To: Members of the Senate Judiciary and Finance Committees From: Chairman Charles E. Grassley, Senate Judiciary Committee Member, Senate Finance Committee Date: May 24, 2017 Re: Wounded Warrior Project Dear Fellow Committee Members: The Wounded Warrior Project (WWP) is a charitable veteran’s service organization established in 2003 for the purpose of providing services and support activities for wounded veterans of military actions following September 11, 2001. 1 Its mission is to “Honor and Empower Wounded Warriors” and provide services and programs to assist severely injured service men and women in transitioning and adjusting to civilian life. WWP provides peer mentoring to assist with life challenges and seeks to involve wounded warriors in physically and mentally stimulating activities to help provide a support system. In addition, WWP has a robust system to assist veterans in acquiring service connected benefits through the Department of Veterans Affairs, which has resulted in nearly $71 million in benefits to wounded warriors since 2008. 2 Executive Summary Over the past ten years, the WWP has grown substantially to 22 locations with roughly 500 employees and has raised at least $1 billion—largely through small donations from people over 65, according to the New York Times. 3 Recently, the WWP claimed that it spent 80.6 percent of its total program expenditures on providing services for veterans. However, news reports have raised questions about the percentage of WWP’s donations that go toward veteran service benefits and the inappropriate reporting of organizational expenses as costs for providing services to veterans. For instance, WWP says that 80.6 percent of its donations are spent on 1 WWP was incorporated in 2005 and filed its first tax forms as a non-profit in FY 2006. Exhibit D at 12. Letter from Charles E. Fletcher Jr., Interim Chief Operating Officer, Wounded Warrior Project, Inc., to Charles E. Grassley, Chairman, U.S. Senate Comm. on the Judiciary (June 6, 2016) (“As of May 31, 2016, WWP’s benefits service program assisted injured veterans and service members in securing approximately $71 million in economic benefit, including approximately $55.3 million in annual entitlements and approximately $15.7 million in retroactive amounts.”). 3 Dave Philipps, Wounded Warrior Project Spends Lavishly on Itself, Insiders Say, N.Y. TIMES (Jan. 27, 2016), https://www.nytimes.com/2016/01/28/us/wounded-warrior-project-spends-lavishly-on-itself-ex-employees-say.html; Chip Reid & Jennifer Janisch, Wounded Warrior Project execs fired, CBS (Mar. 10, 2016), http://www.cbsnews.com/news/woundedwarrior-project-ceo-and-coo-fired/. 2 1 programs for veterans, but this amount actually includes promotional items, donated media and other costs that should not be categorized as program service expenses. For example, without these expenses, Charity Navigator has estimated that WWP only spends about 54 to 60 percent of donations on helping wounded service members. 4 In January 2016, CBS News and the New York Times reported on troubling conditions within the organization, including exorbitant spending on staff meetings, conferences, and plane travel for staff members and program participants. In response to these news reports, Charity Navigator placed the organization on a “watch list” to further investigate and monitor WWP’s spending and reporting on services. 5 The Better Business Bureau also suspended the charity’s seal designation. 6 As a result of the news reports, on January 30, 2016, WWP’s Board of Directors retained Simpson, Thacher & Bartlett LLP and FTI Consulting to conduct an independent review of the reporting. On March 18, 2016, I wrote to WWP citing a multitude of news reports that indicated questionable spending practices. Given WWP’s status as a non-profit, it receives substantial tax breaks but does so with the responsibility that it will use the benefits of the tax code properly and in accordance with its mission. Because non-profit organizations receive tax benefits for serving the public, it’s imperative for Congress to ensure, via oversight, that these organizations are acting in good faith. On April 5 and 12, 2016, WWP provided responses and documents in reply to my initial letter that are attached to this memorandum. 7 On May 16, 2016, I wrote again to WWP following up on additional questions related to information provided in WWP’s first response. WWP appeared to be misstating the amount of program expenses it used for veterans. Specifically, for FY 2014, 33.3 percent ($80,710,673 of the $242,145,985) in WWP program expenses included expenditures for donated media and advertising, not donor money spent on services to support veterans as WWP reports. 8 In addition, WWP’s claimed that it spent more than $40 million in FY 2014 on fundraising solicitations that were educational in nature, and Wounded Warrior Project on Charity Navigator’s Watch List, CBS (Jan. 30, 2016), http://www.cbsnews.com/news/wounded-warrior-project-on-charity-navigator-watchlist-cbs-news-investigation/. See also, CHARITYWATCH, https://www.charitywatch.org/ratings-and-metrics/wounded-warrior-project/559. Charity Navigator raised the 60 percent figure to 75 percent after WWP updated its website to say that money spent on mailings serves a dual purpose: fundraising and education. See David Bauerlein, After financial hit, recovery of Jacksonville-based Wounded Warrior Project could take years, The Florida Times-Union (Feb. 20, 2017), http://jacksonville.com/news/metro/2017-02-20/after-financial-hitrecovery-jacksonville-based-wounded-warrior-project-could. 5 Wounded Warrior Project on Charity Navigator’s Watch List, CBS (Jan. 30, 2016), http://www.cbsnews.com/news/wounded-warrior-project-on-charity-navigator-watchlist-cbs-news-investigation/. See also, CHARITYWATCH, https://www.charitywatch.org/ratings-and-metrics/wounded-warrior-project/559. Charity Navigator has since removed WWP from the watch list. 6 Emily Wax-Thibodeaux, Wounded Warrior Project clear of ‘spending lavishly,’ report finds, The Washington Post (Feb. 8, 2017), https://www.washingtonpost.com/news/checkpoint/wp/2017/02/08/wounded-warrior-project-cleared-of-spendinglavishly-report-finds/?utm_term=.bb4fd50a5a9f. The Better Business Bureau has since reportedly “cleared” the WWP and found that its spending has been “consistent with its programs and missions.” 7 Exhibit A; Exhibit B. 8 Letter from Charles E. Grassley, Chairman, U.S. Senate Comm. on the Judiciary, to Anthony Odierno, Chairman, Wounded Warrior Project, Inc. (May 16, 2016). Notably, in FY 2015 32.05 percent ($98,934,728 of $308,715,167) in WWP program expenses included expenditures for donated media and advertising. 4 2 therefore under Statement of Position (SOP) 98-2 were considered program services on behalf of veterans. There were also concerns related to WWP’s Long-Term Support Trust. According to WWP advertisements, $65.4 million has been spent on long-term support programs. 9 However, WWP has actually transferred $55.1 million to the trust – an amount from which not a penny has actually been spent, but rather is being held in reserve for future needs. The remaining $10.3 million was spent in the Independence Program. 10 WWP grew very quickly and initially failed to form an organizational structure to adequately manage that rapid growth. This lack of organization allowed for certain spending practices that broke faith with the donating public. Exorbitant plane ticket costs, expensive staff meetings, and excessive senior executive compensation were serious red flags. A. The Wounded Warrior Project Inaccurately Reported Spending 80.6 Percent of Donor Funds on Program Services for Veterans The WWP has repeatedly reported that it spent 80.6 percent of its donations on program services for veterans. 11 After reviewing WWP’s IRS Form 990 and Consolidated Financial Statements, it became apparent that this percentage was inaccurately inflated by inappropriately categorizing certain services. For example, WWP’s 80.6 percent assertion includes tens of millions of dollars per year in donated media, such as free advertisements on television. These expenses are more appropriately categorized as fundraising solicitations for the organization. However, by including donated media in program expenses, WWP inaccurately reports that it spends a greater percentage of donor funds on program expenses that directly benefit veterans. These inaccuracies add up to serious overstatements about WWP’s commitment to supporting veterans and understates the actual amount of money that WWP spends on program activities in pursuit of its mission. Following questions about this practice, WWP decided to no longer base its program service percentage on expenses reported in the Consolidated Financial Statement (prepared in accordance with GAAP) and instead used expenses reported in its annual IRS Form 990. For IRS reporting purposes, the value of donated media is not a program service expense. Thus, it might at first appear that WWP’s decision to use expenses from the Form 990 as the basis for its program service percentage would result in the most accurate and conservative percentage. However, that is not the case because WWP’s Form 990 includes funds transferred to the LongTerm Support Trust as a program expense, whereas WWP’s GAAP financial statements do not. WWP has transferred tens of millions to the Trust but has not drawn any money from it. Exhibit D at 9. Id. See also, WWP’s Form 990, (which describes the Independence Program as the following, “The Independence Program helps warriors live life to the fullest, on their own terms. It is designed for warriors who rely on their families and/or caregivers because of moderate to severe brain injury, spinal-cord injury, or other neurological conditions. In addition, the warrior’s cognitive or physical challenges limit their opportunities to access resources and activities in their own community.”). 11 Exhibit B at 5.As reflected in Wounded Warrior Project’s Consolidated State of Activities for FY 2014, Wounded Warrior Project reported that 80.6 percent of Total Expenses were spent on programming based on dividing the line item for Total Program Expenses ($242,145,985) by the line item for Total Expenses ($300,279,601). 9 10 3 Therefore it is inaccurate and arguably deceptive to include money merely transferred to the long-term trust as a program expense on behalf of veterans when computing and reporting WWP’s program service percentage. 12 Instead of basing its program percentage on the Form 990, WWP could have continued to base it on the Consolidated Financial Statement. This would have prevented the inclusion of money transferred to, but not drawn from, the Trust since these transfers are automatically excluded. In addition, WWP could have subtracted the donated media from expenses reported in the Consolidated Financial Statement. The exclusion of both funds transferred to the trust and donated media would have provided a much more accurate accounting of how it reaches its program service percentage than what is derived from the Form 990. If WWP did so, in FY 2014 its program expenses would have been approximately 73.5 percent and approximately 70.1 percent in FY 2015. Further, if joint allocation amounts were subtracted, the percentages would fall further to 67.5 percent and 64.5 percent in FY 2014 and 2015, respectively. 13 For FY 2016, program expenses were 67.5 percent without donated media and joint allocations. These figures are much lower than WWP’s reported 80.6 percent spent on warriors in FY 2014. For additional detail, please refer to Exhibit G. B. The Wounded Warrior Project Inaccurately Reported Spending $65.4 Million on Long-Term Support Programs for Veterans Up until August 22, 2016, the WWP used the following advertisement that says it spent $65.4 million on its Long-Term Support Programs: 12 Exhibit D at 7. Importantly, WWP noted that transfers to the Long-Term Support Trust are not included in the 80.6 program service percentage. This is true because the 80.6 percent is based on the Consolidated Financial Statement which does not include transfers to the Trust but does include donated media. 13 In FY 2014, WWP’s expenses reported pursuant to its IRS 990 amounted to 76.4 percent. WWP’s GAAP financial statements reported 80.6 percent. The 80.6 percent is what WWP reported publicly to the media. In FY 2015, WWP’s expenses reported pursuant to its IRS 990 amounted to 74.6 percent. WWP’s GAAP reported 77.5 percent. 4 This assertion was misleading. In response to inquiries about the amount of contributions spent on veterans, WWP said “[t]o date, no distributions have been made from the Wounded Warrior Project Long [sic] Term Support Trust.” 14 By way of background, in September 2013, the WWP created a separate 501(c)(3) to serve as a Long-Term Support Trust (“the Trust”) as a “resource to assist severely injured veterans and service members in maintaining their quality of life and independence by providing resources and support” for wounded veterans after the loss of a caregiver. 15 The Trust is designed to provide benefits upon the death of a Wounded Warrior’s caregiver and extend financial support to cover the costs of 10-15 years of support services. According to WWP, “[t]he Trust is an extension of WWP’s Independence Program, which provides support and training for those injured veterans and service members with moderate to severe brain injury, spinal cord injury, or other neurological conditions.” 16 The eligibility criteria is as follows: (1) an Alumnus must lose a caregiver due to the caregiver’s passing, disability or other circumstances, and (2) as a result, the caregiver must no longer be able to provide the Alumnus with the necessary care and support to ensure that he or she is living in the least-restrictive setting possible with the highest quality of life. 17 As of June 2016, approximately 251 injured veterans and service members pre-qualified for the Trust. 18 Committee staff asked WWP to explain the process for determining the amount of money veterans would receive should they qualify for payments drawn from the Trust. It was not clear whether WWP was taking the proper steps to ensure the Trust’s solvency; and whether it would determine potential payment amounts with consideration of the amount of money the veteran was currently receiving from the Department of Veterans Affairs or other governmental agencies, state and federal, due to their disability. If WWP did not weigh all monetary receipts, the Trust could lose substantial sums of money because of payments made to warriors that may not have been financially necessary. The end result, of course, would be that veterans that actually need the supporting payments would not receive the necessary funds from the Trust due to overdrawing. For instance, if a veteran is totally disabled based on a disability rating from the Department of Veterans Affairs, that veteran could receive well in excess of $3,000 per month, tax-free. Additional government programs, possibly through the Social Security Administration or state-level programs, would also add to the veteran’s benefit allowance. Depending on that individual’s expenses, he or she may not need Trust payments. In an August 2016 meeting with Committee staff, WWP’s Chief Financial Officer, Mr. Ron Burgess, indicated that WWP would Id. at 7. Id. at 7. 16 Id.at 8. See also, WWP’s Form 990, which describes the Independence Program in the following, “The Independence Program helps warriors live life to the fullest, on their own terms. It is designed for the most severely wounded warriors who rely on their families and/or caregivers because of moderate to severe brain injury, spinal-cord injury, or other neurological conditions. In addition, the warrior’s cognitive or physical challenges limit their opportunities to access resources and activities in their own community.” 17 Exhibit D at 10. 