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TIN: 94-1196203
SCHEDULE C
(Form 990)
Department of the Treasury
Internal Revenue Service
Political Campaign and Lobbying Activities
For Organizations Exempt From Income Tax Under section 501(c) and section 527
Complete if the organization is described below.
Attach to Form 990 or Form 990-EZ.
Go to
www.irs.gov/Form990
for instructions and the latest information.
OMB No. 1545-0047
20
21
Open to Public
Inspection
If the organization answered "Yes" on Form 990, Part IV, Line 3, or Form 990-EZ, Part V, line 46 (Political Campaign Activities), then
Section 501(c)(3) organizations: Complete Parts I-A and B. Do not complete Part I-C.
Section 501(c) (other than section 501(c)(3)) organizations: Complete Parts I-A and C below. Do not complete Part I-B.
Section 527 organizations: Complete Part I-A only.
If the organization answered "Yes" on Form 990, Part IV, Line 4, or Form 990-EZ, Part VI, line 47 (Lobbying Activities), then
Section 501(c)(3) organizations that have filed Form 5768 (election under section 501(h)): Complete Part II-A. Do not complete Part II-B.
Section 501(c)(3) organizations that have NOT filed Form 5768 (election under section 501(h)): Complete Part II-B. Do not complete Part II-A.
If the organization answered "Yes" on Form 990, Part IV, Line 5 (Proxy Tax) (see separate instructions) or Form 990-EZ, Part V, line 35c (Proxy Tax) (see separate instructions), then
Section 501(c)(4), (5), or (6) organizations: Complete Part III.
Name of the organization
DIGNITY HEALTH
Employer identification number
94-1196203
Part I-A
Complete if the organization is exempt under section 501(c) or is a section 527 organization.
1
Provide a description of the organization’s direct and indirect political campaign activities in Part IV. See instructions for definition of “political campaign activities."
2
Political campaign activity expenditures. See instructions
....................................................................
$
1,253
3
Volunteer hours for political campaign activities. See instructions
..................................................................
0
Part I-B
Complete if the organization is exempt under section 501(c)(3).
1
Enter the amount of any excise tax incurred by the organization under section 4955
................................
$
125
2
Enter the amount of any excise tax incurred by organization managers under section 4955
.......................
$
3
If the organization incurred a section 4955 tax, did it file Form 4720 for this year?
.........................................
Yes
No
4a
Was a correction made?
......................................................................................................................
Yes
No
b
If "Yes," describe in Part IV.
Part I-C
Complete if the organization is exempt under section 501(c), except section 501(c)(3).
1
Enter the amount directly expended by the filing organization for section 527 exempt function activities
.....
$
2
Enter the amount of the filing organization's funds contributed to other organizations for section 527 exempt function activities
............................................................................................................................
$
3
Total exempt function expenditures. Add lines 1 and 2. Enter here and on Form 1120-POL, line 17b
...........
$
4
Did the filing organization file
Form 1120-POL
for this year?
...................................................................
Yes
No
5
Enter the names, addresses and employer identification number (EIN) of all section 527 political organizations to which the filing
organization made payments. For each organization listed, enter the amount paid from the filing organization’s funds. Also enter the amount of political contributions received that were promptly and directly delivered to a separate political organization, such as a separate segregated fund or a political action committee (PAC). If additional space is needed, provide information in Part IV.
(a)
Name
(b)
Address
(c)
EIN
(d)
Amount paid from filing organization's funds. If none, enter -0-.
(e)
Amount of political contributions received and promptly and directly delivered to a separate political organization. If none, enter -0-.
1
2
3
4
5
6
For Paperwork Reduction Act Notice, see the instructions for Form 990.
Cat. No. 50084S
Schedule C (Form 990) 2021
Schedule C (Form 990) 2021
Page
2
Part II-A
Complete if the organization is exempt under section 501(c)(3) and filed Form 5768 (election under section 501(h)).
A
Check
if the filing organization belongs to an affiliated group (and list in Part IV each affiliated group member's name, address, EIN,
expenses, and share of excess lobbying expenditures).
B
Check
if the filing organization checked box A and "limited control" provisions apply.
Limits on Lobbying Expenditures
(The term "expenditures" means amounts paid or incurred.)
