2013-14 CRCHC Review of Compliance with Legislation LEGISLATION DIRECTLY AFFECTING NOT-FOR-PROFITS IN ONTARIO 1) Accessibility for Ontarians with Disabilities Act Description Applicability to CHCs Compliance The Accessibility for Ontarians with Disabilities Act, 2005 (AODA) provides a way for Ontario to become barrier-free by 2025. AODA callS for the development of standards for accessibility in five key areas of daily living: Customer Service, Information and Communications, Employment, Transportation, and Built Environment. 11 universal standards are to be reflected in organizational policy CRCHC is in full compliance. Submitted 2 mandatory reports to the ministry. Accessibility standards in Place: all staff trained, all policies approved and disseminated Description Applicability to CHCs Compliance Establishes “a comprehensive program of old age pensions and supplementary benefits in Canada”. Regulations require employers to regularly submit statutory employer contributions and employee payroll deductions from employee earnings, and that a record of employment be completed on termination of employment. Covers deductions from employees as per the Income Tax Act as well. Requires corporations to keep records and books of account and every account and voucher (including computer records) to verify payments for 6 years from the end of the year in which they were created. Requires employers to require employed individuals to have a Social Insurance Number within 30 days of turning 18. The Act hold directors of the company jointly and severally liable, together with the corporation, to pay the government the amount and interest thereon and penalties assessed if the corporation fails to deduct or remit appropriate amount. The Ontario Corporations Act also makes board members responsible for default of payment for salaries and benefits. Canada Revenue Agency – Statement of Account as of March 18th. 0$ owing 2) Canada Pension Plan Act File: Legislation Compliance Review for 2012-2013 No employees have been terminated or ceased employment this year. Page 1 of 13 2013-2014 CRHCH Review of Compliance with Legislation 3) Canadian Human Rights Act “The purpose of this Act is to extend the laws in Canada to give effect, within the purview of matters coming within the legislative authority of Parliament, to the principle that all individuals should have an opportunity equal with other individuals to make for themselves the lives that they are able and wish to have and to have their needs accommodated, consistent with their duties and obligations as members of society, without being hindered in or prevented from doing so by discriminatory practices based on race, national or ethnic origin, colour, religion, age, sex, sexual orientation, marital status, family status, disability or conviction for an offence for which a pardon has been granted.” R.S., 1985, c. H-6, s. 2; 1996, c. 14, s. 1; 1998, c. 9, s. 9. Defines discrimination, hate messages, harassment, sexual harassment, retaliation, accommodation of needs, etc. Useful basis for anti-discrimination, antiracism, policies. Policy 4-24 Employment Equity Policy 4-01 Staff Rights Establishes the duty on the part of any person, including professionals providing services to children, to report to the Children’s Aid Society any suspicions that the person might have that a child has suffered physical harm, emotional harm or sexual abuse, or is at risk of suffering physical harm, emotional harm or sexual abuse. Also, a report must be made where a child requires medical treatment and the parent or guardian refuses to give consent to such treatment. Policy 8-11 Reporting Child abuse and neglect Fully Compliant 4) Child and Family Services Act This Act establishes rules for protecting children. Among its provisions is to set out the principles for determining what is in the best interests of a child in need of protection. Fully Compliant 5) Corporations Act The Corporations Act relates to the formation and operation of corporations in Ontario and covers a wide variety of topics such as: how to incorporate, naming corporations, types of corporations, powers of corporations, objects of corporations, reporting requirements, appointment, qualifications and paying of auditors, annual meeting requirements and procedures, content of by-laws, definition, election, duties, qualifications, insuring, of officers and directors, disclosure of (conflict) of interest, classes and appointment of membership, and record keeping. If a not-for-profit is incorporated under the Corporations Act, then its corporate existence is governed by this Act. Part III is about Corporations Without Share Capital (commonly known as non-profits). By-laws – agm requirements, terms of office in place Annual Audit – appt of auditors 2013 Audit complete Board minutes – declaration of conflict of interest Annual meeting e.g. election of officers ** we are awaiting the 2010 not for profit corporations act to be put into effect. See below Page 2 of 13 2013-2014 CRHCH Review of Compliance with Legislation 6) Employer Health Tax Act Sets out the requirements for employers to deduct and remit to the federal government tax on employees’ income. Also, sets out the requirements to register and to maintain registration as charity. Finally, sets out the exemption from income