARE OUR PHYSICIANS, AND THE MGMA ANNUAL PHYSICIAN COMPENSATION SURVEY IS USED TO DETERMINE THAT SALARIES PAID TO OUR EMPLOYED PHYSICIANS ARE APPROPRIATE. EXECUTIVE COMPENSATION FOR THE CEO IS CHECKED AGAINST REGIONAL COMPENSATION THROUGH THE USE OF A WELL RESPECTED EMPLOYMENT AND RECRUITING FIRM IN MICHIGAN. IT IS ALSO COMPARED TO COMPENSATION DATA PROVIDED BY OUR STATE HOSPITAL ASSOCIATION. THEIR REVIEW IS PERFORMED ANNUALLY BY THE COMPENSATION COMMITTEE OF THE BOARD. THIS REVIEW WAS LAST PERFORMED IN FISCAL YEAR 2009. FORM 990, PART VI, SECTION C, LINE 19 THE ORGANIZATION MAKES ITS GOVERNING DOCUMENTS, CONFLICT OF INTEREST POLICY, AND FINANCIAL STATEMENTS AVAILABLE TO THE PUBLIC UPON REQUEST. CHANGES IN NET ASSETS OR FUND BALANCES: FORM 990, PART XI, LINE 5: NET UNREALIZED GAINS ON INVESTMENTS: 44,846. FORM 990, PART XII, LINE 2C: THE BOARD OF DIRECTORS ASSUMES RESPONSIBILITY FOR OVERSIGHT OF THE FINANCIAL STATEMENT AUDIT. THIS PROCESS HAS NOT CHANGED FROM THE PRIOR YEAR. CHARLEVOIX AREA HOSPITAL FOUNDATION 14700 LAKE SHORE DRIVE CHARLEVOIX MI 49720 753078034 FUNDRAISING MI 501(C)(3) LINE 11A, I CHARLEVOIX AREA HOSPITAL 1 0 0 1 0 0 0 0 0 0 0 0 0 0 1 0 1 0 0 CHARLEVOIX AREA HOSPITAL FOUNDATION C 103672 CASH CHARLEVOIX AREA HOSPITAL FOUNDATION N 41965 FMV - ACTUAL AMOUNTS PAID CHARLEVOIX AREA HOSPITAL FOUNDATION P 60487 FMV - ACTUAL AMOUNTS PAID THIS RETURN IS BEING FILED BETWEEN MARCH 1, 2012 AND MARCH 30, 2012, AS DIRECTED BY THE IRS NOTICE 2012-4, BECAUSE ELECTRONIC FILING WAS NOT AVAILABLE JANUARY 1, 2012 THROUGH FEBRUARY 29, 2012. WE REQUEST THAT PENALTIES BE WAIVED BECAUSE IT WOULD BE INEQUITABLE TO IMPOSE A PENALTY ON US DUE TO THE UNUSUAL CIRCUMSTANCES REQUIRING US TO DELAY THE FILING OF THIS RETURN.