(a)
Filing
organization's
totals
(b)
Affiliated group totals
1a
Total lobbying expenditures to influence public opinion (grass roots lobbying)
......................
b
Total lobbying expenditures to influence a legislative body (direct lobbying)
........................
c
Total lobbying expenditures (add lines 1a and 1b)
............................................................
d
Other exempt purpose expenditures
...............................................................................
e
Total exempt purpose expenditures (add lines 1c and 1d)
..................................................
f
Lobbying nontaxable amount. Enter the amount from the following table in both
columns.
If the amount on line 1e, column (a) or (b) is:
The lobbying nontaxable amount is:
Not over $500,000
20% of the amount on line 1e.
Over $500,000 but not over $1,000,000
$100,000 plus 15% of the excess over $500,000.
Over $1,000,000 but not over $1,500,000
$175,000 plus 10% of the excess over $1,000,000.
Over $1,500,000 but not over $17,000,000
$225,000 plus 5% of the excess over $1,500,000.
Over $17,000,000
$1,000,000.
g
Grassroots nontaxable amount (enter 25% of line 1f)
.................................................
h
Subtract line 1g from line 1a. If zero or less, enter -0-.
................................................
i
Subtract line 1f from line 1c. If zero or less, enter -0-.
................................................
j
If there is an amount other than zero on either line 1h or line 1i, did the organization file Form 4720 reporting
section 4911 tax for this year?
...................................................................................................................
Yes
No
4-Year Averaging Period Under Section 501(h)
(Some organizations that made a section 501(h) election do not have to complete all of the five
columns below. See the separate instructions for lines 2a through 2f.)
Lobbying Expenditures During 4-Year Averaging Period
Calendar year (or fiscal year
beginning in)
(a)
2018
(b)
2019
(c)
2020
(d)
2021
(e)
Total
2a
Lobbying nontaxable amount
b
Lobbying ceiling amount
(150% of line 2a, column(e))
c
Total lobbying expenditures
d
Grassroots nontaxable amount
e
Grassroots ceiling amount
(150% of line 2d, column (e))
f
Grassroots lobbying expenditures
Schedule C (Form 990) 2021
Schedule C (Form 990) 2021
Page
3
Part II-B
Complete if the organization is exempt under section 501(c)(3) and has NOT filed Form 5768 (election under section 501(h)).
For each "Yes" response on lines 1a through 1i below, provide in Part IV a detailed description of the lobbying activity.
(a)
Yes
|
No
(b)
Amount
1
During the year, did the filing organization attempt to influence foreign, national, state or local legislation, including any attempt to influence public opinion on a legislative matter or referendum, through the use of:
a
Volunteers?
...........................................................................................................
Yes
b
Paid staff or management (include compensation in expenses reported on lines 1c through 1i)?
........
Yes
c
Media advertisements?
...................................................................................................
No
d
Mailings to members, legislators, or the public?
.............................................................................
Yes
78,714
e
Publications, or published or broadcast statements?
...........................................................
No
f
Grants to other organizations for lobbying purposes?
..........................................................
Yes
561,408
g
Direct contact with legislators, their staffs, government officials, or a legislative body?
.......................
Yes
447,558
h
Rallies, demonstrations, seminars, conventions, speeches, lectures, or any similar means?
..................
No
i
Other activities?
...................................................................................................................
Yes
231,394
j
Total. Add lines 1c through 1i
....................................................................................................
1,319,074
2a
Did the activities in line 1 cause the organization to be not described in section 501(c)(3)?
.....
No
b
If "Yes," enter the amount of any tax incurred under section 4912
...........................................
c
If "Yes," enter the amount of any tax incurred by organization managers under section 4912
...................
d
If the filing organization incurred a section 4912 tax, did it file Form 4720 for this year?
........................
Part III-A
Complete if the organization is exempt under section 501(c)(4), section 501(c)(5), or section 501(c)(6).
Yes
No
1
Were substantially all (90% or more) dues received nondeductible by members?
...............................................
1
2
Did the organization make only in-house lobbying expenditures of $2,000 or less?
............................................
2
3
Did the organization agree to carry over lobbying and political expenditures from the prior year?
.................................
3
Part III-B
Complete if the organization is exempt under section 501(c)(4), section 501(c)(5), or section 501(c)(6) and if either (a) BOTH Part III-A, lines 1 and 2, are answered "No" OR (b) Part III-A, line 3, is answered “Yes."
1
Dues, assessments and similar amounts from members
......................................................................