tax, under certain conditions, of non-profit organizations. Administrators and directors of a corporation can be held responsible for statutory deductions (including interest and penalties) not made or deductions collected but not paid to Canada. S. 227. Employer Health Tax Account Summary $0 owing dated April 23, 2014 Board members should be appraised regularly of the organization’s compliance with salary and benefits commitments, and payment of mandatory deductions, as they are ‘jointly and severally’ liable for organizations ability to pay. The management and the board should be familiar with the Act and their respective responsibilities. Human resource policies will draw on requirements of this Act. Policy # 4-13 Performance Management 4-20 Termination of Employment 4-15 Progressive Discipline 4-29 Hours of work/Overtime 4-32 Group Insurance 4-34 Statutory Holidays 4-35 Vacation 4-36 Sick Leave 4-37 Medical Leave 4-38 Pregnancy and Paternal Leave 4-39 Other Leave 2012-2013 Registered Charities Return – Form #3010 submitted Sept 27, 2013 7) Employment Standards Act This Act establishes the basic relationship between employees and employers employed in the jurisdiction of Ontario, and defines many work related terms including: public holiday, regular rate (of pay or wages), regular work day, regular work week, statutory notice, trade union, wages, work week, etc. The Act covers: posting of information concerning rights of employees and obligations of employees. continuity of employment, Payment of wages, record keeping, hours of work and eating periods, overtime pay, minimum wage requirements, public holidays, vacation pay, equal pay for equal work, payment of benefit plans, leaves of absence including pregnancy leave, parental, and emergency leaves, termination, severance, and recall, use of lie detectors, liability of directors. complaint processes, enforcement, penalties, etc. “Directors’ liability for wages 81. (1) The directors of an employer are jointly and severally liable for wages as provided in this Part if, (a) the employer is insolvent, the employee has caused a claim for unpaid wages to be filed with the receiver appointed by a court with respect to the employer or with the employer’s trustee in bankruptcy and the claim has not been paid; (b) an employment standards officer has made an order that the employer is liable for wages, unless the amount set out in the order has been paid or the employer has applied to have it reviewed; (c) an employment standards officer has made an order that a director is liable for wages, unless the amount set out in the order has been paid or the employer or the director has applied to have it reviewed; or (d) the Board has issued, amended or affirmed an order under section 119, the order, as issued, amended or affirmed, requires the employer or the directors to pay wages and the amount set out in the order has not been paid. Page 3 of 13 2013-2014 CRHCH Review of Compliance with Legislation 8) Employment Equity Act The purpose of this Act is to achieve equality in the workplace so that no person shall be denied employment opportunities or benefits for reasons unrelated to ability and, in the fulfilment of that goal, to correct the conditions of disadvantage in employment experienced by women, aboriginal peoples, persons with disabilities and members of visible minorities by giving effect to the principle that employment equity means more than treating persons in the same way but also requires special measures and the accommodation of differences. Defines employment equity and the responsibilities of employers to: “(a) identifying and eliminating employment barriers against persons in designated groups that result from the employer's employment systems, policies and practices that are not authorized by law; and (b) instituting such positive policies and practices and making such reasonable accommodations as will ensure that persons in designated groups achieve a degree of representation in each occupational group in the employer's workforce that reflects their representation in (i) the Canadian workforce, or (ii) those segments of the Canadian workforce that are identifiable by qualification, eligibility or geography and from which the employer may reasonably be expected to draw employees. 4-03 Employment Status 4-24 – Employment Equity 9) Employment Insurance Act Regulations regarding employment insurance, and employers responsibilities. Defines insurable earnings, employment, insured person, qualifying period, record keeping responsibilities, requests for ruling on insurability, appeals process, etc.. Mandatory deduction Canada Revenue Agency – Statement of Account $0 owing March 18, 2014 Page 4 of 13 2013-2014 CRHCH Review of Compliance with Legislation 11) Excellent Care for All Act Description Applicability to CHCs Compliance Required Components: Although the intention was for this to be utilized in hospital setting to begin with, the SE LHIN is requiring for all HSP’s Continuous Quality Improvement (CQI) Committee in place. Meets monthly to review all aspects of quality monitoring and quality care Quality committees, which will report to health care organizations on quality-related issues Annual quality improvement plans, which each health care organization will be required to develop and make public