18 Id. 14 15 5 analyze other payments received from federal and state programs when determining how much, if anything, the veteran would receive from the Trust. Between Fiscal years 2013 and 2015, WWP transferred more than $55 million of donor contributions to the Trust instead of spending it on program activities. It spent an additional $10 million on the Independence Program, which is also separate from the Trust. In fact, the only payments drawn from the Trust were for wealth managers. For example, the Trust’s FY 2014 Form 990 shows that Barclays received $134,721 for managing the Trust. In a June 6, 2016, letter to the Committee, the WWP further broke down the FY 2014 expenses into several categories: “(1) $99,737.56 in Investment Management Fees paid to the trustee of the Trust, formerly Barclays Wealth Trustees, and now known as Stifel Trust Company Delaware, National Association; (2) $16,250.00 in Fiduciary Fees; and (3) $18,733.44 in Non-Affiliate Third Party manager fees.” 19 Accordingly, the advertisements were at best misleading because $65.4 million was not actually spent on veterans. Rather the money was simply transferred to the Trust. Misleading advertisements undercut the public’s trust in any organization. In addition, based on the concerns that I raised during the investigation, WWP informed the Committee that on or around August 22, 2016, it ceased using the advertisements. The WWP should do more to explain to the public its goals with respect to the Trust and how it intends to use it on behalf of veterans. C. WWP’s Independent Review Disclosed Additional Inappropriate Use of Donor Funds On January 30, 2016, the WWP Board of Directors employed Simpson, Thacher & Bartlett LLP as well as FTI Consulting to conduct an independent review (“the review”) of the WWP financials for FY 2011 through the Q1 of 2016. 20 The review was completed on March 9, 2016, and, as a result, the Chief Executive Officer and Chief Operating Officer of WWP were relieved of their duties. Simpson, Thacher, & Bartlett and FTI Consulting provided an oral presentation of the findings of the review to the WWP Board of Directors. Accordingly, written documentation of the review has not been shared with the public until now. The Board of Directors provided to the Committee a written summary of the oral presentation at Exhibit C. With respect to the independent review, over the course of a month, close to forty individuals from various levels of the organizations were interviewed, including people who had spoken to the media. 21 The review focused on media allegations of certain practices at WWP, which claimed that WWP engaged in excessive spending of donor contributions, overly expensive employee travel, overspending on administration and fundraising, and a general Id. Exhibit C at 3. Letter from Paul C. Curnin, Attorney-at-law, Simpson Thacher & Bartlett, to Charles E. Grassley, Chairman, U.S. Senate Comm. on the Judiciary (Sept. 12, 2016). 21 Exhibit C at 3. 19 20 6 failure to work towards its mission of assisting veterans. 22 Furthermore, financial statements, training materials, and travel documents were reviewed. Simpson, Thacher, and Bartlett LLP also hired FTI Consulting, Inc., a forensic accounting firm, to review WWP financials for FY 2011 through the Q1 of 2016 as well as provide a review of the accounting methodology for calculating expenses. 23 FTI evaluated WWP’s application of American Institute of Certified Public Accountants standards regarding joint cost allocations, employee credit card reports, Board meeting minutes, and reimbursements, among other things. 24 Although FTI Consulting reviewed various financial aspects of WWP, the scope of the review did not engage in a full forensic audit of the reported IRS 990s or of the audited financial statements. 25 The review made a number of findings including several that focused on the inner workings of the organization as well as others that highlighted the excessive amounts of donor contributions that were misused. Here is a brief summary of the independent review: 1. WWP lacks sufficient policies and procedures to manage the organization. While WWP’s approach to policies and procedures was appropriate at its inception, it has failed to adapt to its growing size. The review stated, “[h]istorically, WWP management took a minimalist approach to formal written policies and procedures.” 26 WWP had very few written policies and instead relied on the philosophy of “trust [their] employees.” 27 The review noted that due to the organization’s significant expansion, the lack of written policies was “no longer appropriate.” 28 2. WWP spent excessive amounts of donor funds on employee travel expenses. The review also analyzed employee plane travel from August 3, 2010, to March 23, 2016. The review found that during that period employees spent approximately $18.8 million on 38,112 flights for employees, wounded warriors, and wounded warrior caregivers. 30 According to the review, 95 percent (or 36,240 of 38,112) of the flights were economy class, and the remaining 5 percent (or 1,872 of 38,112) were first or business class travel. The review determined that roughly $2.2 million was spent on domestic and international first or business class travel, despite WWP’s travel policy against such charges. 31 WWP’s travel policy states that the “approved class of transportation for all team members is coach.” 32 However, 29 Id. Id. at 4. 24 Id. 25 Id. 26 Id. at 5. 27 Id. 28 Id. 29 Id. at 6. 30 Id. During the investigation, WWP employees defended the use some, but not all, first class plane tickets because some wounded warriors require extra space due to their injuries. The Committee fully understands this requirement. 31 Exhibit A at 5-6. 32 Exhibit E at 2. The policy also states that upgrades are not allowed. However, in WWP’s response in Exhibit A at 5-6, it notes that the upgrade information provided to the Committee were complimentary. 22 23 7 documents provided to the Committee contain examples of the high cost of plane tickets, at least 43 first and business class tickets were over $5,000 33 and some over $10,000. 34 The most expensive fare was a first class flight for $12,137. 35 These costs are exorbitant. When Committee staff met with the new CEO, Mr. Michael Linnington, he assured them that these high priced ticket purchases would not continue under his watch. 36 3. WWP spent excessive amounts of donor funds on administrative and fundraising events but found executive salaries reasonable. The review found that the costs of the “All-Hands Huddle” events, which were organizational-wide team meetings held to promote growth and team building, increased substantially as the number of employees increased year-to-year–growing from $129,460 to $987,209 between 2011 and 2014. 37 These meetings cost the organization as much as $2,379 per person. 38 The review also noted several instances where the former CEO made expensive and grand entrances to conferences, such as entering on horseback or rappelling down to the audience. The former CEO and former Chief Operating Officer (COO) defended their dramatic entrances noting that it “demonstrated the organization’s commitment to ‘fun’ as a core value.” The organization has since noted that the All-Hands Huddle events will no longer continue as of August 2016. The review also found that WWP performs a substantial amount of outreach in the furtherance of its mission. For example, WWP made 150,065 calls from 2013-2015 and sent 114,343 emails to warriors. 39 A study of senior executive compensation at similarly sized charities, including veterans’ charities, found that WWP’s CEO and COO combined compensation was between the median and the 75 percent percentile. 40 The review concluded that senior executive compensation was in line with similar practices in the non-profit field. 41 High non-profit executive salaries are always a concern. In addition to an annual salary of $352,000 and $342,766 in fiscal years 2014 and 2015, the former CEO also received $88,000 in bonuses in each of those years. The COO had an annual salary of $280,000 and $271,487 in fiscal years 2014 and 2015 and also received a $70,000 bonus for both years. IRS rules state the nonprofit CEOs should receive “reasonable compensation.” According to a recent study by Charity Navigator, the median CEO compensation among the charities that it rates is $123,462 Exhibit A at 56-60, 62, 67-68, 71-73, 76, 78-79, 81, 84-85. Id. at 62, 79, 88. 35 Exhibit A at 79. 36 In a follow up email on March 28, 2017, WWP’s General Counsel, Amber Allred, said that WWP has not paid for firstclass travel by an employee since February 18, 2016. 37 Exhibit C at 7. 38 Id. 39 Exhibit A at 2. See also, Exhibit C at 5-6. 40 Id. at 9-10. 41 Id. at 7. 33 34 8 including salary, cash bonuses and expense accounts, which represents a 3 percent raise over the previous year. 42 Mr. Linnington, the new CEO, joined WWP at a $280,000 salary. Lastly, the review argues that 80.6 percent of WWP funds are spent on programing and that the discrepancy between its figures and Charity Navigator’s 60 percent figure comes from Charity Navigators disregard of Joint Cost Allocations principles. 43 Thus, there are significant concerns about the previous use of the 80.6 percent figure. D. WWP’s Use of Joint Cost Allocations are Questionable In a May 16, 2016 letter, I noted that separate from its Consolidated Financial Statement, WWP’s FY2014 Form 990 shows what it considers to be functional expenses attributed to joint cost allocations. A joint cost allocation is applicable when a non-profit organization combines a fundraising function with a program activity such as public education. The standard for compliance is set out in the American Institute of Certified Public Accountant’s Statement of Position (SOP) 98-2. 44 The problem with its use is that fundraising activity can be accounted for in such a way that it results in it being considered an “educational” expense and thus a benefit to veterans when often that is really not the case. Thus, its use can be misleading. SOP 98-2 established three criteria that an entity must meet in order to charge otherwise fundraising costs to program expenses. The criteria are purpose, audience, and content. The purpose must be to carry out a program or management purpose. The audience should fit with the action being requested or the activity being highlighted. And the content must support the program at issue. In FY 2014, WWP spent $40,916,885 on program service costs that were joint educational and fundraising solicitations. The $40.9 million was considered program expenses on behalf of wounded warriors even though not all of it was actually a deliverable benefit because it included money spent on fundraising expenses. In FY 2015, the amount allocated to joint educational and fundraising increased to $47,148,553. When meeting with WWP personnel, Committee staff specifically raised issues with how the WWP determined the dollar value allocated to joint costs. According to WWP, it uses an independent contractor, Gary Ellis, to “perform joint cost allocation on its paid direct mail pieces, emails, and Direct Response Television scripts.” 45 In doing so, Mr. Ellis uses the lines of copy method which is described by WWP as follows: 46 42 See https://www.charitynavigator.org/index.cfm?bay=content.view&cpid=4404. Id. at 8. 44 Richard F. Larkin, Joint Cost Allocation, NONPROFIT ACCOUNTING BASICS (June 3, 2009), http://www.nonprofitaccountingbasics.org/fundraising/joint-cost-allocation. 45 Exhibit C at 8. 46 Exhibit C at 8–9. 43 9 Prior to performing his allocation, Mr. Ellis receives a copy of each of WWP’s direct response mailings, email solicitations and DRTV scripts. He then numbers each line of a mailing, email, and/or television script and highlights each line of copy associated with fundraising. He allocates lines of copy that are not highlighted to program expenses; and prepares a spreadsheet showing how many lines are allocated to each of: “fundraising,” “management and general,” and “program.” Mr. Ellis then creates a document for each direct response item that outlines the purpose, audience, and content for the specific communication, as well as the public education and “call to action” portions—which can be allocated to programming— articulated in that particular item. In review, the WWP concluded that its joint cost allocation process was “transparent” and “well-documented.” Most charity watchdog organizations do not count this type of spending as a program expense because it generally does not provide any benefit in support of a charity’s mission other than fundraising. As such, claiming this nearly $41 million dollars in FY 2014 as program services for veterans is questionable. In reviewing the examples of material that WWP considered to be jointly allocated, there is reasonable concern that it is more fundraising in nature than a legitimate program expense. 47 In particular, WWP’s Exhibit J-3 appears to be wholly fundraising in nature. 48 In my May 16 letter, I noted that if no benefit is really derived for veterans, it calls into question WWP’s claim that 80.6 percent of its revenue is spent on program expenses. Although the tax code allows WWP to claim these engagements as program expenses on behalf of veterans, the endeavor is actually more fundraising in nature than a benefit to veterans. As such, its use skews WWP’s reported program expenses. E. The WWP Alumni Program Lacks Proper Oversight and Requires Additional Changes to Ensure Efficiency According to WWP, “[t]he Alumni program provides long-term support and camaraderie for wounded warriors through events, discounted services, and an online community.” 49 According to documents provided to the Committee, in FY 2013 WWP had a total of approximately 3,426 events, and about 76 percent (2,615 of 3,439) were categorized as alumni events. In FY 2014, WWP had approximately 4,485 events, and 71 percent (3,197 of 4,496) were categorized as alumni events. 50 Exhibit D at 17-35. Exhibit D at 29–35. 49 Wounded Veterans Learn About Sea Life, WOUNDED WARRIOR PROJECT (Aug. 6, 2015), https://www.woundedwarriorproject.org/featured-campaign/wounded-veterans-learn-about-sea-life. 50 For additional detail, please refer to WWP’s June 6, 2016 response, Exhibit D at 11. 47 48 10 A significant portion of WWP’s alumni events were “sporting events” with in kind ticket donations, for example; NFL games, MLB games, NBA games. 51 WWP has argued that these events are a way of networking and bringing wounded warriors into the WWP. In addition, WWP has argued that participating in these types of events contribute to a bonding experience that helps warriors in dealing with the emotional difficulties of being home after war. The WWP has said that the Alumni program is an important first step in reintegrating service members into civilian life. However, the events often had low rates of participation, sometimes one to two participants. Further, it has been reported the WWP often invited the same veteran to multiple sporting events, but reported the activity as supporting multiple veterans. 52 The documentation WWP provided the Committee includes the number of warriors involved in the Alumni events. Each participant listed is a wounded warrior, not a staff member. WWP tracked participants and employees with Salesforce program. WWP informed the Committee that 0.12 percent of all participants in the Alumni events were also staff members but they did not attend as a staff member but rather as a wounded warrior. 53 Going forward, WWP has informed the Committee that it has improved its staff tracking capabilities. Employees who participate in an Alumni event will be listed with the event by name and contact information. 54 In addition, WWP has informed the Committee that it is placing increased focus on tracking which events are paid for by WWP and which are in-kind donations. Notably, events can have ancillary costs supported by WWP. For example, donated tickets to a sporting event could include a dinner that is paid for by WWP. Going forward, WWP will be better able to track those ancillary costs. WWP does not have designated staff to warrior ratios or staffing guidelines for any events other than Project Odyssey. Project Odyssey is a program that aims to assist veterans with overcoming combat stress through outdoor recreational activities. Examples of activities include horseback riding, canoeing, whitewater rafting, kayaking, fishing, and hunting. Given that level of activity, there is a set list of staff involved – two WWP staff members and one clinician – to assist with the programs and monitor any health concerns. However, WWP believes that it would not be helpful to establish similar guidelines or staff to participant ratios for other Alumni events because of the varying types of activities and level of participation involved. Exhibit B at 8-171. Dave Philipps, Wounded Warrior Project Spends Lavishly on Itself, Insiders Say, N.Y. TIMES (Jan. 27, 2016), https://www.nytimes.com/2016/01/28/us/wounded-warrior-project-spends-lavishly-on-itself-ex-employees-say.html. “If the same warrior attends six different events, you could record that as six warriors served. You had the same few guys who loved going to free events.” 