1
2
Section 162(e) nondeductible lobbying and political expenditures
(do not include amounts of political expenses for which the section 527(f) tax was paid).
a
Current year
.............................................................................................................................
2a
b
Carryover from last year
............................................................................................................
2b
c
Total
...........................................................................................................................................
2c
3
Aggregate amount reported in section 6033(e)(1)(A) notices of nondeductible section 162(e) dues
.
3
4
If notices were sent and the amount on line 2c exceeds the amount on line 3, what portion of the excess does the organization agree to carryover to the reasonable estimate of nondeductible lobbying and political expenditure next year?
......................................................................................................................
4
5
Taxable amount of lobbying and political expenditures. See Instructions
.........................................
5
Part IV
Supplemental Information
Provide the descriptions required for Part l-A, line 1; Part l-B, line 4; Part l-C, line 5; Part II-A (affiliated group list); Part II-A, lines 1 and 2 (see instructions), and Part ll-B, line 1. Also, complete this part for any additional information.
Return Reference
Explanation
PART I-B, LINE 4A:
DIGNITY HEALTH RECENTLY LEARNED THAT RBR MANAGEMENT LLC, A RELATED LLC IN WHICH DIGNITY HEALTH HAS A 50.1% MEMBER INTEREST, MADE A POLITICAL CONTRIBUTION IN 2021 IN THE AMOUNT OF $1,253. DIGNITY HEALTH HAS POLICIES AND PROCEDURES IN PLACE TO AVOID SUCH TRANSACTIONS, AND ONCE THE ORGANIZATION BECAME AWARE OF THIS SITUATION, DIGNITY HEALTH IMMEDIATELY INSTRUCTED THE LLC TO CEASE MAKING POLITICAL CONTRIBUTIONS. DIGNITY HEALTH WILL CLOSELY MONITOR THIS LLC TO ENSURE FULL COMPLIANCE GOING FORWARD. RBR MANAGEMENT LLC HAS PUT IN PLACE POLICIES TO ENSURE THIS WILL NOT OCCUR AGAIN. IN ADDITION, DIGNITY HEALTH HAS INSTRUCTED RBR MANAGEMENT LLC TO TAKE STEPS TO RECOVER THE EXPENDITURES TO THE EXTENT POSSIBLE. DIGNITY HEALTH IS ALSO PAYING THE EXCISE TAX ON FORM 4720.
PART II-B, LINE 1:
LOBBYING EXPENDITURES PAID BY THE FILING ORGANIZATION FOR ANNUAL MEMBERSHIP DUES AND OTHER SUCH LOBBYING ACTIVITIES REFLECTED ON LINES 1F AND 1I. DIGNITY HEALTH IS A MEMBER OF HEALTHCARE ASSOCIATIONS WHOSE PURPOSES INCLUDE DIRECTING, DEVELOPING, AND AFFECTING PUBLIC POLICY AND LEGISLATION WITH REGARD TO ISSUES AFFECTING HEALTHCARE. THE ORGANIZATION PAID ANNUAL DUES TO THESE ASSOCIATIONS, WHICH MAY BE USED FOR LOBBYING PURPOSES AS REFLECTED ON PART II-B, LINE 1I, OTHER ACTIVITIES. 