Executive compensation which will be required to be linked to achieving improvement targets set out in the annual quality improvement plan Patient/client/caregiver surveys to assess satisfaction with services Staff surveys to assess satisfaction with employment experience and views about the quality of care provided by the health care organization Have submitted 2 approved Quality Improvement Plans to Health Quality Ontario Monthly quality reports to board Staff and Client surveys completed Declarations of values that will be developed after public consultation by health care organizations that are currently without one. Patient relations process to address patient experience issues and reflect its declaration of values Page 5 of 13 2013-2014 CRHCH Review of Compliance with Legislation 12) Excise Tax Act Portion of this Act sets out the rules for the Goods and Services Tax Portion of this Act sets out the rules for the Goods and Services Tax. The HST will apply in some respect or other to CHCs. While each CHC should consult with its auditor to determine how the HST applies, directors of CHCs should note that they have personal liability in the event that their CHC is required to charge HST for services or goods and remit it to the federal government (for example, if the CHC is a commercial landlord, the rent charged is subject to HST) and fails to do so. 2013-2014 CRCHC Audited Finance Statement to be ratified at Annual General Meeting 13) Commitment to the Future of Medicare Act, 2004 The Commitment to the Future of Medicare Act, 2004, received Royal Assent and became law on June 17, 2004. This Act referred to in the Local Health System Integration Act, 2006 Clinical services policies in place and fully compliant The Act improves publicly-funded health care in the province by: Ensuring that Ontarians get the health care they need, through the establishment of accountability agreements between the ministry and health care providers Strengthening the prohibition of “two-tier” medicine by closing legislative loopholes that allow queue-jumping and extra billing; and Establishing an independent Ontario Health Quality Council to report on our health care system in areas including wait times, so we can determine where improvements are needed and where progress is being made 14) Health Cards and Numbers Control Act Concerns privacy re: health cards, numbers “2. (1) No person shall require the production of another person’s health card or collect or use another person’s health number. Exceptions (2) Despite subsection (1), a person may collect or use another person’s health number for purposes related to the provision of provincially funded health resources to that other person. In addition, a person who provides a provincially funded health resource to a person who has a health card or health number, (a) may require the production of the health card; or Fines and/or imprisonment may be applied to individuals (max. $5,000) and corporations (max $25,000) for inappropriate use of health cards and numbers. No complaints in 2013 8-01 – Statement of Clients Rights Oath of Confidentiality Page 6 of 13 2013-2014 CRHCH Review of Compliance with Legislation (b) may collect or use the health number for purposes related to health administration or planning or health research or epidemiological studies. Exception, prescribed persons (3) Despite subsection (1), a person prescribed by the regulations may collect or use health numbers for purposes related to health administration or planning or health research or epidemiological studies. Exception, professional governing bodies (4) Despite subsection (1), the governing body of a health profession whose members provide provincially funded health resources may collect or use health numbers for purposes related to its duties or powers. 1991, c. 1, s. 2. 15) Health Care Consent Act “1. The purposes of this Act are, (a) to provide rules with respect to consent to treatment that apply consistently in all settings; (b) to facilitate treatment, admission to care facilities, and personal assistance services, for persons lacking the capacity to make decisions about such matters; (c) to enhance the autonomy of persons for whom treatment is proposed, persons for whom admission to a care facility is proposed and persons who are to receive personal assistance services by, (i) allowing those who have been found to be incapable to apply to a tribunal for a review of the finding, (ii) allowing incapable persons to request that a representative of their choice be appointed by the tribunal for the purpose of making decisions on their behalf concerning treatment, admission to a care facility or personal assistance services, and (iii) requiring that wishes with respect to treatment, admission to a care facility or personal assistance services, expressed by persons while capable and after attaining 16 years of age, be adhered to; (d) to promote communication and understanding between health practitioners and their patients or clients; (e) to ensure a significant role for supportive family members when a person lacks the capacity to make a decision about a treatment, admission to a care facility or a personal assistance service; and (f) to permit intervention by the Public Guardian and Trustee only as a last resort in decisions on behalf of incapable persons concerning treatment, admission to a care facility or personal assistance services. 