53 Telephone Interview by Josh Flynn-Brown with Michael Linnington, CEO, Wounded Warrior Project, and Amber Allred, Gen. Counsel, Wounded Warrior Project (Dec. 13, 2016). 54 Id. 51 52 11 In reviewing the documentation provided to the Committee by WWP it appears some events are questionable in nature. 55 A few examples are: 1. “Alumni-CA-Food & Wine Festival” on October 13, 2013, with 20 participants 2. “Alumni-Family VA Wine and Design” on March 4, 2014, with 16 participants 3. Numerous Alumni “Texas Hold’em,” poker, and casino events in Texas, New York, Arizona, the District of Columbia with approximately 5 to 40 participants at each event 4. “Alumni NY Midnight Pool Party” on August 24, 2013, with 10 participants 5. Numerous Alumni “Getaways” in Vermont and Maine often at multiple resorts in the same location with only 1 participant The utility of the events is questionable. It is also troubling that WWP did not have a system place that could easily account for which events were paid for by the organization or were in-kind donations. But, in the future, WWP has placed emphasis on being able to easily discern what was actually paid for by WWP, to include ancillary costs, as opposed to in-kind donations. Regardless of the funding mechanisms for the events, paying for or otherwise supporting activities that include gambling and alcohol for veterans and WWP staff is problematic. Without additional information on the utility of the events, it is impossible to determine how these events are in line with WWP’s mission and purpose to provide rehabilitative services and support to wounded warriors. F. WWP has Taken Action to Address Some Problems On August 10, 2016, Mr. Linnington, CEO, Mr. Ronald Burgess, Chief Financial Officer, and Ms. Amber Allred, General Counsel, provided a briefing to my staff on changes to the structure of the organization by streamlining the workforce and identifying highest priorities. According to Mr. Linnington, WWP intends to increase investments in mental healthcare for those who suffer from Post-Traumatic Stress Disorder and Traumatic Brain Injury through the Long-Term Support Trust and community engagement activities. 56 Mr. Linnington has said he recognizes the importance of improving transparency and accountability by clear reporting and being accountable to the wounded warriors and their families. 57 Since the briefing, WWP has cut the executive staff by 50 percent and began to reduce administrative cost. 58 According to documents provided to the Committee, WWP has revised its travel and spending policies. 59 Such policies include changes to the travel bookings platform that no longer permit employees to book first class airfare without warnings that prevent them from proceeding Exhibit B. Joanne Fried, Wounded Warrior Program Announces Changes to Maximize Impact, WOUNDED WARRIOR PROJECT (Aug. 31, 2016), www.woundedwarriorproject.org/featured-campaign/wounded-warrior-project-announces-changes-tomaximize-impact. 57 Id. 58 Id. 59 Exhibit F. 55 56 12 further. 60 Additionally, airline tickets of at least $200 more than the lowest fare offered automatically generate a “flight rule violation” which is reported to the Travel and Events Manager. 61 The Manager also receives a monthly travel expense report to review. WWP also implemented additional protocols to monitor and prevent improper spending of expense accounts. 62 For example, all credit card statements and cash reimbursement reports must be approved by the employee’s direct manager. The Accounting department has implemented analytics to identify potential fraud as well as protocols to review monthly credit card reviews. The Payroll Manager is tasked with ensuring that any personal use of a WWP credit card is reimbursed to the organization. WWP has taken other steps to mediate waste such as eliminating complimentary snacks, soda, and water bottles as well as closing its stage 1 offices (executive suites in locations where WWP has few employees) and instructing affected employees in these locations to work from home. 63 A new Internal Audit Department was created on April 2016, who would answer directly to the Audit Committee, and the 2016 “All Hands Huddle” meetings have been cancelled with no plans to hold this style of event in the future. 64 Conclusion WWP has a tremendous responsibility to be a force for good in the veteran community. It has a created a significant reach in the veteran community and the American people have taken notice of its potential. It is clear that a substantial number of Americans trust the WWP to properly spend the money that they donate to it by virtue of the extensive level of donations it receives per year. However, with this money and level of support comes great responsibility. The WWP appears to manage a number of its programs successfully, but it remains unclear if it is doing all that it can to appropriately convert donor funds into services for wounded veterans. As a tax-exempt organization, the WWP receives generous tax treatment and must be accountable and transparent in how it conducts business. Moving forward, the WWP needs to improve and restore the public trust and it can begin to do so by being transparent and honest about the use of donor contributions and program activities that provide real benefits to veterans. In turn, transparency will bring accountability and lead to a better fulfillment of its mission. 60 Exhibit C at 16. According to documents provided the Committee, the WWP has already implemented several changes to its ticketing policy. For example, the software platform WWP uses to purchase tickets, “Concur,” no longer permits employees to book first or business class tickets without warnings. 61 Id. 62 Exhibit F at 2. 63 Exhibit C at 17. 64 Id. 13 The WWP has used misleading advertisements to advocate for its Long Term Trust. Not a single penny has been paid out of the trust yet for the benefit of veterans. The WWP has repeatedly informed the Committee that payments will eventually be made. But, questions persist as to the process and procedure that will be employed to ensure wounded warriors receive a proper amount of money for the care they require. WWP has stopped using its previous advertisements regarding the Long Term Support Trust, a welcome improvement. To its credit, WWP has made changes to its airline ticketing policy that will bring forth more efficiency and better spending practices. Prior to the new ticketing policy, employees were able to purchase extremely expensive tickets, some in excess of $10,000. This type of spending breaks faith with the donating public and illustrates a disregard for the hard-earned money that people choose to donate. Going forward, the new ticketing policies are a welcome improvement. With respect to the Alumni Events, WWP forcefully argued that they are an integral part of the organization’s mission to assist veterans. That argument is reasonable; however, to more adequately justify the benefits of these events WWP is improving its tracking of how many staff are participating versus the number of warriors involved. Also, without knowing additional context for each event, those with only one or two warriors involved appear to be questionable. Granted, these events by and large are donated tickets rather than WWP spending. But, WWP has been unable to provide a breakdown of which events it paid for. Going forward, it should better track which events were donated versus paid for by the organization. The WWP should also carefully choose the events it sponsors and reconsider those focused on drinking and gambling. The WWP does not actually spend 80.6 percent of its donations on program services for veterans. In meeting with my staff, Mr. Linnington pledged that in the future WWP would report its program expenses based upon WWP’s yearly IRS 990 Form. With this change, WWP will no longer be reporting donated media as program service expenses. However, the Form 990 includes transfers of money to the Trust as a program expense even though no money has yet been drawn from the Trust to support veterans. This change does not provide the most accurate accounting possible. If WWP continued to use the Consolidated Financial Statement as the basis for its program service percentage and did not include donated media, that would provide the most accurate representation of how it arrives at its program service percentage and how much is actually spent on veterans each year. The WWP and its current leadership were open, transparent, and responsive to my inquiries. Americans want WWP to be successful for the sake of our veteran population. The changes made thus far by WWP illustrate that oversight works to bring about adjustments that result in more transparency for the donating public. WWP is rightly focused on making changes, but, more must be done. Charities serve an integral role in our society and have a tremendous 14 responsibility to be a force for good. WWP should continue to strive to increase transparency and accountability to set a good example for others in the non-profit field. If you have further questions, please do not hesitate to contact me or Josh Flynn-Brown of my Judiciary Committee staff. Sincerely, Charles E. Grassley Chairman Committee on the Judiciary 15 EXHIBIT A SJC 1 Simpson Thacher & Bartlett LLP 425 LEXINGTON AVENUE NEW YORK, NY TELEPHONE: FACSIMILE: 10017-3954 +1-212-455-2000 +1-212-455-2502 Direct Dial Number E-mail Address pcurnin@stblaw.com (212) 455-2519 CONFIDENTIAL TREATMENT REQUESTED BYE-MAIL April 5, 2016 Re: Wounded Warrior Project, Inc. Senator Charles E. Grassley Chairman Committee on the Judiciary United States Senate Washington, D.C. 20510-6275 Dear Senator Grassley: I write on behalf of Wounded Warrior Project, Inc. ("Wounded Warrior Project" or "WWP") in response to your letter dated March 18, 2016. We are grateful for the opportunity to address the inaccuracies in the recent media reports concerning WWP. Consistent with telephone discussions with your Staff, set forth below and enclosed are the initial responses to your March 18 letter. As discussed with your Staff, we will provide additional responsive information on a rolling basis. We look forward to meeting with your Staff to address the organization's commitment to serving the needs of this nation's wounded service members. Wounded Warrior Project intends to fully cooperate with your inquiry, and is committed to maintaining an ongoing and productive dialogue with the Committee. By way of background, Wounded Warrior Project's mission is to honor and empower wounded service members, and to foster the most successful, well-adjusted generation of warriors in this nation's history. Wounded Warrior Project furthers this vision by raising awareness about the nation's wounded warriors and providing access to direct programming for the 87,677 injured service members who have registered with Wounded Warrior Project and 17,922 of their registered family members. Wounded Warrior Project offers over 20 direct programs and services designed to respond to the changing needs of this generation of injured service members, organized around four main program areas: (1) helping warriors and their families live with the invisible wounds of war such as post-traumatic stress disorder and traumatic brain injury (mind); (2) helping warriors achieve physical health and maintain active lifestyles (body); (3) connecting warriors with each other, with the networks of support in their communities, with Wounded Warrior Project's programs, and with experienced professionals who can help them access federal and state benefits (engagement); and (4) helping warriors IJlCJ.JJNr. HONG JMfY\; SSl¢t1 "[, '> z.c, WWP_0000298 SJC 63 Exhibit SJC 64 990 Form Return of Organization Exempt From Income Tax Ocpnrtmnn1of lhn ffonsury 1ntPrnn1Hn""""" s"'"''" A B .... Tho organization m ay have to use a copy of this r eturn to satisfy state reporting requirem ents 09/''7 "01 3 For the 2012 ca le nda r yea r or t ax year beginning ( ' I ~. • I 0'1 /"lO I 20 1 ·i and e nd i n g D Employer l do111lflcnllo11 1111m bor C Nnme of orgonlzallon Ct-•£0:..:i r•to -x ~@ 12 U n d er section 501(c), 527, o r 4947(a)(1) of the Internal Revenue Code (excep t bl ack lung benefit trus t or priv ate found ation) WOUNDED PHOJECT L'l' !"ilJl'POR'J' 'l' l{lln'I· ~//\RR l.OR 1 / - G'>'>llh .U ~ /1 :M reu c. ho11•a e ,__ U1rre I PORTUNOPF S'I' REE'r , \'/JI.MINGTON I J sot(c)( ) .... (insen no.) J Hia) DE 1 •JHO l J 4047(a)( 1) 1111• •uroupre111111101 oll~1~·fcs? H(b) 1\10 oil nflllln1os 1nc1uucc? or I I s21 H{c ) Grour1 AJ:ornp11ou n11mbt.Y I L Ycai or rorma1 1ow ?OJ 11 M m: N umber o f voting members o f the governing body (Part VI. line la) 3 () 4 Number o f 111dependent votin g members ol the governing body (Part Vt, lin e 1b) , 4 () 5 Tol al number of individuals employed In calendar year 2012 (Part V, line 2a) . To tal n umber o f volunteers (estimate if n ecessary) 5 6 0 6 7r. () 0 '7b Curra nt Year Pri or Year Cl 8 Contributron s •111d grants (Part VIII , line 1h). 0 "a; 9 Progra.111 sorv1ce revenue (Part VIII, line 2Q) • (1 > GI 10 0: 11 ~) ' 100 , 000 . 0 ,, 1nves 1111ent Income (Part VIII, column (A), lines 3, ti , ancl 7dJ. \/ (1 O ther r evenu e (Part VIit , cohm1n (A), lines 5, Gd, Sc, 9c, 10c, an d 11e). (1 l) ~~ , 12 To tal revenue. add lines 8 through 1 t (must equal Part VIII, column Totnl fundmisl ng expenses (Part IX , column (D), line 25) ,... - - - - - - - - - _____ Q_____ >( 100 , 000 . 0 0 [) () I',) () Oth er expen ses (Pan IX, column (A), llnes 11a- 1 I d, 1 tf-2 4e) 0 () 18 l o tal exp enses. Add lines 13-17 ( must equal Part IX, column (A), line 25) (I 19 Revenue less exoenses. Subtract line t 8 from line 12 . 0 0 17 (; ~ td~ . . 20 ;; 1! .... StnlP. or lag ~I clomfclle· 3 b Ne t unrel ated business taxable In com e from For m 990-T, line 34 i~ No Vos If •Not nunc.h rs h~I (sou i11 struct1t.'f'lt·) WOUM DE D\•//\RRIORPHOJEC'l' . ORG I I Corporollon I X I Tru st I I /\ssoclnlloo I I Other .,.. I• 7 a Total unrelated busin ess revenue from Part VIII. column (C), line 12 UJ (J , 100 , 001 .1 . a:~ G Gror.s rccoipts S S l\ R/\ 'I'O AS8 1ST WTTH LONG TEHM CARF. NSF.OS UPON SSPi\P.l\TTON FROM CT1R P.t:T\IER . Ch;ck this-~;-,;o-;f-1h;;,9;niz-;;;1;;;;;~~on~1~drt;~~e~;;;;,~;~r-d:~-;s~d~f-n~~;ti,;,~25"A~~tlt; ~;t~'l;;e~s------ - -------- - - 2 .~ ·z:; ? ')t>- / J 'J() ------------------------------------------'l'() l'R(lVJ D C: 'l'fl8 SCONOMI C ME/\ NS rnR SU PPOR 'l' l V I~: Sl·:lE!'.'.f_I\_:>__!'_s,>_S§_I_b_L'._E_i _ !~~L!_ _ - - - -- - -- - - - -- - - - .:;; (!) Telephone number ( CJ OtJ) Briefly describe !lie organization 's mission or most signlncan t activil les "'uc ., E Rooml sulle Summary 1 > 0 [)!.; F Nam e and address of prlnclpnl olf1cor· Af'tllf!" 41 1(HI I I ~ 'l'RE8 '1' City. town or post office, sl ate, and ZIP code lrl11./ll ~ Doh1g Business /\s Numb ~ r end ~11 ee1 (Ot P.O l)OX lfnrnll ls not dQl1veied to sl/oe1address) 21 z? 22 Boglnnlnu ot Curront Yoar 0 0 0 Total assets (Pall X. line 16) . Total Jlabltltles (Part X. line 26). N e t assets or fund balances . Subtract l111e 21 from line 20 . ·~. 1 111 • Sign Here 9 , 100 ,000 . End or Yonr ') , 1 0 0 , \)()() . . () '.l , 1 00 , OtlO . Signatu r e Block Date 1irii.. BARl, T. l\Y ~; \·1E11.L'r ll ,.. Type or prlnl name ruirl 11110 01:" 1•1WPL'fST PrlntrTypo preparers name ,~l::!O~S~E~l:'.:'f~l.:!:l_!:N~I::;__:_:f'~>_S:C~O~'l!::'T!:._ Check 11 PTIN _L-tJ~~~~~.Q!.:!t~hfJ.:d.1JLL1:.jl..f~~!..::..1-_Ls~c~1r~-c~m~p'.'.'.1o~y~ed:J. _JP:_t(~)(~J~1J.'..''•.."'i~l6~'!_7 Paid I ______ _ __ Prcparor 1Use Only t-Fl_rn_1·_s_n_on_1_a_ ..... __B_D_0 __1l_S_l\~1_ _ L_l._P______________________-+-F'-i"rrn-'-'s;;.,,;::. El"N -'-'....--J-J_-_'J_3_f.l_l_':>.,..·~.... lf_l_ _ __ Firm's oddr 7nl/l01'1 J.?. : 39 : 1'1 PM V l2 - 7 . 12 PAGF WWP_0000300 SJC 65 i'IOt.n:Drr Wl\RE .