340B HEALTH $2,466 ALLIANCE OF CATHOLIC HEALTHCARE $66,462 AMERICAN HOSPITAL ASSOCIATION $76,799 CALIFORNIA ASSOCIATION FOR HEALTH SERVICES AT HOME $1,366 CALIFORNIA HOSPICE AND PALLIATIVE CARE ASSOCIATION $2,860 CATHOLIC HEALTH ASSOCIATION OF THE UNITED STATES $59,746 AMERICAN MEDICAL ASSOCIATION $5,374 CALIFORNIA MEDICAL ASSOCIATION $50,000 AMERICAN TRAUMA SOCIETY $1,147 AMERICAN ACADEMY OF FAMILY PHYSICIANS $820 GREATER OXNARD CHAMBER OF COMMERCE $200 THE GREATER LAS VEGAS CHAMBER OF COMMERCE $600 SOCIETY OF THORACIC SURGEONS $1,300 NEVADA HOSPITAL ASSOCIATION $4,863 NATIONAL ASSOCIATION OF EPILEPSY CENTERS $120 LONG BEACH AREA CHAMBER OF COMMERCE $1,137 PRIVATE ESSENTIAL ACCESS COMM HOSP INC AKA PEACH INC $127,500 FERRARI PUBLIC AFFAIRS $56,658 HEALTH SYSTEM ALLIANCE OF ARIZONA $3,886 CASSIDY & ASSOCIATES INC $220,000 AMERICAN ACADEMY OF ORTHOPAEDICS SURGEONS $113 NATIONAL ASSOCIATION OF RURAL HEALTH CLINICS, INC $194 GOODMAN SCHWARTZ LLC $107,250 RBR MANAGEMENT LLC $1,253 AMERICAN OSTEOPATHIC ASSOCIATION $112 AMERICAN SOCIETY OF HEALTH-SYSTEMS PHARMACISTS $281 VARIOUS OTHER ORGANIZATIONS UNDER $100 $296 TOTAL EXPENDITURES PAID TO ORGANIZATIONS $792,803 PART II-B, LINES 1B, 1D AND 1G: THE ORGANIZATION PAID FEES TO OTHER ORGANIZATIONS FOR LOBBYING PURPOSES, PAID COMPENSATION TO STAFF AND MANAGEMENT IN THE PERFORMANCE OF THEIR DUTIES IN ATTEMPTING TO INFLUENCE LEGISLATION, HELD MEETINGS WITH AND CALLED GOVERNMENT OFFICIALS, AND DEVELOPED AND SENT LETTERS. DIGNITY HEALTH ENGAGED IN LETTER-WRITING CAMPAIGNS, COSPONSORSHIP CAMPAIGNS, AND OTHER LOBBYING ACTIVITIES AIMED AT INFLUENCING PUBLIC POLICY. THIS IS DONE PRIMARILY THROUGH EMPLOYED DIVISION-LEVEL ADVOCACY LEADERS WITH LEADERSHIP AND GUIDANCE FROM NATIONAL EMPLOYEES. DRAFT LETTERS WERE PROVIDED ON DIGNITY HEALTH ADVOCACY PRIORITIES; DIVISION-EMPLOYED ADVOCACY LEADERS WERE ABLE TO CREATE THEIR OWN LETTERS AS WELL. DIGNITY HEALTH COMMUNICATES WITH LEADERS OF THE SYSTEM'S HOSPITALS AND HEALTH CARE ORGANIZATIONS ON ADVOCACY ACTIVITIES PRIMARILY THROUGH E-MAIL. MOST COMMUNICATIONS WITH CONGRESS OCCUR THROUGH EMAIL AND PHONE. DIGNITY HEALTH ADVOCACY ACTIVITIES INVOLVED COMMUNICATIONS ON DIGNITY HEALTH ADVOCACY PRIORITIES, INCLUDING ISSUES RELATED TO ACCESS AND COVERAGE FOR ALL, HOSPITAL AND HEALTH PROVIDER REIMBURSEMENT, COVID-19 RELIEF FOR INDIVIDUALS AND HEALTH ENTITIES, AND SOCIAL JUSTICE ISSUES (E.G. ENVIRONMENTAL STEWARDSHIP, HOUSING). CENTRAL TO THE DIGNITY HEALTH MISSION AND VISION IS A COMMITMENT TO ADVOCATE FOR SYSTEMIC CHANGES TO IMPROVE THE HEALTH AND WELL-BEING OF INDIVIDUALS AND COMMUNITIES WITH A SPECIFIC CONCERN FOR PERSONS WHO ARE POOR AND MARGINALIZED. THE DIGNITY HEALTH ADVOCACY ACTIVITIES ARE INEXTRICABLY LINKED TO ITS FUNDAMENTAL GOAL TO BUILD HEALTHIER COMMUNITIES. ONE DIMENSION OF THE DIGNITY HEALTH ADVOCACY PROGRAM FOCUSES ON PUBLIC POLICY ADVOCACY, WHICH INCLUDES ATTENTION TO FEDERAL LEGISLATIVE AND REGULATORY MEASURES, FORMATION OF POSITIONS ON PRIORITY ISSUES, AND POLITICAL ACTIVISM. THE COMMONSPIRIT HEALTH PUBLIC POLICY AGENDA INCLUDES BOTH TRADITIONAL HEALTH CARE POLICIES (E.G., PAYMENT ISSUES, QUALITY AND SAFETY, ETC.) AS WELL AS SOCIAL JUSTICE POLICIES.
Schedule C (Form 990) 2021
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