1996, c. 2, Sched. A, s. 1. The Act covers all health care practitioners in Ontario and is lengthy, complex, and continues to evolve. It is based on the principle that everyone has the right to determine what shall be done to their body. Consent can be oral or written, express or implied and to be valid it must be: a) given voluntarily b) given by a patient who has capacity, c) specific to the treatment and to the provider, and d) informed Have client privacy statements posted in public areas Section 11 research Policies Section 7 Client Records 4-26 Conflict of Interest Fully compliant will all existing policies Failure to obtain consent and/or obtaining consent in coercive circumstances can lead to serious consequences for providers (and perhaps to their employers), not the least of which is the possibility of +being sued or criminal charges. Practitioners must be aware of the consent laws and practice accordingly. Centres should have clear protocols on consent and consult a lawyer practicing health law when issues are unclear. Page 7 of 13 2013-2014 CRHCH Review of Compliance with Legislation 16) Human Rights Code This Act is the basis of workplace anti-discrimination policies and related practices, as well as governing discrimination in the provision by CHCs of their services. Establishes a persons right to freedom from discrimination on the basis of race, ancestry, place of origin, colour, ethnic origin, citizenship, creed, sex, sexual orientation, age, marital status, handicap or the receipt of public assistance. Freedom from discrimination covers services, goods, and facilities, accommodation, harassment in accommodation, contracts, employment, harassment in accommodation, vocational associations, harassment because of sex in accommodations, harassment because of sex in workplace, reprisals. This Act is the basis of workplace anti discrimination policies and related actions by employers. 4-24 – Employment Equity 2-20 Anti Discrimination Responsibility for the collection and remittance of income tax applies throughout the organization to the board level. Canada Revenue Agency – Statement of Account $0 owing March 18, 2014 17) Income Tax Act “2. An income tax shall be paid as hereinafter required for each taxation year by every individual, (a) who was resident in Ontario on the last day of the taxation year; or (b) who, not being resident in Ontario on the last day of the taxation year, had income earned in the taxation year in Ontario as defined in section 4. R.S.O. 1990, c. I.2, s. 2.” “Part III,38. (1) Where a corporation has failed to deduct or withhold an amount as required by subsection 153 (1) of the Federal Act, as it applies for the purposes of this Act, or has failed to remit such amount, the directors of the corporation at the time the corporation was required to deduct or withhold the amount, or remit the amount, are jointly and severally liable, together with the corporation, to pay any amount that the corporation is liable to pay under this Act in respect of that amount, including any interest or penalties related thereto. R.S.O. 1990, c. I.2, s. 38 (1). Boards should receive regular reports that the obligations in this area have been met. 18) Local Health System Integration Act (2006) This Act defines the purpose of the establishment of the LHINs, defines “integration” and “HSPs” and requirements of HSPs re: integration. Under the Act, all HSPs must identify opportunities to integrate the services of the local health system for the purpose of providing appropriate, co-ordinated, effective and efficient services, both individually and collectively and notification of integration. The Act does not apply to integration with services and entities not funded by the LHIN. Deemed by SE LHIN to be fully compliant Have submitted two compliance reports to the SELHIN this year Page 8 of 13 2013-2014 CRHCH Review of Compliance with Legislation 19) Not For Profit Corporations Act 2010 Bill C-65 Anticipated to be enacted January 2015 Board committee has revised by-laws 1-D. These are now in place and reflect a single class of membership structure 20) Occupational Health and Safety Act The Act’s purpose is to protect workers against health and safety hazards on the job. To balance the employer's general right to direct the work force and control the production process in the workplace, the Act gives four basic rights to workers: (i) the right to be part of the process of identifying and resolving workplace health and safety concerns. This right is expressed through worker membership on joint health and safety committees, or through worker health and safety representatives; (ii) the right to know about any potential hazards to which they may be exposed. This means the right to be trained and to have information on machinery, equipment, working conditions, processes and hazardous substances. The parts of the Act that implement the Workplace Hazardous Materials Information System (WHMIS) play a role in giving workers the right to know; (iii) the right to refuse work that they believe is dangerous to either their own health and safety or that of another worker. The Act describes the exact process for refusing dangerous work and the responsibilities of the employer