~Oh L'HIJJJ::C'l' L T SU l ' L'CJ!-:'l' ·rnu:n· Form 990(70 12) Page l@ii!I Statement or Program Serv ice Accomplishments Check if Schedule O contains a response to any question in this Part Ill . . . . . . . . . . . . . . . . . . . . . . . . BriefJy doscrlbe the orga rnza tion's mission· 2 [2J 1\1'1'/\CHMENT 1 2 Did tho orga niza tion undertake any significan t program services during the year which were not lis ted on the . . . . . . . . . . . . . . Yes [Kl No prior Form 990 or 990-EZ? .. . . . . . . . . . , . . . . . . . . . . . . . . . If "Yes," describe these new services on Schedule 0 3 Did tho organization cease conducting, or make significa nt changes in how ll conducts, any program services? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Yes No If "Ye~." describe these changes on Schedule 0 . '1 Describe the organiza tion's program service accomplishmen ts for each or its three largest program services, as measured by expenses. Section 501 (c)(3} and 501 (c)('1) organizations are required lo report the amoun·l of grants and allocations lo others, the total expenses. and ievenue. 1f arly, for each program service reported. D D W 4a (Code. _____ )(Expenses $ _ _ _ _ _ _ including grants of$ _ _ _ _ _ _ ) (Revenue $ - - -- - -- 4b (Code· _____ )(Expenses S _ _ _ _ __ includ111g grants of$ _______ } (Revenue $ - - -- - - - - 4c (Codo: _____ )(Expenses $ _ _ _ _ _ _ including grants or$ _______ ) (Revenue$ _ _ _ _ _ _ __ 4d O ther program sorvrcos (Describe In Schedule 0 .) (Expenses$ 111cludlng grnnts of$ ) ( Revenue S 4o Total program sorvice expenses .,.. JSA Fo101 7E IOW 2 000 d ' J1:t,1 /Ll2 1• 0 //;n/~'Oltl l /. : J~J : H l'H V 1:-! - '7 . t ;! 02JJ,l llll 990 (~012) P/IG!!: .~ WWP_0000301 SJC 66 \: 11 c 11 cl 11 0 x - -;{ ,__ 11 r __:< ,__ 12a :·: ~--i-- ,__ 12b 13 14a ___ x _ x X 14b -- >: 15 ;.: 16 >: 17 x 18 - - - -x x 19 20a 20b Fonn JSA No 990 (201 ?) 2E 1021 I 000 2.35''.GM /020 'I /~ l /201 '1 1 2 : '39 : 14 l'M \/ 12 - ' /. J;~ P/\Gb l WWP_0000302 SJC 67 W_iUI IL)t; [1 'tlf1HklO I·. l'HOJ EL'.'f L 'I' ;)U['f'Ol\T TRllS T Form 990 t20 12) Page 4 - -Von --No- 21 Did the organizRtion roporl rnore than $5,000 of grants a nd other assistance to any governrne nl or organization In the United States on Part tX, colum n (A), line I? If "Yes," complete Scl1ecl11le I, Paits I one/ II. . . . . . . . . . 1-2_1--+----+--i_: _ Did the organiza tion 1eport more than $5.000 or grants and o lhe r assistance to 1ndiv1duals 1n the United S tates on Part IX. colurnn (A), hne 2? /1 ''Yos." con1pleto SclJedule I. Parts I and Ill . . . . . . . . . . . . . . . . . . . _2_2_ __ __~_;_ 22 1 23 1 Did the orgamzation answer "Yes" to Part VII, Section A. line 3. 4, o r 5 about compensa11on of lhe 24 a b c d 25 a b 26 organization's c urrent and form er o fficers. directors, trustees. key employees, and highest compensated employees? If "Yes," complete Schodulo J . . . . . . . . . . . . . . . . . . . . . . . . . . Did the organization have a tax-oxempt bond Issue with an outstanding principal amount of more than $100,000 as o f the last rlay o f the year, that was Issued afte r December 31 2002? If "Yes," answet lines 24/J x 24a through 2<1d one! complete Schec/11le J<. If "No." go to line 25 . . . . . . . . . . . . . . . . . . . . . . .. . 24b Did the orga ntzation Invest any proceeds of tax-exempt bonds beyond a temporary period exception? . . . . . . Did the o rga111zat1on maintain an escrow account o ther than a refunding escrow at any time d uring the year 24c to defease any tax-exempt bonds? . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . · l- -t -24d Did the 01ganlza11on act as an "on behalf of" Issuer 101 bonds out standing at any time dunng the yea r? . . . . . Section 501(c)(3) and 501(c)(4) organizations. Did the organiza tion engage in an excess benerit transactio n 25a . . . . . . . . ... with a disqualified person during the year? If "Yos. • complelo Sc/1eclule L. PM I ls the organization aware lhat it e ngaged in an excess benefit transaction with a disqualified pe1son 111 a prio1 year, and that the transaction has not Ileen reported o n any of the organization's ptior Fo1ms 990 or 990-EZ? 25b If "Yes. · complete Sclled11/e L, Par/ I . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . x Was a loan to or by a current or former officer. director, trustee, key employee, highly com pensated employee. o r disqualified p erson outstanding as o f the end or the organization's tax year? If "Yes." comple te Schec/11/e L, Part II . Did the organization provide a grant or other assistance to an officer. director, trustee, key employee, substantial con tributor or employee thereof. a g rant selection comm ittee m ember, or lo a 35% co ntrolled . ..... . . e ntit y or family m ember of any of these persons? Ii "Yes," comple /o Sc/led11/e L, Part Ill . W as the o rganization a party to a business lransaclion with o ne of the following pa rties (see Schedu le L, Part IV mst1uc t1ons for ap plicable liltng lhresholds, cond ilions, and exceptions). 27 28 23 a A curre nt or lormer officer, d irector . trustee. or key employee? If "Yes." co111plete Scl1od11le L, P11rt IV . . . . . A family member o f a current or former officer, d irector, trustee , or key e mployee? If "Yes," complete Scltodu/e L, Part IV . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . • . . . . . x 26 ___, _ x 27 2Ba ,,\ 28b x b c 29 30 3·1 An ent ity of which a c urrent or former officer, dtrector. trustee, or key employee (or a fam ily member thereof) was an offlc01. dtrector. l rus tee. or direct or tndtrect owner? If "Yos." complete Sclied11/e L, Pon IV . . . . ... Did the organizallon receive more than $25,000 in non-cash contributio ns? If "Yes," comµlete Schodule M Did the o rga11izat1011 receive c ont ributions of art, historical treasures. or o ther sim ila r assets , or qualified co nservation contributions? If "Yes," complete Scl1odule M . . . . . . . . . . . . . . . . . . .. . .. . Did the orgarnza tlon liquida te, term mate. or dissolve and cease ope ra11ons? If "Yes." complete Scl1edulo N, Part I . . . . . . 32 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28c ~·: 29 >: 30 x 31 x 32 ,,.. Did tho organizalion sell. exchange dispose of, or transfer more than 25% of its net assets? If "Yes," r.omplele Scliedule N, Purl II. . . . . . . . . . . . . . . . . . . . . . . . . . .... . . . .......... . 33 Did the o rg aniza tion own 100% of an entity disregarded as separate from the orga111zat1on under Regulations sections 30 t 770 I ·2 and 301 .7701- 3? lf'Yes,"complete Scl1edule R, Pa11 I . . . . . . . . . . . . . . . . . . 33 34 Was the organization related to any tax-exempt o r laxable e ntity? If "Yes," complete Schedule R, Part II, Ill, or IV, ancl Pa11 V, line 1 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34 35 a Did tho orgarnwtlo n have a controlled entity w1lhin the meamng o f section 512(b )(13J? . . . . . . . . . ~ b If "Yes" to line 35a. did the organization rece ive a ny payment from or engage In a ny transaction with a 36 37 ;~ - -- i~ co ntrolled en tity within the m eaning of section 5 12(b)( 13)? If "Yes." complete Sc/1edule R, Part V, lino 2 . . . . . 35b Sectio n 501(c)(3) organizations. Did the orga111zation make any tra nsfers to an exempt non-charitable related organization? If "Yes," co1nplele Schedule R. Part V, line 2 . . . . . . . . . . . . . . . . . . . . . . . . _3'""6_ 1_-+-_z_ Did the orga111zation co nduct more than 5% of its aclivit1es through an entity that is not a related organiza tion and ti1al 1s treated as a partnership for federal income tax purposes? If "Yes." comrit1Jte Schedule R. PCl/t VI 38 >: . . . . . . . . . . . . . . . . . . . . . . . , . . . . . , . . , . . Did tho o rgan iz<1t1on comple te Schedule 0 and provide exp la nations in Schedule 0 for Pa rt VI, lines 11 b and 19? Noto, All Form 990 file rs are reoutred lo comole le Sched ule 0 . . . . . . . . . . . . . . . . . . . r-3_7_ 1----+--;.:_,_ 38 Form 990 (70 12) JGA ~( I OJO 1 00 0 1 2 : l ' 1 : I c Did the orgarnzalion comply with backup withholding rules for reportable paymenls to vendors and 1c rcporlable gaming (gambling) winnings lo prize winners?. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2a Enter the number or employees reported on Form W-3. Transm1ttal of Wage and Tax j j Stalemenls. flied for Ille calendar year ending with or within lhe year covered by this return . ~2_ a~-----'--T n - rcr,fi·,.,·1 P ~ 7 Compensation of Officers , Directors, Trustees, Key Employees, Highost Compensated Employees, and lndepondont Contractors Check 1r SchedL1le 0 contains a response to any question in this Part VII . . . . . . . . . . . . . Section A. . . 0 Officers, Dire ctors , Trustees , Koy Employoos , and Hlnhest Compensated Employees 1 a Complete this table for all persons required to be listed Report compensation for the calendar year end ing with or w1 th1n the organization's tax year. • List all of the organization's current o fficers, directors, trus tees (whe the r individuals or orga niza tions). regardless o f amount of compens ation Enter -0- in columns (D), (E), and (F) if no compensation was paid. • List all o f !he org anization's c urrent key employees, If any. See Instructions for oefinitlon of "key employee." • Lis i !he orga111zatlon's fi ve current highest compens ated employees (other tha n an officer, director. trus lce, or key em ployee) w ho rece ived repo rlab le com pensa tion ( Box 5 of Form W -2 and/or Box 7 of Form 1099- MISC ) o f m ore lha11 $ I 00, 0 00 from the o rganiza tion and any related organizations. • List all of lhe organization's former o fficers, key employees, and highest compensated em p loyees who rece ived more than $ 100 .000 of reportable compensa tion from the organiza tion and any related organizoticns. • List all of tho organiza tion's former directors or trustees that received , in the capacity as a former director or trustee of the organiza tion. more than $ t 0,000 o f reportable compensation from the organization and any rela led organizations List persons in the following order: individual compensated em ployees: and forme r s uch persons. 0 Check this box Ir neither Lile trustees or directors: ins t1tut1onal trustees: o fficers, key em ployees , h ighest orga nization nor any related orga niza tion compensated any c urrent officer. director, or trus1ee (C) Poslllon (A) (B) Name and Tille Average hours per week ''" ' '"~ ( '" &. ------------------------------------------ ---------------------------------- ---------------------------------------- ------- ---------------------------------- ------- ---------------------------------- ------- ... ,_______ _______,________ (_) ~ 1 1> Su b-to tal _ _ _ __ _ _ (',1 --_ _ _ _ _ _ <1 c Tot a l fro m c o 11tln uatl o11 s heets to Par t VII. Seclio11 A cl Tot a l (a cid ll11es 1 b and ·Jc ) . . • . . • • . . • . . . • • • 1 l1 1 II'- O O 2 Total num ber o f ind ivid uals ( including b ut not limited to those lis ted above) who received m ore than $ 100.000 o f reportable com pensa tion l rom the o rg anizatio n • O 3 Did the o rganization list any f ormer o ffice r, d irector, or trustee. key emp;oyee. or hig hest com pe nsated emp loyee on line 1a? If "Yes, " complete Sclledule J for sue/I mdiv1dua/ . .. Yes .. .. No 3 >'. .. 4 }; Dtd any person listed on line 1a rece ive or accrue compe nsatio n lrom a ny unr elalecl o rganizatio n or lnd 1v1d ual fo r services rende red lo the o rg a nization? If "Yes." comp lete Sc/Jed11/e J for sue/I per:;on .. Sectio n B. tndependo nl Co ntra ctors 5 :< 4 For any tndivid ual ltsted o n line 1 a. IS lhe sum of reportable comµ ensa l ion a nd ot her compe nsation from t he orga n1zat1on and rotated orga niza tions grea ter than $15 0,0 00 7 If "Yes." complete Sc/lod11/o J for Sf/Cll inc/iviciuai . 5 1 2 Complete this tab le for your five hig hest compensated indepe ndent contractors t hat received m o re than $100.000 o l comp ensalto n from the o rganiza tion. Report com pe nsa tion for the c alendar year e nding wit h or w ilhin the organiza tion's l ax year. (A) (8 ) (CJ Na111e and business address Descrlpt1or1 or services Compcnsalion Total num ber of independen t co ntra ctors (Including b ut no t lim ited to those listed above) who received () more than $1 00,000 in com pensation from the org aniza tion • Jl-A ~EI 0~·6 Form 3 000 .~<~. -1r~M 702r• i/21/.!0111 i.' : lf'1 : I •1 PM V 12- '/ . l ~ O:>J 11l'3A 9 90 (20 12) i'/\G!".; 8 WWP_0000307 SJC 72 Form 900 (201 2) lirilfllli ~11\RRTO R l'IOllN DF:r• PRO,JF:C1 l)J' :111PJ 'OH'l' I'HU!~'!' Pogo Statomont of Revenue .n Cl1eck if Scl1edule 0 contains a response to any question in this Part VI II. (A) (8) {C) Totnl revenue Rolotnd 01 Unrelated Rovonuo o~ompl llusinoss lunctlon rovcnve ravenua oxcloded rrom tru. under socllons !l l 2, 513. or5 14 ' JHl 1a Federated campaigns 10 Cl 0 IJ Membership dues 1 IJ cc I? :> -~ ~N Cl::: :J On c events (not Including S > C1> 0:: See Part IV. lino 18 C1> .... Net gain or (loss) 'I Gross income from rundr a1sing of contributions reported on hne 1c). ...C1> b 5 c 911 b c 10a h c n Less: direct oxpcnsos Nel 1nc:onrn o r (loss) from rundralsing events . " Gross Income from oomlng activities See Part IV, line 19 OJ . ~ ( n Less: direct expenses b Net income or (loss) from gaming achv111es . Gross sales of Inventory, returns and allowances '" . ~ less a .... Less: cost or goods sold . b Net Income or (loss) rrom sates of Inventory , Misccll'1neous Revenue Bus lnoss Codo (o 11 (I b c d All other revenue 0 Total. Add lines 1 ta-1 Id Total rovonuo. See Instructions 12 .~ . ~ 1, f 1·111 1f\ ' ' Form 990 (20 12 ) JS.II 2~ 1051 ' 000 2J5J(;M ·102 0 '/ /2 1 /2 014 0 23 ~1Jfl(l WWP_0000308 SJC 73 Form 990 (201 2) iiltfilf!j \<,'Ull lll •l·:r• WAhr- l (J R ['1{(1.J E•:'I' L'f' :mrrORT .l"l- Li'1!1 8 111 I Tflll:~1· Pnge Soc/ion 501 (c)(J) ancl 50 I (c)(4) organizations m11st complete all columns. All ot11er orga111zatio11 s must complete column (A) Check If Sch o dulo 0 con t ains a ro s p onso to any question in this Part IX . Do 1101in cludo nm o unts repo rtod on lines 6b, 7b, Bb, 9b, n11d 1Ob of Port VIII. (8) Program service l'.!Jtpenses (A) Tol al expenses I I (Cl (0) Mono9ernc111 and ocncrnl cxpt?nsos Funuralslno oxponsos Gran1s and ol hCr t\Ss1!"ita11ce l o governments and 1 OrlJanlrnhun~ ( In lliu Uniled Stales Sec Pan IV, line 21 Grnrot s and o lher 11ssrslance to lndovrduals 1n 2 ( 1'1o U nited St~1es Soo Part IV, line 22 . 3 Gran1s and 01l1er assistance to governmen1s. urganizalrons, and rndlvi cl uals o utside Oro Unrted Stales See Port IV, lines 15 and 16, ( 4 B ene fit s pard l o or for m embers . !.' 5 Cornpen saloor1 Of current o f11cers, directors, ' tiustees. and key empl oyees Compen5alton 001 6 PCl60!16 (OS lncludt') c111ployAr conlrll>uuon&) , ( O ther crnployeu bc11cfi t~ ( (' Payroll taYes . f' ees lor scr vie.cs (11011-employeos) a Management b Legal ( ( c Acco1Jntlng (. d l. obbyrng (' e Profassi.. cec-d1 IO'Y, of ho• 2:). r olwr.n (At .1mou111 111'\ lin e I ( iu rop,111u•.J on S.Choill1~e 0 ). 12 Advertising and prornotron . ( 13 Office expen ses r 14 15 lnforrnalron teo:.hnol ogy . ( Royaltrcs. (' 1G Occupancy (I 17 Travel (, 18 Payr11enl3 of travel or en1erta111ment expenses for any redcr;il, stale. or local public ( official~ 19 Conferences. conventions and meetings f 20 Interest ( 21 Paynienls to affrh ates . 0 22 23 Dcproc1at1on . doplo t1 on, a11d arnortizatio 11 c Insurance 24 0 11101 nxµcnscs l llcrnlze expenses 1101 covered al>ovo cllst ml sccllonoous c~penscs in hnc 2 •1 0 , II I lrno 2do nmounl oxc.ccds 10% or hne 25, column (I\) M10unl llsl linn 24u P.8·720) , D ( ' J~A F01m ..!E 1052 I 000 L2 : 3 ~1 : l 1! l'i'i V l 990 (2012) :! - 7 . l 1! WWP_0000309 SJC 74 \'iOlJM()f.f) W\RRTOR PRO ff~C'T' ur :mPJ>Ol\'J' 'l'RW}'J' Form 990 (20 12) l::l:T•• ·· Pugo Ct1eck if Schedule 0 contains a response to anv oueslion in this Part X .. .' . . ' . . .. . . I I (A) Beginning of year 1 2 3 4 6 6 tJCll 7 Ill Ill 0 1m 9 90 (20 12) JSA 1E 1053 < 000 ?.3'.>IGM 'I0 ?. 11 '7/ 2 10014 12 : 39 : 1'l PM I/ l ?-7 . ! ). 0~3Jlj8fl !'l\GE: 1 l WWP_0000310 SJC 75 l·}- t) 1 1 1 1IJ', ( •, f orm 9!JO 1?01 7) 1@131 1 2 3 I\ 5 6 7 8 9 1O Page Reconci liati on of Net Assets Check 11 Schedule 0 contains a res 12 uestion in this Part XI . 1 ola l revenue (m 11st equal Par I VIII, column (/\). line t 2) To l al expenses (mus t equal Part IX. column (A). line 25) .. Heven11e less expenses. Subtract line 2 from hne I • . • • • Net asse ts or fund balances at beginning of year (m ust equal Pall X. line 33, column (A)) Nel unrealized ga111s (losses) on 11westments Donated stHvices and use of facilities lrwosllnonl expenses . . .. . . . . . . . . . Prior period adjustments . . . . . . . . . . . Other changes in net asse ts or fund balnnces (explain in Schedule 0) . Not assets or fund balances al end of year Com bine lines 3 tluough 9 (must equal Pai l X hnc 33 column 0 . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . .. .. . . 1 t't , ) Ill! , i I\) . I) _ 2_ 3 t , I IJO, 0\ Hl . -~·'--<~~~~~~~~') n 5 _G_,_~~~~~~~O 7 () 8 I) 9 I.• 10 . , l 011 , 1)1)\) . Financial Statements and Reporting Check if Schedule 0 contains a response to any question in tllis Part XII 0 GJ 0 Separate basis D Consolldaled basis D Yes 0 /\cco unhng m olhod used lo prepare the Form 990. Cash Accrual Other --If tho orga 111za 11011 changed its method of accounting from a prior year or checked "Other," expl;::i111 In Sched ulo 0 2a W ere Ille 01gan1zahon's linanc1a l slatem ents compiled or reviewed by an independent accountant? . . .. If "Vos" chock a box below to indicate whethe r tho f111ancial statem ents for the year we re compiled or reviewed on a separa le basis. consolidated basis or both. No 2a ;; Both consolidated and separate basts b Were the organiw tion's financial statemonl s audited by an independent accountant? . . . . . . . . . . . . . . 2b i'. If "Yes," check a box bolow lo indicate whel hor the fina11cial slalern enls for lhe year we re audlled on a s~ara l e I basis. consolidated basis, or both ' Consolidated basis J Scpaia te basis W D Both consolidated and separate basis c If "Yes" to line 2a or 2b. does lhe orga 111zalion have a co111m1llee l hal assumes responsibility for ove1s ighl of lhe audit. reviow. or co mpilation of lls financial sl alemonts ond selection of an lndependonl nccounlant? If the orga mza11on changed eilher ils overs1ghl process or selection process during the la x year. explain In Schedule 0 3a As a result of a federal awa1d. was lhe orga111zation required lo undergo an aud1I or audits as sot fort h in the Single A11d 1l Act and OMB Circular A· I 33? . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . • b If "Yes," did the orga nization undergo the required audit or audits? If the organizal1on did not underg o the re< u1recl audit or audits. ex la111 wh 111 Schedule 0 and describe on ste s taken to under o such auchts 2c i: 3a i: 3b FOJm ) "' h .H ")( ).'I> 7 /;:I I ~' \I I4 I / : l ( I : l •i l'H "! I ,' - I . I ;~ 990 (7012) 1'/\ l.iF: 1,: WWP_0000311 SJC 76 SCHEDULE A Public Charity Status and Public Support (Form 990 o r 990-EZJ complolo If tho orga nization Is n section !i01(c)(3) organization or n section 4947(0)(1) nonexempt chorltablo trust. Dcpm1111er11 of thu Trcunury 1n1ornn1Rovonuo smvlce ._ Attach to Form 990 or Form 990-EZ. ._ Seo soparato Instructions. OMO No. 1545·0047 ~@ 12 Ooon to Public lnspocllon Nnrno of tho organ lzotlon Employer Identification number l·iOlJNOE".O 1tll\f\RTOR i'f,0,1EC1' LT !JUPPOHT TRUS'I' Reason for Publi c Chari Status All or anizations must corn See instructions. The ~ranization is not a priva te foundation because 11 1s: (For lines 1 th rough 11, checK only one box.) 1 /\ cl!urch, convention of churches, or associa tion of churches described 1n soctlon 170(b)(1)(A)(i). · 2 A school described 1n section 170(h)(1)(A)(tl). (Attach Schedule E.) · 3 A hospital or a cooperative hospital service organization described in section 170(b)(1)(A)(ill). 4 A medical research organization operated 111 con1unction with a hospital described In section 170(b)(1)(A)(lll). Cnter the hospital's name. city, and stale: 5 An organization operated for th~- benefit-or- ii coliege -or -u~1~e~s7'y o~v-ned-or-opera-tedby "°a-governn~ental~1lil scribed I n section 170(b)(1 )(A)(lv). (Com plete Part II.) 6 A federal. state, or local government or governmental unit described In section 170(b)( 1)(A)(v). 7 [£] An organiza tion that normally receives a substantial part of Its support from a governmen tal unit or from tho general public described in sectio n 170(b)(1 )(A)(vi). (Complete Part Ii.) 6 A community trust described In sec tion 170(b)(1)(A)(vl) . (Complete Part Ii ) 9 An organization that normally receives: (1) more than 3311a'Y.1of !i s support from c ontrlbl1llons. membership fees. and gross receipts from aclivitios related to its exempt functions - subject to certain exceptions, and (2) no more than 33113% of its support from gross Investment income and unrelated business taxable Income (less section 51 1 tax) from businesses acquired by the organization alter June 30, 1975. See soctton 509(a)(2). (Complete Part Iii.) An organizauo n organized and operated exclusively to test for public safety. See soc lion 609(a)(4). 10 11 An organization organized and operated exclusively for the bonofll of, to pe1rorm the functions of. or to carry out the purposes or one or more publicly supported organizations described in section 509(a)( 1) or section 509(a)(2). See section 609(a)(3). Chock the box th at describes tl ~pe or supporting organiza tion and complete lines 11 e through1 l h. a Type I b Type II c LJ Type Ill-Functionally integrated d Type Ill-Non-functionally integrated e By checking this box, I certify that the organiza tion is not co ntrolled directly or indirectly by one or moro d1squalifted pe rsons other than foundation managers and other than one or more publicly supported organizations described 1n section 509(a)(1) or section 509(a)(2). I( the organization received a writlen determination from the IRS that 1t is a Type I. Type II, or Type Ill supporting D do D 0 D D 0 0 D D D 0 . . . . . . . organilatlon, check this box . . . . , . . . . , • . . . . . . . . . . . . . . . . . . . . . . . . . . Since August 17, 2006, has the organization accep ted any girt or contribution from any of the following persons? Yoa No (I) A pe rson who directly or Indirectly co ntrols. either alone or toge ther with persons described in (ii) 110(1) and (iii) below, the governing body of the supported organization? 1lo(ll) (Ii) A family member of a person described in (i) above? . . . . . . . 11g(lll) (Ill) A 35% controlled entity of a person described in (i) or (ii) above? h Provide the followln~ Information about the supported organlzation(s). (I) Name of supported (ll)EIN (v) DU.I you nottty (vi) Is Illa (vii) Amount of mone1ory (i ~ Type of oroarnz.atton Pvl 1s 111e crgnnluuoo Ir organizalion thn orgnnrzal1011 orgmuzatron 1n ( escrlbcd on lines 1·9 support cot JI) '"'•d n above or IRC section m col (I) of col (I) oro111117.ed vour oo\ernino (soc lnstrnctlons)) your 011ppo11? m Iha US ? ~-· ..... 7 Vos Vos No No Yoe No o (A) (B) (C) (0) (E) Total For Pnporwork Reduction Act Notico, see tho Instructions for F orrn 990 or 990-EZ. Schedule A (Form 990 or 990-EZ) 2012 JSA 2Fl?10 I 000 23'\JGM 7(1.W 7/21/20l tl WWP_0000312 SJC 77 Schodulo A (fo1m 090 or 9!JO·EZ12012 IQffii!i Sec tio n Page 2 Support Schedule for Organizations Described In Sections 170(b)(1 )(A)(iv) and 170(b)(1 )(A)(vi) (Complete only if you checked the box on line 5, 7, or 8 of Part I or if !lie organization failed to qualify under Part Iii. If the organization fails to qualify under the tests listed bel ow. please complete Part Ill. ) A. Publi c Support Calondar year (or flscol yoar IJoginnlng in) 1 (a) 2008 "" Girts, grants, con1nbut1ons. anll membership fees received (Do not include any ''unusual grants.") .. (bl 2009 ,, .. 2 T ID< IOVC11UOS IQv1ed 101 the organization's benelll and elthor paid to or expended 011 Its bohulf • 3 l he valuo of services or fac11111es furnished by a governrnontal uml to lhe organization w1 1hout charge . 4 Totnl. Add lines 1 through 3 . ( Q D 1 7a 10%-fact s-and-c lrc umst ances t es t - 2 01 2. If the organization did not c he ck a box on line 13. 16a, or 16b, ond line 14 is 10'X, 0 1 more. and 1f the organization meets the "facts-a nd·c1rcu111stances" test, check this box and s t op ho ro. Explain in Pa rt IV how tho organization meets the "facts-and-circumstances" lest. The o rganiza tio n qualifies as a publicly suppo rted organization . . . . . . . . . . . . • . . . . . . . . . . . . • . . . . , , . • . . . . • . . . . . . . . . . . . . . . . . . . . .. Iiib 1 0%-f act s-a nd-c lrc umst;:m ces t est - 2011 . If the organization did not check a box on lme 13, 16a, 16b, or 17a, and line D t 5 1s 10% or m o re, and if the orga nization meets the " facts·and-circumsiances" lest. chock lh1s box and s l o p hero. Explain 111 Part IV how lhe orga nizalion meets the "facts-and-circumstances" test. The orgarnza tion qualifies as a publicly 1B D . . .,.. D s upporte d organiza tion .. . . . . . . . .. . . .. . . . . . . . . . . . . . . . . . . . . . . . . . , . . . . . .. . . . . . . . .,.. Pr lval o foundatio n. If tho org anization did not check a box on line 13, 16 a. 16b, 17a. or 17b , che ck this box and see in s truc tions .. . .• . . . . • . . . . . . . ••. • .. . . . . . . . . , . . . . . . . . . . . . . . . . . . . . . , . . . . . Sc hoduto A (Form 000 or 090·EZ) 2012 JSI\ ~t 1220 I 000 2 3',Jr;M 1o;w 7/ 2: 1 ~ 0 l4 J ;• : 1 •1 : L '1 PM \I 1 2 - '/ . 1 2 Pf\Gl·.: l tJ WWP_0000313 SJC 78 WOONPSD VIAlilU OK l' H0,1 8 C'l' L 'I' f.lJPP O l~'l' T IUl:~T Sc11odulo A (Form 990 or 990·E Z) 2012 Pn110 3 1@1!11 Support Sc hodule for Organizations Described in Section 509(a)(2) (Complete only if you checked the box on line 9 of Part I or if the organization failed to qualify under Part II. If the org anization fails to qualify under the tests listed below, please complete Part II.) Secti on A. Public Suooort Colondar your (or llscal yoar b oginnlng In) ~ (a) 2008 (b} 200!> (11) 2008 (b) 2009 (C ) 201 0 (cl) 20 11 (I) l o tal (e) :>O 1:> Cina, granis, con1rlbullons. und m em bership rees 1 rocolve Amou111s lnclmfod 0 11 llnos 2 anc:l 3 rccctvod from other than disquoJ,fied por~on s fhnt exceod the groa1er or SS, 000 or t% or tho 0111011111 on llnn 13 tor tho yoor .. c Add l lnos ?a 011d 7b . Public oupport (Subtract line 7c from 8 .. line 6 l . Section B. Total Sueport C11 lo11ctor year (or tlscol yonr boglnnlng in) ~ .. (c) 20 10 (cl) 2011 (o) 20 12 (I) Total .. Amounts from line G. 1011 Gross Incom e from interest. dividends. payments received on securities loans. rent s, royatues and rncome fr om s1m1lar sources . 9 . .. .. b Unrola ted bu siness taxable incom e (less section 5 11 from taxes) acquired after June 30. 1 975 businesses .. c Add lines 10a and I Ol> ... 11 Nel Incom e from unrelated business activities nol i ncluded 111 line 10b, whether or n ol l he bus1nesr. Is regularly carried on 12 OlhOr lncomo. Oo no t i n clude gain or loss from tho sale of capital asso1s (Exploln In Part IV.) 13 Total s upport. (Add lines 9 , 1oc. 11. 14 Firs t flvo yonrs. If the Form 9!'10 Is for the or ganization's firs t. socond. thlfd, fourth Md1 2) , .. or fifth tax year as a sectron 50 1(c)(3) orgo11lzollon, c hock this box and st op h ero • . • . . . • • • • . • . Section c. Com utation of Public Su . ~ [] ort Porconta e 15 Public suppoll percentage tor 20 12 (hn e 8, c olumn (I) diVlded by lino 13, column (I)). 16 % 16 Public support percentage from 20 11 Schedule A. Pan Ill. line 15 • • • • • • . • . • 16 % 17 % 18 'l'o Section D. Com utatlon of Investment Income Percenta e 17 Inves tment Income p ercen l ago tor 20 1 2 ( line 10c, column (I) di vided by lino 13 . column (I)) • 18 11wos1111ont Inc om e p ercentage from 201 1 Schedule A. Parl Ill, line 17 . . . . . . . . . •. ...... ... ~-~---------- 19 a 33 Ill% s upport tos ts • 2012 . If !he organization did not ch eck the box on line 14, and hn e 15 1s m ore than 33 113 %. and l111e ~ 17 15 no t m ore than 33 113%, c heck this box and stop horo. Iha organization qualifies as a publicly supported organ1zat1on h 33 113 % support tos ts . 20 11 . If the organization did not check a b o x on line 18 Is not m ore than 33 1/3 %. check this box and s to p h ero. The organization qualrf1es as a publicly supported organ w1 t1011 20 D line I it or line 19a. an d line 16 is rnoro tllon 33113 %, and lifl> P r lvnto foundot lon. ti the or anizatlon did n o t check a IJox on lino ·14 , 19a, or I 9b. check this box an cl see Ins truc tion!; ~ JSA Sc hodul o A (Form 090 or 990.EZ) 2012 2El22 1 I 000 l.J')JGM 7 0 2 1) 70 l /?.O J 11 l 2 : 3 9 : I 4 l 'M V l 2 - 7 . 1 2 0~!3J 1I trn Pl\Gl·; I r, WWP_0000314 SJC 79 Schodulc A (Fornr 990 or 990·EZ) 20 12 IQfthN Paga 4 Supplemental Information. Complete this part to provide lhe explanations required by Part II , line 1O; Part II. line 17a or 1 ?b; and Part Ill, line 12. Also complete this part for any additional information. (See instructions). Schollulo A (Form 090 or 990·EZ) 201 2 JS•\ ?EI~?,~ I OO(I 12 : 3 '' : l 4 f'M V I. !. - 7 . 1 2 WWP_0000315 SJC 80 SCHEDULE D (Form 990) OMB No 11145-0047 Supplemental Financial Statements ~@ 12 .,._Complete If the organization answered "Yos," to Form 990 , Part IV, line 6, 7, 8, 9, 10, 11 a, 11b, 11c, 11d, 11e, 11f, 12a, o r 12b. ,. Attac h to Form 99 0. ,... See so Jarate Instruct ions. Oupamnon t or the Tt'jfl ~'dJ W()lJNDf. D W/\RHTOH PrW cTEC'I' LT Slll' l'OH'I' T RUST Organizations Maintaining Donor Advised Funds or Other Similar Funds or Accounts. Complete If the organization answered "Yes" to Form 990, Part IV. line 6. (b) Funds ;;ind other nccounls (a) Donor advised funds . . ... . . Total number at end of year Aggrega te contributions lo (during year) Aggregate grants from (during year) . Aggrega te value al ond of year . . . . . . Did the organ iza tion inform all donors and donor advisors in writing that the assets held In donor advised flinds are the organiza tion's property, subject to the organization's exclusive legal control? . . . . . . . . . . . Did the org anization inform all grantees, donors, and donor advisors in writ ing tha l grant fLmds can be used only for charitable purposes and not for the benefit of the donor or donor advisor, or for any other Pllrpose co nferrin im ermlssible rlvate be nefit? . . . . . • . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 2 3 4 5 6 D Yes D No D Yos 0 No Conservation Easements. Com lete if the or anization answered "Yes" to Form 990, Part IV, line 7. ir ose(s) of conse rva tion ease ments held by the organization (chock all that apply). § D D Prese1va tion of land for pllblic l!Se (e .g., recrea llon or edL1catlon) Preservation of an h1storlcally Important land area Pro1ecllon of na tu ral habitat Preservation of a certified historic structure · Preservation of open space Complete Jin es 2a th rough 2d If the organization held a qualified conservation contribution lr1 the form or a conservation easement on the last day or the tax year. Ho ld at tho E n d of tho Tax Your 2 a b c d 3 2A To tal number or co nservation easements . . . . . . . . . . . . . . . . . . .• . . . 2h Total acreage restricted by conserva tion easeme nts . . ....... . . . . . . 2c Number of conserva tion easements on a certified historic stnicture included in (a). Number or conservation easeme nts Included In (c) acquired after 8/17/06, and not on a 2d historic structure listed In the National Register . . . . . , . . . . .. , . . . . . , . . . . Number or conservation easements modified, transferred. released, extinguishe d, or termina ted by the organization during the 6 tax year .,.. - -- -- - --- - --- -· - -Number or states where property subject to conservation easement is located ,. ---- - - - --------- Does the orga nization have a written policy regarding the periodic monitoring , Inspection , handling of viola tions, and enforcemonl of the co nservation easements it holds? . . . . . . . . . . , . . . . . . . . . . . . Yes Staff and volunteer hours devoted lo monitoring, inspecting, and enforcing co nservation easements during the year 7 Amount of expens es lncllrred 111 monitoring. Inspecting , and enforcing conservation easements during the year B Does each conservation easemen t reported on line 2(d) above sa tisfy the requirements or section 170(11)(4)(8) 4 5 D D No D D No .... ------- -- - ------- .... $ --- - -- - ---- - -- - -- (I) and sect1qn 170(h)(4)(B)(ii)? . . . . . . . .. . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. Yes In Part XIII, describe how the orga nization reports con servation easements In its reve nue and e>JOllll llJ::ll ~·Jll H i'. !OH J'f.:( 1,J F't :T J.T SUJ> l 'O lr:· 'l'J.:I J ~1T PntJll Sr.llo I 000 ,".\!./ V,~: /0,! I > I/ ;· 1 /;~U l 11 L:: : 3<1 : l .S'iHr., l HJl{l·l 'i'HI l'/\H'I' If I, .i P.V'l TUN Ii , lli"\h<'T,/\Y:; \'IF./\l,TH 'l'H ll S'l'l'.;t:::_; ~ ()f \ M 1·111, ANNll/\L!." , ~·/\RT '1'Hh 'Ol"1 ,,,.. ':"flf'. i\ Vl , I.I NI·: 11 (IJ . ~ . ) , ~Jl::C 'l' l Pl l Ll , i'i . 1\ . 1 RF'VTf,\·1:-" Tiil·: l"Tl\NPS 'J'llC: T HU:..i'l' TN f)Rl•F:R 'I\ L~C TRil~T1·:1·; ' :' POLI CY , '1" 11 /\'J' f\ ("COMl'Ll !iil rn:r-. IT H I\ ~' RE./\HCL/\'l::: i·ff.AJ.'1 11 1'!{U!'1'!::E., t"11·;·11 '!'I ll·, /\;~~; J ,; l'/1l•h "f. OF I Tr> . 1.1111:\ 111 1.:.i . 1u::vu;w~:D vlOll N(lEll 'i/AP.IUOP. £T COtlf:JSTJ·:il'J' t.l :. TI! i']'!; f11T1i'l'f.f1 'l'l ll : T1.;1•:;·n .r-. REVlEWF. D T11 1.. :_:/\Ml:: l\Nu 111'1.'l{OV t: r; r-e>r Ff i. IML· . For Privacy Act ontl Paperwork Reductio n A ct Notlco, s ec tho Instructions for Form 990 or 990-EZ. :r JSI\ 1i}1 l 1 1!'0!1 (II . S . ) N . 7\ . I Ml.•J·: l t:MDl:..NT l\C' 'tllJN'l'/1N'l' , PF(),IJ·:l"I' f'!{ r:[' /\Hl·,l) T ii i·, ?i::'l'U Pl! /\ND 1· ~ Schedulo 0 (Form 990 or 990-EZ) (201 2) onu '.l~ hiM ·102 u 7/:?l/?\li ti 1 ;> : l q : I ti !•M I/ l 2- 7 . I .~ o n_HCJ8 WWP_0000321 SJC 86 Schedule 0 (Form 990 orfJUD·EZJ 201 2 Pll{]O Nmnc of lllo organization 3"f-6SS8:1 ·~ WOUNDC:l.r \v/\RR TOR P!{(),J8C'l' L'l' SUPPORT '!'HUST !\.'.tT~U Hl~NT TO l'hOVJ.J)E 'l'llE 2 Emptoyor lclonllflcntlon 11111nbor l~CONOMlC WL)lJNf)l.::l) W/\l~RIOH~ MEN!S F'UH ~;ul:'l'OR'J'IVI:: ::F:RVJCr·:~; - . l -- --.::==:---:~-· '!'Cl M/\Hl'l'/\Hl LN r;1~'J"l' INGS '!' II /\'!' /\R F: AS lNLJEPENm~ N'I' /1.S P(J!.).;JllLJo:, l\Nl• 'T'O i\~ ; s I S'I' ~I I.1'fl LONG TF:RM C/l.!UO: NSS[)~; l N '!'HF: F.VF:N'J' OF Tim 't/F1RH TOH . s S l~f'/\Ri\'l 'ION FROM 111. :J OR lll-:R CllRRF:N'T' CAR8G TVER , Cll.RF'.GIVER ' :3 Dlrn'lf!, l.llSABH.l"TY , OH OT!! ER REASONS . THP. '!'HUST \'JILL M/\KF. u n;TrnBUT ! ON:.; 'l'U !'i{OVfDJo: F'OH TI W Nt:t:DS OF !J.lSA[lTJ,J'rl ES 'l'i! EY Hl\Vl:. SERV 1C8 rN 1·m: TIRME:l> A~rER AP.~ r Jo: M Dt:R 11 , BY REMiON OF T ll 8 :;Uffl~RED FOHCE~S \'Ji\RRfOR~ , g1-:LA'l'lN(; TO T HE TN 1'118 COURSE OF , OR l\S l\ RE~i UL'l' or~ , O r' Tl!P. UNI'PF,11 S'J'A'l'ED m · i\MF:RI CA ON OR 2 001 . Scflnrtulo 0 (Form 990 or 990-EZ) 2012 JS/I lE 1218 I 000 2 1~:1GM '/()/. I J 1/21/2011! 12 : 3 9 : 1'l Pt·I V l2-7. lL I '!\(if. ;• J WWP_0000322 SJC 87 ;·;:·1:.t!::}s:· \·-· ;..=--::: :c;.~ SCHEDULER (Form 990) C-e-:a.·tr9~1 ~, ;..~: :::,:-T :.:r S'J ~ :-o~ : ; :;.:i:;,-:- ~7 - €:=:::?-: OMB Related Organizations and Unrelated Partnerships jll> h'l·Ql'l'tal =t."~e ~u Attach to Form 990. jll> AAA-MA A See separate instructions. Name of tne cr;on:a·re,, w:~J~::.s: mm 1: .:5--00.:; ~'.~ 12 II>- Complete i f t he organization answered "Yes- to Form 990, Part IV , hne 33, l4. 35. 36. or 37. of tne ....ri!~f ~lo. EmDlcyer hlentification number ~-J?.F.?. _ 'J:= !=? 1~ r::·:::' ~: a·.:~?CP: :--"":" - Ec5.~_5-., : ':'?"''3': Identification of Disregarded Entities (Complete if the organization answered "Yes"' to Form 990, Part N line 33.) (a) Mame (b ) Pnmary ac:t;vny adcress and E lr-1 [If "l'P• cabfeJ of OISregan:!ed enlJty _Ul ___ __ ______________________ ________ _________ __ __ ____ ___ J I ~' (e) Eno-Of-year assets (d) Total income (c) Leg al c!. cm . ic:le. (51.ate lfl Direct ccntr oll,ng 'o!ejg!'!_~~~¥1_) entrt; I _ec:1.G11 Public cl'lanty sta1us D1rec1 controUlng Se<:ticn 5 t 2 (b)\ 131 (If se<:ucn 50 1(c)(3)) en1rty or fcr21gn cou ntry ) contro lled ent:ty> Yes I - ~~ = ~~22i·~·i __ :~:~·.;t::-.";,:_t ~. I \ '"E 'ISFAil '": 1: r..;. _111 __ ________________________________ ____ ______ _ .~ss : s - 50 : ( 1: ) 3 :·Cl v:~ 2 1,..,...T -·"' D , 1.,... l '- - . ' " .:l;\C 11 . . .. No I >: _(} l _________________ ___ ______ ________ _ _ ________ _ -~l _____ ______ _______ ___ _____ __________ _______ _ J.?l ______________________ ____ __________________ _ _@l ___________ __ __ __________ ____ __ ____ __ __ _____ J WWP_0000323 I I (7) ----------------------- L _ _ ______________________] 1 For Paperwork Reduction Act Notice. s ee the Instructions for Form 990. I I l i Sch edule R (Form 990) 2012 JS,..; 2E. 1207 1.XC .:_2~.:;·:;J-: 702D 7/2:/201·~ :.:: : 39 : 14 ?:·l •. :2- 7 . E :.:;~:-<~es ?AGZ ~4 SJC 88 W Ot.: ~: JE!:' ~~A~F< i'O:\ ?P:O...BCT 31 - ;3 553 533 SU FF'.);;:.7 TF.057 Schedule R (Form s-90) 2012 mll!I Page {e) Legal domicile (b) P11mary acllv~y ta) Narr.e addrass ana EIN of relaied ~aniza:JOn (d) Direci controlling entity (f) Share of tO!al income (e) Predoml1131lt income trelcaed . unrelated. excludeo irorn (s1a1e or fori!•gn country) J~l 2 Identification of Related Organizations Taxabl e as a Partnership (Complete if the organization answered "Yes" to Form 990. Part IV. line 34 because it had one or more related organizations treated as a partnership during the tax year.) (g} Share Of eno-ol- year asse.s {h) :i, :'1:-~ ,,.._. tax und,,,- {l) CodeV4JSI amount m box 20 ol Sch'!!tlule K-1 (Ferm 1055) Iii i;at".r~ scclcon s 512·51"J Yes No ________ ________ _____ I I J3l_ ___ __________________ I I I I I I I I I I ,. I J§l _______ _____ _____ ____ I I I J.!?l _________ ____ ________ I I I JZl _____________________ I I I I I J!l_ ___ _____ __ ___________ Yes No I 1 J~l -- ----~- -- ---- -- - --- mm (k) Percentage ownersn:p Get'eral"' r.lat".3\l,,,. I 1 ! l I Identification of Related Organizations Taxable as a Corporation or Trust (Complete if the organization answered "Yes" to Form 990. Part IV, line 34 because it had one or more related organizations treated as a corporation or trust during the tax year.) Name :r.:ia~. (b) Pnmary actMty {2) and EIN of rebled or,ia.1c:a-Jon I Le;all SJC 89 ~·1.J ~::~E: ' ;·:h?.:~ ; o: S=."':~ ..1'11 r: , c~ ~.;, 1:n;q P:=. .:'~~c r :r s~_~ ?.! '0 2.: :F.~.r s: .: 1 - c::::-:.23 •oc;• 3 :c1: Transactions With Related Organizations (Complete if the org anization answered "Yes" to Form 990. Part IV. line 34. 35b. or 36.) ~-Y_es Note. C omplete line 1 if any entity 1s listed in Parts II. Ill, or N of this schedule. 1 During the tax year. did the organizatio:i engage m any of the following transactions with one or more related organizations l!Sted 1n Parts II-IV? a Receipt of (i) interest (ii) annuities (iii) royalties or (iv) rent from a controlled entity . b Gm. grant. or capital contribution to related organization(s) . . c Gift grant. or capital contribution from related organization(s) . d Loans or loan guarantees to or for related organiza!Jon(s) e Loans or loan guarantees by related organization(s). g h I I I 1c 1d p q Reimbursement pa id to related organization(s) for expenses . Re imbursement pa id by related organization(s) for expenses s Other tra nsfer of cash or propeny to related organization(s) •. Other transfe:r of cash or orooertv from related orqanization(s) . If the answer to anv of the above 1s ''Yes," see the instructions for inf, ~I \·;P.-F.:=.: :::.z..:. t r•:'·,TEC'l , i: 1n j I .,. 10 I 1 :·: 1Q I :-: 1pn . 1rrT: I I :,: 1s (b) Transaa•Cll of atncr organi:::allOO iype ("'s) :·; c-~~ :~ ~·:: L· I :...; tt ~ (a) ( 1) .. .. 1h Lease of fac11it1es. equipment, or other assets from related orgamzation(s) . . . • . • . • .. . Performance of services or membership or iundrais1ng solicitations for related organization(s) Performance of services or membership or fundraising solicitations by related orgamzation(s) . Sharing of facilities. equipment. mailing hsts. or other assets with relaled organization(s) Sharing of paid employees with related organization(s) . . . . . . . . .. . . . . . . . . . ~.a'Tle I 1a ~ Dividends from related organizahon{s) . . . ..• Sale of assets to related organization(s) . . . .. Purchase of assets from related organizat:on(s) . Exchange of assets with related organization(s) . Lease of fac1lrties equipment or other assets to related organization(s) . k I m n o N<> rn:: ': I I (d) [c;) Amount in :ol'li!O ~.lethcd or delennrrn 990) 2012 ; SA 2 E1 ~ 1.00:· 23 ~ 3(::·• •on ·1 1211201 ; !~ : 3S- : i~ :-M . ,, 1 7: - 1 . 12 C1 ~33 _;3 5 : ns:: :.;:. SJC 90 ~\O'.J!lJED \·:;.;.~I O~- ?;O'-IEC':' ~T 31 - 555CS33 SiJP?Q?.T :"!=.UST P-..ge 4 Schedule R \ Fam 990) Z012 lil)lj\'41 Unrelated Organizations Taxable as a Partnership (Complete if the organization answered "Yes" on Form 990, Part N , line 37.) Provide ihe following mformauon for each entity taxed as a partnership through which the organization conducted more t.han five percent of rts activities (measured by total assets or gross revenue) that was not a related organization. See instructions regarding exclusion for certain investment partnerships. le11: Z> 3tnOur\t No I I I I l J~L---- ---- ---- -----~------J I el Scr...-..ule "·· 1 {!=0tm 1t\..--Sj I (5) Jil ____ _______ ______________ _ 111n::..u"'~-: Yes I __________________ __ ____ _ lhl ,,.,,.,.,.,,_,,. :r.w.. I ----------------------------- I Md-d•yeot ~c:.'Jtcins"> Yes No I ____ ______________________ !QI llJ a.Ii pOlr"u~~.".S I (3) J ~l .:.. re i...nrtS~ee CAduC~ :reim tu uncC! ~~·or. ~1z...s1~> --- I (•) mcome (tel~a I I I I I I I I I I Schedule R (Form 990) 2012 ;SA :tE13iO l 00:> 2353:;:: -; 02 [i 7 / 2li ~ o::. .; 12 : 39 : l l ~t·· ·; 12- 7. ::-: 0~3::: -4 35 ;:"..~.\,;~ 2.7 SJC 91 .'IUL!Nflf',[I 1:l/IH[(Ic1i·: Pf«J lECT L'i' SUPPOf,T 1 TRll.~'I' Sehodulo R (Form 990>?O1~ l@@ii Pill]e 5 Supplem ental Information Comple te this part lo provide additional information for responses to question s on Schedule R (see instructions). Sc h o llulo R ( Form 990) 201 2 2E 1'• 10 I ll!Jll L.! : Y.l : ltl ('M V l 2-"/ . l~ 02 JJ 1rod•ry•~•£O•l.,,.LJ(.lf)f i-."tt!"l"'1'in-.."'"" .......,...r. ~ l!J . ~@13 }'.JOUN.t2..~;;.Q..•J'.~bJS_fi. ;; c;J<. 1'.li.~J.~tEC~T ._l .:l' ~;_1,1~;~.~ )HT . . .'l: RUS T Narn1t o,,.., ttlle c f ~t"N lmJ T_y_pe of Return and Return Information (Whple ~!~~s O.!Jly)_ . Chc<:k lhe boic for the return for w hich )-ou are using this Form 8879-EO anti c 111or Ille applicable amount. 11 :my, from the return. If you check l he box on line 1a, 2a, 3a, d:i, or Sa , below, ;:inck her e • 11''1!1 Declaration and_..§!graatur.L~ythorization of OfJJc~e_r_ __ ;:;_li1J.I}.f?.!l , 1b 2b 3b '4b - - - - - Sb - ·-----·-··-- - --·-- - ------- Under pcMlties of perjury, I declare that I am an officer of lhe above organizalion el'ld that f ha11e examtnod a copy of the organization's 2013 electro11ic r1~t urn <111d accompanying schmJules and statern1mt11 orid lo tho best or my knowtcdgo ond belief, 1hcy are true, correcl, and complete . I further declare that the amounl l11 Parl I above is tho amount shown on tho copy of tho organization's electronic return . I consonl lo allow my inlcrmodiate service proVlder. lrimsmrttor, or eleclronlc rcllM'll originator {ERO) to send tlie organiLalion's return to the IRS and to rncelve from the IRS (a) an acknowledgement or receipt or reason tor rejection of the trilnSmisSion. {b) the reason l or any delay in processing lhe relurn or reflXld, and (c) the dale of any refund. II appllcablo, I aulhonzt tlwl U S Treasury and lls desiqnated f hancial Agent to initiate an eleclroNc funds wilh slalu , su back of form. r.,..,, 8879-EO 420 131 J5-' lE. t 61t ' 000 WWP_0000330 SJC 95 OMO Nu 1~· 004/ Return of Organization Exempt From Income Tax 99 0 Form 1111- Do not enter Social Security numbers on this form as it may be made public. Ocp.11lmc11I ul lht: T1C1l~'Y ~ Information about Form 990 and its instructions is at www.irs.gov/form990. 1111crna1 Re""""" s.:1 ...cc l OI A Fo r the 2013 calenda r year, or t ax yea r beginning B -I WOUNDED - Add•C'H lf.lrt~\.l.:t~ 0 ~"17\RRIOR 1 ('111'1"-'" cd Amundt!ll \'lllLM!N(i 'fON , D!:: 1980 l F Name and address of pnncipal officer: rv!llrll APt~l11,.,,t 101l ,141nclnl9 37 - 6SS8533 I E Room/suite IX Tso1(c)(3) I ·1501(c) ( ) .... (insert no.) J Website : 1111- WWW. WOUND Em~l\RRIOf·:PRO,JECT. ORC Form of I Corpl)r H(b} I I 4 94 7(<1)11)~~ I I!>ZI - , Other .... - IL If " No," ulli<-0'' H(c} c:;,oup I I Association I Yes H(o) Is lh•s a group 1eium for m: 19801 ~\ li st. ( st~~ ~xenipli on tj 81 , 182,lll G G, oss 0 u - . - - --------------- - -- -- --- --- - - --- - - ----- - - ----- -- - - .. - - ---- - ---------0 6 0 0 Current Year Prior Year "'> QI ~ II) QI 9, 100,000. 8 Co11 tribulions and grants (Part VIII , line 1h) . 9 Program service revenue (Part VIII, lin e 2g) • 0 10 Investment income (Part V III, column (A ), lines 3, 4, and 7d). 0 11 Oth er revenue (Part VIII , column (A), lines 5. 6d. 8c, 9c, 10c, and 11e). 12 Total re~enue • add lines 8 through 11 (must equal P<1rl VIII. column (A). line 12). "'::>c ~ .. Grants and sim ilar amounts paid (Part IX, column (A), lines 1·3) . 0 Benefits paid to or for members (Part IX, column (A). line 4) . 0 15 Sa laries, o ther compensation, employee benefits (Part IX, colum n (A), fines 5-10). ___ 17 u ,__ • _ O ther expenses (Part IX, column (A ), lines 11a·1 1d, 11f·24e) 18 Total expenses . Add li nes 13· 17 (must equal Part IX, column (A) . line 25) 19 Revenue less expen se s. Subtract lin e 18 from line 12. 0 ---·--- - 0 1 34 , "/Ll. 9,100,000 . 28,?.8/,61J3. End of Year Beginning of Current Year .. 0 _c 20 ct~ _,, 21 .,c z~ 22 l::r. ---134 , 721. 9 , 100 , 000. . 13 O __ .. 28,000,000. . .. 9 , 100,000 . Total assets (Part X . line 16) . .37, IJ85 , 063 . 0 .37, '185, 063. 0 Tolal lillbililies (Part X, line 26). Net assets or fund balances. Subtract line 21 from line 20. 9 , 1 00,000. Signatu r e Block Undc< pen<)ltics or per1ury. I declare that I haw examined this return. inclvdrng accompanying sche (see instruction s) For Paperwork Reduction A ct Notice, see the separate in structions . X Yes F()(m No 990 (2013) •J!;A 3E 1010 1.000 WWP_0000331 SJC 96 Form 990 (2013) Page Part III 1 Statement of Program Service Accomplishments Check if Schedule O contains a response or note to any line in this Part III Briefly describe the organization's mission: mmmmmmmmmmmmmmmmmmmmmmmm 2 X ATTACHMENT 1 2 Did the organization undertake any significant program services during the year which were not listed on the X No prior Form 990 or 990-EZ? Yes If "Yes," describe these new services on Schedule O. 3 Did the organization cease conducting, or make significant changes in how it conducts, any program X No services? Yes If "Yes," describe these changes on Schedule O. 4 Describe the organization's program service accomplishments for each of its three largest program services, as measured by expenses. Section 501(c)(3) and 501(c)(4) organizations are required to report the amount of grants and allocations to others, the total expenses, and revenue, if any, for each program service reported. mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 4a (Code: ) (Expenses $ including grants of $ ) (Revenue $ ) 4b (Code: ) (Expenses $ including grants of $ ) (Revenue $ ) 4c (Code: ) (Expenses $ including grants of $ ) (Revenue $ ) 4d Other program services (Describe in Schedule O.) (Expenses $ including grants of $ 4e Total program service expenses JSA 3E1020 2.000 I ) (Revenue $ ) Form 990 (2013) WWP_0000332 SJC 97 Form 990 (2013) Part IV Page Yes Is the organization described in section 501(c)(3) or 4947(a)(1) (other than a private foundation)? If "Yes," complete Schedule A Is the organization required to complete Schedule B, Schedule of Contributors (see instructions)? Did the organization engage in direct or indirect political campaign activities on behalf of or in opposition to candidates for public office? If "Yes," complete Schedule C, Part I Section 501(c)(3) organizations. Did the organization engage in lobbying activities, or have a section 501(h) election in effect during the tax year? If "Yes," complete Schedule C, Part II Is the organization a section 501(c)(4), 501(c)(5), or 501(c)(6) organization that receives membership dues, assessments, or similar amounts as defined in Revenue Procedure 98-19? If "Yes," complete Schedule C, Part III Did the organization maintain any donor advised funds or any similar funds or accounts for which donors have the right to provide advice on the distribution or investment of amounts in such funds or accounts? If "Yes," complete Schedule D, Part I Did the organization receive or hold a conservation easement, including easements to preserve open space, the environment, historic land areas, or historic structures? If "Yes," complete Schedule D, Part II Did the organization maintain collections of works of art, historical treasures, or other similar assets? If "Yes," complete Schedule D, Part III Did the organization report an amount in Part X, line 21, for escrow or custodial account liability; serve as a custodian for amounts not listed in Part X; or provide credit counseling, debt management, credit repair, or debt negotiation services? If "Yes," complete Schedule D, Part IV Did the organization, directly or through a related organization, hold assets in temporarily restricted endowments, permanent endowments, or quasi-endowments? If "Yes," complete Schedule D, Part V If the organization’s answer to any of the following questions is "Yes," then complete Schedule D, Parts VI, VII, VIII, IX, or X as applicable. Did the organization report an amount for land, buildings, and equipment in Part X, line 10? If "Yes," complete Schedule D, Part VI Did the organization report an amount for investments-other securities in Part X, line 12 that is 5% or more of its total assets reported in Part X, line 16? If "Yes," complete Schedule D, Part VII Did the organization report an amount for investments-program related in Part X, line 13 that is 5% or more of its total assets reported in Part X, line 16? If "Yes," complete Schedule D, Part VIII Did the organization report an amount for other assets in Part X, line 15 that is 5% or more of its total assets reported in Part X, line 16? If "Yes," complete Schedule D, Part IX Did the organization report an amount for other liabilities in Part X, line 25? If "Yes," complete Schedule D, Part X mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmm 1 2 3 4 5 mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 6 mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 7 8 9 mmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmm 10 11 a b c d mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmm e f Did the organization’s separate or consolidated financial statements for the tax year include a footnote that addresses mmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmm mmmmmmmmmm mmmmmmmmmmmmm the organization's liability for uncertain tax positions under FIN 48 (ASC 740)? If "Yes," complete Schedule D, Part X 12 a Did the organization obtain separate, independent audited financial statements for the tax year? If "Yes," complete Schedule D, Parts XI and XII b Was the organization included in consolidated, independent audited financial statements for the tax year? If "Yes," and if the organization answered "No" to line 12a, then completing Schedule D, Parts XI and XII is optional 13 Is the organization a school described in section 170(b)(1)(A)(ii)? If "Yes," complete Schedule E 14 a Did the organization maintain an office, employees, or agents outside of the United States? b Did the organization have aggregate revenues or expenses of more than $10,000 from grantmaking, fundraising, business, investment, and program service activities outside the United States, or aggregate foreign investments valued at $100,000 or more? If "Yes," complete Schedule F, Parts I and IV 15 Did the organization report on Part IX, column (A), line 3, more than $5,000 of grants or other assistance to or for any foreign organization? If "Yes," complete Schedule F, Parts II and IV 16 Did the organization report on Part IX, column (A), line 3, more than $5,000 of aggregate grants or other assistance to or for foreign individuals? If "Yes," complete Schedule F, Parts III and IV 17 Did the organization report a total of more than $15,000 of expenses for professional fundraising services on Part IX, column (A), lines 6 and 11e? If "Yes," complete Schedule G, Part I (see instructions) 18 Did the organization report more than $15,000 total of fundraising event gross income and contributions on Part VIII, lines 1c and 8a? If "Yes," complete Schedule G, Part II 19 Did the organization report more than $15,000 of gross income from gaming activities on Part VIII, line 9a? If "Yes," complete Schedule G, Part III 20 a Did the organization operate one or more hospital facilities? If "Yes," complete Schedule H b If "Yes" to line 20a, did the organization attach a copy of its audited financial statements to this return? mmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmm mmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmm mmmmmm JSA 3E1021 1.000 3 Checklist of Required Schedules 1 2 No X X 3 X 4 X 5 X 6 X 7 X 8 X 9 X 10 X 11a X 11b X 11c X 11d 11e X X 11f X X 12a 12b 13 14a X X X 14b X 15 X 16 X 17 X 18 X 19 20a 20b X X Form 990 (2013) WWP_0000333 SJC 98 Form 990 (2013) Part IV Page Yes 21 Did the organization report more than $5,000 of grants or other assistance to any domestic organization or government on Part IX, column (A), line 1? If "Yes," complete Schedule I, Parts I and II Did the organization report more than $5,000 of grants or other assistance to individuals in the United States on Part IX, column (A), line 2? If "Yes," complete Schedule I, Parts I and III Did the organization answer "Yes" to Part VII, Section A, line 3, 4, or 5 about compensation of the organization's current and former officers, directors, trustees, key employees, and highest compensated employees? If "Yes," complete Schedule J Did the organization have a tax-exempt bond issue with an outstanding principal amount of more than $100,000 as of the last day of the year, that was issued after December 31, 2002? If "Yes," answer lines 24b through 24d and complete Schedule K. If “No,” go to line 25a Did the organization invest any proceeds of tax-exempt bonds beyond a temporary period exception? Did the organization maintain an escrow account other than a refunding escrow at any time during the year to defease any tax-exempt bonds? Did the organization act as an "on behalf of" issuer for bonds outstanding at any time during the year? Section 501(c)(3) and 501(c)(4) organizations. Did the organization engage in an excess benefit transaction with a disqualified person during the year? If "Yes," complete Schedule L, Part I Is the organization aware that it engaged in an excess benefit transaction with a disqualified person in a prior year, and that the transaction has not been reported on any of the organization's prior Forms 990 or 990-EZ? If "Yes," complete Schedule L, Part I Did the organization report any amount on Part X, line 5, 6, or 22 for receivables from or payable to any current or former officers, directors, trustees, key employees, highest compensated employees, or disqualified persons? If so, complete Schedule L, Part II Did the organization provide a grant or other assistance to an officer, director, trustee, key employee, substantial contributor or employee thereof, a grant selection committee member, or to a 35% controlled entity or family member of any of these persons? If "Yes," complete Schedule L, Part III Was the organization a party to a business transaction with one of the following parties (see Schedule L, Part IV instructions for applicable filing thresholds, conditions, and exceptions): A current or former officer, director, trustee, or key employee? If "Yes," complete Schedule L, Part IV A family member of a current or former officer, director, trustee, or key employee? If "Yes," complete Schedule L, Part IV An entity of which a current or former officer, director, trustee, or key employee (or a family member thereof) was an officer, director, trustee, or direct or indirect owner? If "Yes," complete Schedule L, Part IV Did the organization receive more than $25,000 in non-cash contributions? If "Yes," complete Schedule M Did the organization receive contributions of art, historical treasures, or other similar assets, or qualified conservation contributions? If "Yes," complete Schedule M Did the organization liquidate, terminate, or dissolve and cease operations? If "Yes," complete Schedule N, Part I Did the organization sell, exchange, dispose of, or transfer more than 25% of its net assets? If "Yes," complete Schedule N, Part II Did the organization own 100% of an entity disregarded as separate from the organization under Regulations sections 301.7701-2 and 301.7701-3? If "Yes," complete Schedule R, Part I Was the organization related to any tax-exempt or taxable entity? If "Yes," complete Schedule R, Part II, III, or IV, and Part V, line 1 Did the organization have a controlled entity within the meaning of section 512(b)(13)? If "Yes" to line 35a, did the organization receive any payment from or engage in any transaction with a controlled entity within the meaning of section 512(b)(13)? If "Yes," complete Schedule R, Part V, line 2 Section 501(c)(3) organizations. Did the organization make any transfers to an exempt non-charitable related organization? If "Yes," complete Schedule R, Part V, line 2 Did the organization conduct more than 5% of its activities through an entity that is not a related organization and that is treated as a partnership for federal income tax purposes? If "Yes," complete Schedule R, Part VI Did the organization complete Schedule O and provide explanations in Schedule O for Part VI, lines 11b and 19? Note. All Form 990 filers are required to complete Schedule O mmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmm 22 23 mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 24 a b c d 25 a b mmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmm mmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 26 mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmm 27 28 a b c 29 30 31 32 33 34 35 a b 36 37 38 JSA 3E1030 1.000 4 Checklist of Required Schedules (continued) mmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmm mmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmm No 21 X 22 X 23 X 24a 24b X 24c 24d 25a X 25b X 26 X 27 X 28a X 28b X 28c 29 X X 30 X 31 X 32 X 33 X 34 35a X X 35b 36 X 37 X 38 Form X 990 (2013) WWP_0000334 SJC 99 Form 990 (2013) Part V Page mmmmmmmmmmmmmmmmmmmmm 0 mmmmmmmmmm 0 mmmmmmmmm X mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 0 m X mmmmmmm X mmmmmmmmmm mmmmmmm Yes 1a 1 a Enter the number reported in Box 3 of Form 1096. Enter -0- if not applicable 1b b Enter the number of Forms W-2G included in line 1a. Enter -0- if not applicable c Did the organization comply with backup withholding rules for reportable payments to vendors and reportable gaming (gambling) winnings to prize winners? 2 a Enter the number of employees reported on Form W-3, Transmittal of Wage and Tax 2a Statements, filed for the calendar year ending with or within the year covered by this return b If at least one is reported on line 2a, did the organization file all required federal employment tax returns? Note. If the sum of lines 1a and 2a is greater than 250, you may be required to e-file (see instructions) 3 a Did the organization have unrelated business gross income of $1,000 or more during the year? b If "Yes," has it filed a Form 990-T for this year? If "No" to line 3b, provide an explanation in Schedule O 4 a At any time during the calendar year, did the organization have an interest in, or a signature or other authority over, a financial account in a foreign country (such as a bank account, securities account, or other financial account)? b If “Yes,” enter the name of the foreign country: See instructions for filing requirements for Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts. 5 a Was the organization a party to a prohibited tax shelter transaction at any time during the tax year? b Did any taxable party notify the organization that it was or is a party to a prohibited tax shelter transaction? c If "Yes" to line 5a or 5b, did the organization file Form 8886-T? 6 a Does the organization have annual gross receipts that are normally greater than $100,000, and did the organization solicit any contributions that were not tax deductible as charitable contributions? b If "Yes," did the organization include with every solicitation an express statement that such contributions or gifts were not tax deductible? 7 Organizations that may receive deductible contributions under section 170(c). a Did the organization receive a payment in excess of $75 made partly as a contribution and partly for goods and services provided to the payor? b If "Yes," did the organization notify the donor of the value of the goods or services provided? c Did the organization sell, exchange, or otherwise dispose of tangible personal property for which it was required to file Form 8282? 7d d If "Yes," indicate the number of Forms 8282 filed during the year 8 9 a b 10 a b 2b 3a 3b Did the organization receive any funds, directly or indirectly, to pay premiums on a personal benefit contract? Did the organization, during the year, pay premiums, directly or indirectly, on a personal benefit contract? If the organization received a contribution of qualified intellectual property, did the organization file Form 8899 as required? If the organization received a contribution of cars, boats, airplanes, or other vehicles, did the organization file a Form 1098-C? Sponsoring organizations maintaining donor advised funds and section 509(a)(3) supporting organizations. Did the supporting organization, or a donor advised fund maintained by a sponsoring organization, have excess business holdings at any time during the year? Sponsoring organizations maintaining donor advised funds. Did the organization make any taxable distributions under section 4966? Did the organization make a distribution to a donor, donor advisor, or related person? Section 501(c)(7) organizations. Enter: 10a Initiation fees and capital contributions included on Part VIII, line 12 10b Gross receipts, included on Form 990, Part VIII, line 12, for public use of club facilities mmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmm mmmmmmmmmmmmmm mmmm mmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmm mmmmmmmmmmmmmmmmmm Section 501(c)(12) organizations. Enter: 11a a Gross income from members or shareholders b Gross income from other sources (Do not net amounts due or paid to other sources 11b against amounts due or received from them.) 12 a Section 4947(a)(1) non-exempt charitable trusts. Is the organization filing Form 990 in lieu of Form 1041? 12b b If "Yes," enter the amount of tax-exempt interest received or accrued during the year 13 Section 501(c)(29) qualified nonprofit health insurance issuers. a Is the organization licensed to issue qualified health plans in more than one state? Note. See the instructions for additional information the organization must report on Schedule O. b Enter the amount of reserves the organization is required to maintain by the states in which the organization is licensed to issue qualified health plans 13b 13c c Enter the amount of reserves on hand JSA 3E1040 1.000 X 5a 5b 5c X X 6a X 7a 7b X 7c X 7e 7f 7g 7h X X X X 8 X 9a 9b 12a 13a mmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm m m m m m m m mm mm mm mm mm mm 14 a Did the organization receive any payments for indoor tanning services during the tax year? b If "Yes," has it filed a Form 720 to report these payments? If "No," provide an explanation in Schedule O 4a 6b mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmm mmmmm 11 No 1c mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm I mmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm e f g h 5 Statements Regarding Other IRS Filings and Tax Compliance Check if Schedule O contains a response or note to any line in this Part V 14a 14b X Form 990 (2013) WWP_0000335 Form 990 (2013) SJC Part VI Page 6 100 Governance, Management, and Disclosure For each "Yes" response to lines 2 through 7b below, and for a "No" mmmmmmmmmmmmmmmmmmmmmmmm response to line 8a, 8b, or 10b below, describe the circumstances, processes, or changes in Schedule O. See instructions. Check if Schedule O contains a response or note to any line in this Part VI X Section A. Governing Body and Management 1a Enter the number of voting members of the governing body at the end of the tax year mmmmm Yes 1a No 0 If there are material differences in voting rights among members of the governing body, or if the governing body delegated broad authority to an executive committee or similar committee, explain in Schedule O. mmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mm mmmmmm mmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 0 1b b Enter the number of voting members included in line 1a, above, who are independent 2 Did any officer, director, trustee, or key employee have a family relationship or a business relationship with any other officer, director, trustee, or key employee? 