in responding to such a refusal; and (iv) the right to stop work that is dangerous to any worker. The Act sets out these circumstances and how the right to stop work can be exercised. Management and, staff should be aware of the provisions of the Act. Board members should be advised when management fails to satisfy the committee’s recommendations. Section 6 Policy and Procedure manual Conduct monthly workplace inspections Terms of reference – OH&S Committee List of OH&S Committee members OH&S Bulletin Board Certified staff reps and management reps in place The Act gives the Minister of Labour power to implement the conditions of the Act. Corporations with greater than 20 employees must have a Joint Health and Safety Committee (JH&SC)of at least 2 persons if under 50 employees, and 4 persons for larger numbers of employees. The committee, which must meet at least every three months, is given powers to operate and employers must respond to written recommendations of the committee within 21 days. The committee work is deemed work. Page 9 of 13 2013-2014 CRHCH Review of Compliance with Legislation 21) Pay Equity Act An Act aimed at addressing systemic discrimination in compensation by designing and implementing pay equity plans (to ensure equal pay for work of equal value). Initially, jobs were compared on the basis of compared characteristics by assigning point values, so that female-gender dominated job classes were compared to others in the same company. Later, the proxy method of comparison that enabled comparison outside of the company was introduced, but that was repealed in January 1997. Not-for-profis are subject to this legislation and should ensure that a pay equity plan has been developed and is implemented. 4-24 Employment Equity 4-01 – Employee Rights This Act applies to all employers in the private sector in Ontario who employ ten or more employees, and all employers in the public sector. Not-for-profits are included as being part of the public sector. The Act requires comparing the value of jobs usually done by women to the value of different jobs usually done by men. Compensation (wages and benefits) must then be adjusted so that it is at least the same for jobs performed mainly by women that are equal or comparable in value to jobs performed mainly by men, even if the jobs are quite different. 22) Personal Health Information Protection Act An Act aimed at addressing the protection of personal health information. This Act applies to “health care custodians, of which many not-for-profits are considered. Not-for-profis are subject to this legislation and should ensure that provisions in the Act are followed. 7-08 Client Consent 8-01 – Statement of Client Rights Provisions are required for protection, access, retention and release of client health information and stipulates that the organization’s privacy policy and practices must be made public to the clients it serves. 23) Public Sector Salary Disclosure Act The Public Sector Salary Disclosure Acct developed in 1996, requires organizations that receive public funding from the Government of Ontario to disclose annually the names, positions, salaries and taxable benefits of employees who were paid $100,000 or more. Record of Employees’ Salaries and Benefits for 2013 filed with Ministry of Finance February 28, 2014 24) Regulated Health Professions Act “Duty of Minister 2. It is the duty of the Minister to ensure that the health professions are regulated and coordinated in the public interest, that appropriate standards of practice are developed and maintained and that individuals have access to services provided by the health Many of the employees in not-forprofits are licensed under the provisions of the RHPA and the supplementary Acts (see special Audit of HR Files dated June 2014 Signed copy of BHO Audit Checklist of HR Files for BHO Accreditation Review May 2014 Page 10 of 13 2013-2014 CRHCH Review of Compliance with Legislation professions of their choice and that they are treated with sensitivity and respect in their dealings with health professionals, the Colleges and the Board. 1991, c. 18, s. 3.” Establishes the council named the Health Professions Regulatory Advisory Council in English and Conseil consultatif de réglementation des professions de la santé in French. “Duties of Advisory Council 11. (1) The Advisory Council’s duties are to advise the Minister on, (a) whether unregulated professions should be regulated; (b) whether regulated professions should no longer be regulated; (c) suggested amendments to this Act, a health profession Act or a regulation under any of those Acts and suggested regulations under any of those Acts; (d) matters concerning the quality assurance programs undertaken by Colleges; and (e) any matter the Minister refers to the Advisory Council relating to the regulation of the health professions, including any matter described in clauses (a) to (d). Additional duty (2) It is the Advisory Council’s duty to monitor each College’s patient relations program and to advise the Minister about its effectiveness. 1991, c. 18, s. 11. section below), which define “who may be licensed as a professional, the standards of care and conduct they are expected to meet, and what kind of behavior could attract punishment, or even exclusion, from the professional community”. Quote from The Canadian Health Law Practice Manual, which has a chapter on the licensing and regulation of health professionals. Boundary and professional misconduct issues are addressed in 'The Health Professions Procedural Code' which is part of this Act and spells out the powers of the Colleges to handle complaints against members of the Colleges. 25) Smoking in the Workplace The Act prohibits smoking in the workplace except in areas designated by the employer, an area used primarily by the public, an area used primarily for lodging, or in a private dwelling. Before establishing a smoking area, an employer must consult with the joint health and safety committee or the health and safety representative. Parts of the Occupational Health and Safety Act apply. An employer must make every reasonable effort to accommodate employees who request that they work in a place separate form a designated smoking area. In the event of conflict between this Act and another Act or a regulation or a municipal by-law respecting smoking in a workplace, the provision that is the most restrictive of smoking prevails. Fines may be levied for conviction. New signage has been ordered and will be in place Fall 2014 26) Substitute Decisions Act Sets out the requirements for appointing attorneys and guardians for personal care and for property, for persons who are incapable of taking care of themselves or of their property, as well as the powers granted to such attorneys and guardians. This is a complex area of law involving several pieces of legislation. Chapter 2.127 of the Canadian Health Law Practice Manual has a discussion of consent, capacity, and substitute decision making.Health care providers will have occasions to deal with attorneys and guardians of persons who are no longer able to make 7-08 Obtaining Consent Page 11 of 13 2013-2014 CRHCH Review of Compliance with Legislation decisions concerning their personal care. The powers granted to attorneys and guardians with respect to personal care need to be read in the light of the Health Care Consent Act, 1996 27) Technical Standards and Safety Act Purpose 1. The purpose of this Act is to enhance public safety in Ontario by providing for the efficient and flexible administration of technical standards with respect to the matters referred to in section 2. 2000, c. 16, s. 1. This act applies to CRCHC subsequent to May 28th, 2013 with respect to the electric chair lift installed at Guthrie House CRCHC is required to engage the Technical Standards Safety Authority on an annual basis to inspect and licence the electric chair lift located at 10 Perth St. Elgin. (Guthrie House) License in place and on-file. Part IV concerns the health care that injured workers are entitled to. Part V concerns regarding ‘returning to work’. Part VI concerns insured payments or compensation. Part VII concerns employers and their obligations, participating employers. Part X, Uninsured Employment Like many small organizations, CRCHC does not carry WSIB but covers employees by alternative means acceptable under the legislation. Application 2. This Act applies with respect to amusement devices, boilers and pressure vessels, elevating devices, fuels, operating engineers and upholstered or stuffed articles, as referred to in the regulations. 2000, c. 16, s. 2; 2006, c. 34, s. 25 (1). 28) Workplace Safety and Insurance Act This Act governs the Workplace Safety and Insurance Board (WSIB) Purpose "1. The purpose of this Act is to accomplish the following in a financially responsible and accountable manner: 1.To promote health and safety in workplaces and to prevent and reduce the occurrence of workplace injuries and occupational diseases. 2.To facilitate the return to work and recovery of workers who sustain personal injury arising out of and in the course of employment or who suffer from an occupational disease. 3.To facilitate the re-entry into the labour market of workers and spouses and same-sex partners of deceased workers. 4.To provide compensation and other benefits to workers and to the survivors of deceased workers. 1997, c. 16, Sched. A, s. 1; 1999, c. 6, s. 67 (1). Programs Offered to CRCHC Employees Supplemental Unemployment Benefit Plan (CRCHC tops up EI benefits to 95%) Long Term Disablity plan Return to work plan Annual OHS training Infection control inservices Free flu shots for all employees CPR training Page 12 of 13 2013-2014 CRHCH Review of Compliance with Legislation 29) Workplace Violence and Harassment Act Description Applicability to CHCs Compliance Requires employers to develop a workplace violence and harassment program, educate all employees and volunteers in its utility and conduct workplace violence and harassment surveys. Requires policies on workplace violence and workplace harassment Responsible for all aspects of this act as of June 2010 Policy 6-10 2 staff training days completed including orientation to wpv program Coordinator identified: M. Crapper 2014 workplace violence inspection completed June 2014 I CERTIFY THAT TO THE BEST OF MY ABILITY, THE OPERATIONS OF COUNTRY ROADS COMMUNITY HEALTH CENTRE ARE IN COMPLIANCE WITH ALL PERTINENT LEGISLATION Signed by: __________________________________ Date: ______________ Chair, CRCHCBoard ____________________________________ Date: ______________ Executive Director, CRCHC Page 13 of 13