3 Did the organization delegate control over management duties customarily performed by or under the direct supervision of officers, directors, or trustees, or key employees to a management company or other person? 4 Did the organization make any significant changes to its governing documents since the prior Form 990 was filed? 5 Did the organization become aware during the year of a significant diversion of the organization's assets? 6 Did the organization have members or stockholders? 7a Did the organization have members, stockholders, or other persons who had the power to elect or appoint one or more members of the governing body? b Are any governance decisions of the organization reserved to (or subject to approval by) members, stockholders, or persons other than the governing body? 8 Did the organization contemporaneously document the meetings held or written actions undertaken during the year by the following: a The governing body? b Each committee with authority to act on behalf of the governing body? 9 Is there any officer, director, trustee, or key employee listed in Part VII, Section A, who cannot be reached at the organization's mailing address? If "Yes," provide the names and addresses in Schedule O mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmm 2 X 3 4 5 6 X X X X 7a X 7b X 8a 8b X X 9 X Section B. Policies (This Section B requests information about policies not required by the Internal Revenue Code.) mmmmmmmmmmmmmmmmmmmmmmmmmm mmm m mmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmm 10 a Did the organization have local chapters, branches, or affiliates? b If "Yes," did the organization have written policies and procedures governing the activities of such chapters, affiliates, and branches to ensure their operations are consistent with the organization's exempt purposes? 11 a Has the organization provided a complete copy of this Form 990 to all members of its governing body before filing the form? b Describe in Schedule O the process, if any, used by the organization to review this Form 990. 12 a Did the organization have a written conflict of interest policy? If "No," go to line 13 b Were officers, directors, or trustees, and key employees required to disclose annually interests that could give rise to conflicts? c Did the organization regularly and consistently monitor and enforce compliance with the policy? If "Yes," describe in Schedule O how this was done 13 Did the organization have a written whistleblower policy? 14 Did the organization have a written document retention and destruction policy? 15 Did the process for determining compensation of the following persons include a review and approval by independent persons, comparability data, and contemporaneous substantiation of the deliberation and decision? a The organization's CEO, Executive Director, or top management official b Other officers or key employees of the organization If "Yes" to line 15a or 15b, describe the process in Schedule O (see instructions). 16 a Did the organization invest in, contribute assets to, or participate in a joint venture or similar arrangement with a taxable entity during the year? b If "Yes," did the organization follow a written policy or procedure requiring the organization to evaluate its participation in joint venture arrangements under applicable federal tax law, and take steps to safeguard the organization's exempt status with respect to such arrangements? Section C. Disclosure Yes No X 10a 10b 11a X 12a X 12b X 12c 13 14 X X X mmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 15a 15b X X mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 16a X mmmmmmmmmmmmmmmmmmmmmmmmm I 16b 17 18 List the states with which a copy of this Form 990 is required to be filed Section 6104 requires an organization to make its Forms 1023 (or 1024 if applicable), 990, and 990-T (Section 501(c)(3)s only) available for public inspection. Indicate how you made these available. Check all that apply. X Upon request Own website Another's website Other (explain in Schedule O) 19 Describe in Schedule O whether (and if so, how) the organization made its governing documents, conflict of interest policy, and financial statements available to the public during the tax year. State the name, physical address, and telephone number of the person who possesses the books and records of the organization: BARCLAYS WEALTH TRUSTEES (U.S.), N.A. 100 SOUTH WEST STREET WILMINGTON, DE 19801 904-296-7350 Form 990 (2013) 20 JSA 3E1042 1.000 I WWP_0000336 Form 990 (2013) SJC Part VII Page 7 101 Compensation of Officers, Directors, Trustees, Key Employees, Highest Compensated Employees, and Independent Contractors Check if Schedule O contains a response or note to any line in this Part VII mmmmmmmmmmmmmmmmmmmmmm Section A. Officers, Directors, Trustees, Key Employees, and Highest Compensated Employees 1a Complete this table for all persons required to be listed. Report compensation for the calendar year ending with or within the organization's tax year. % % % % % List all of the organization's current officers, directors, trustees (whether individuals or organizations), regardless of amount of compensation. Enter -0- in columns (D), (E), and (F) if no compensation was paid. List all of the organization's current key employees, if any. See instructions for definition of "key employee." List the organization's five current highest compensated employees (other than an officer, director, trustee, or key employee) who received reportable compensation (Box 5 of Form W-2 and/or Box 7 of Form 1099-MISC) of more than $100,000 from the organization and any related organizations. List all of the organization's former officers, key employees, and highest compensated employees who received more than $100,000 of reportable compensation from the organization and any related organizations. List all of the organization's former directors or trustees that received, in the capacity as a former director or trustee of the organization, more than $10,000 of reportable compensation from the organization and any related organizations. List persons in the following order: individual trustees or directors; institutional trustees; officers; key employees; highest compensated employees; and former such persons. Check this box if neither the organization nor any related organization compensated any current officer, director, or trustee. (C) (A) Name and Title Position (B) (do not check more than one Average hours per box, unless person is both an week (list any officer and a director/trustee) Former Highest compensated employee Key employee line) Officer below dotted Institutional trustee related organizations Individual trustee or director hours for (D) (E) Reportable Reportable compensation compensation from from related the organizations organization (W-2/1099-MISC) (W-2/1099-MISC) (F) Estimated amount of other compensation from the organization and related organizations (1)BARCLAYS WEATH TRUSTEES (U.S.), N.A. X 134,721. 0 (2) (3) (4) (5) (6) (7) (8) (9) (10) (11) (12) (13) (14) JSA 3E1041 1.000 Form 990 (2013) WWP_0000337 0 SJC 102 Form 990 (2013) Part VII Page 8 Section A. Officers, Directors, Trustees, Key Employees, and Highest Compensated Employees (continued) (A) Name and title (B) (C) Average Position (do not check more than one box, unless person is both an officer and a director/trustee) hours per week (list any hours for Former Highest compensated employee Key employee Officer line) Institutional trustee below dotted Individual trustee or director related organizations (D) (E) Reportable Reportable compensation compensation from from related the organizations organization (W-2/1099-MISC) (W-2/1099-MISC) m m m m m m m m m m m m m m m m m m m m m m m m m mm mm mm mm mm mm mm mm mm mm mm mm mm I m m m m m m m m m m m m m m m m m m m m m m m m m m m m II I (F) Estimated amount of other compensation from the organization and related organizations 1b c d 2 134,721. Sub-total 0 Total from continuation sheets to Part VII, Section A 134,721. Total (add lines 1b and 1c) Total number of individuals (including but not limited to those listed above) who received more than $100,000 of reportable compensation from the organization 1 0 0 0 0 0 0 3 Did the organization list any former officer, director, or trustee, key employee, or highest compensated employee on line 1a? If "Yes," complete Schedule J for such individual mmmmmmmmmmmmmmmmmmmmmmmmmm 3 X For any individual listed on line 1a, is the sum of reportable compensation and other compensation from the organization and related organizations greater than $150,000? If “Yes,” complete Schedule J for such individual 4 X Yes No 4 mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmm Did any person listed on line 1a receive or accrue compensation from any unrelated organization or individual for services rendered to the organization? If “Yes,” complete Schedule J for such person 5 Section B. Independent Contractors 1 Complete this table for your five highest compensated independent contractors that received more than $100,000 of compensation from the organization. Report compensation for the calendar year ending with or within the organization's tax year. 5 (A) Name and business address 2 (B) Description of services X (C) Compensation Total number of independent contractors (including but not limited to those listed above) who received more than $100,000 in compensation from the organization 0 JSA 3E1055 1.000 I Form 990 (2013) WWP_0000338 Form 990 (2013) SJC Part VIII 103 Statement of Revenue Page Check if Schedule O contains a response or note to any line in this Part VIII Contributions, Gifts, Grants Program Service Revenue and Other Similar Amounts (A) Total revenue mmmmmmmm mmmmmmmmm mmmmmmmmm mmmmmmmm mm m m m m m m m m m m m m m m m m m m m mI Federated campaigns 1a b Membership dues 1b c Fundraising events d Related organizations 1d e Government grants (contributions) 1e f All other contributions, gifts, grants, 1a (B) Related or exempt function revenue (C) Unrelated business revenue (D) Revenue excluded from tax under sections 512-514 28,000,000. 1f Noncash contributions included in lines 1a-1f: $ Total. Add lines 1a-1f 28,000,000. Business Code 2a b c d e f g m m m m m m mm mm mm mm mm m m m m m m m m I m m m m m m m m m m m m m m m m m m mI m m m m m m m m m m m m m m m m m m m m m m mm mm mm II mmmmmmmm mmm mm mmmmmmmmmmmmmmm I All other program service revenue Total. Add lines 2a-2f 0 Investment income (including dividends, interest, and 3 other similar amounts) 311,868. 4 Income from investment of tax-exempt bond proceeds 0 5 Royalties 0 6a Less: rental expenses c d Rental income or (loss) b (i) Real (ii) Personal (i) Securities (ii) Other Net rental income or (loss) Gross amount from sales of assets other than inventory 8a 0 52,870,263. Less: cost or other basis mmmm m m mm mm mm mm mm m m m m m m m m m m m m m m m m and sales expenses c d 311,868. Gross rents b 7a Other Revenue mmmmmmmmmmmmmmmmmmmmmmmm 1c and similar amounts not included above g h 9 52,764,767. Gain or (loss) Net gain or (loss) 105,496. Gross income from fundraising I 105,496. 105,496. events (not including $ of contributions reported on line 1c). See Part IV, line 18 b c 9a b c 10a b c mmmmmmmmmmm mmmmmmmmmm mmmmmmmm I mmmmmmmmmmm mmmmmmmmmmmmmmmmmmm I mmmmmmmmm mmmmmmmmmmmmmmmmmm I a Less: direct expenses b Net income or (loss) from fundraising events Gross income from gaming activities. See Part IV, line 19 a b Less: direct expenses Net income or (loss) from gaming activities Gross sales of inventory, returns and allowances 0 0 less a b Less: cost of goods sold Net income or (loss) from sales of inventory Miscellaneous Revenue Business Code 0 11a b c m m m m mm mm mm mm mm mm mm mm mm m m m m m m m m m m m m m m m m m m m m m m II d All other revenue e Total. Add lines 11a-11d Total revenue. See instructions 12 JSA 3E1051 1.000 0 28,417,364. 417,364. 990 (2013) WWP_0000339 Form Form 990 (2013) SJC 104 Part IX Statement of Functional Expenses Page 10 Section 501(c)(3) and 501(c)(4) organizations must complete all columns. All other organizations must complete column (A). Check if Schedule O contains a response or note to any line in this Part IX mmmmmmmmmmmmmmmmmmmmmmmm Do not include amounts reported on lines 6b, 7b, 8b, 9b, and 10b of Part VIII. m mmmmmm (A) Total expenses (B) Program service expenses (C) Management and general expenses (D) Fundraising expenses 1 Grants and other assistance to governments and organizations in the United States. See Part IV, line 21 2 Grants and other assistance to individuals in the United States. See Part IV, line 22 3 Grants and other assistance to governments, organizations, and individuals outside the United States. See Part IV, lines 15 and 16 mmmm mmmmmmmmm mmmmmmmmmm 0 0 4 Benefits paid to or for members 0 0 5 Compensation of current officers, directors, trustees, and key employees 0 6 Compensation not included above, to disqualified persons (as defined under section 4958(f)(1)) and m m m m m m mm mm mm mm mm mm mmmmmm mmmmmmmmmmmm mmmmmmmmmmmmmmmmmm m m m m mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmm m mmmmmmmmm mmmmmm m m m m m mm mm mm mm mm mm mm mm mm mm mm mmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmm 0 0 0 0 0 134,721. mmmm mmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmm mmmm mmmmmmmmmmmmmmmmmmm 0 0 0 0 0 0 persons described in section 4958(c)(3)(B) 7 Other salaries and wages 0 0 8 Pension plan accruals and contributions (include section 401(k) and 403(b) employer contributions) 9 Other employee benefits Payroll taxes 10 Fees for services (non-employees): a Management 11 b Legal c Accounting d Lobbying e Professional fundraising services. See Part IV, line 17 f Investment management fees g Other. 0 0 0 134,721. (If line 11g amount exceeds 10% of line 25, column (A) amount, list line 11g expenses on Schedule O.) 12 Advertising and promotion 13 Office expenses 14 Information technology 15 Royalties 16 Occupancy 17 Travel 18 Payments of travel or entertainment expenses for any federal, state, or local public officials 19 Conferences, conventions, and meetings 20 Interest 21 Payments to affiliates 22 Depreciation, depletion, and amortization 23 Insurance 24 Other expenses. Itemize expenses not 0 0 0 0 0 0 0 covered above (List miscellaneous expenses in line 24e. If line 24e amount exceeds 10% of line 25, column (A) amount, list line 24e expenses on Schedule O.) a b c d e All other expenses 25 Total functional expenses. Add lines 1 through 24e 26 Joint costs. Complete this line only if the organization reported in column (B) joint costs from a combined educational campaign and fundraising solicitation. Check here if following SOP 98-2 (ASC 958-720) JSA 3E1052 1.000 mIm m m m m m 134,721. 134,721. 0 Form 990 (2013) WWP_0000340 SJC 105 Form 990 (2013) Part X 1 2 3 4 5 Net Assets or Fund Balances Liabilities Assets 6 Page Balance Sheet Check if Schedule O contains a response or note to any line in this Part X mmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmm Cash - non-interest-bearing Savings and temporary cash investments Pledges and grants receivable, net Accounts receivable, net Loans and other receivables from current and former officers, directors, trustees, key employees, and highest compensated employees. Complete Part II of Schedule L mmmmmmmmmmmmmmmmmmmmmmmmm Loans and other receivables from other disqualified persons (as defined under section 4958(f)(1)), persons described in section 4958(c)(3)(B), and contributing employers and sponsoring organizations of section 501(c)(9) voluntary employees' beneficiary organizations (see instructions). Complete Part II of Schedule L m m m m m m m m m m m m m mm mm mm mm mm mm mm mm mm mm mm mm m m m m m m m m mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm Notes and loans receivable, net Inventories for sale or use Prepaid expenses and deferred charges Land, buildings, and equipment: cost or 10a other basis. Complete Part VI of Schedule D 10b b Less: accumulated depreciation 11 Investments - publicly traded securities 12 Investments - other securities. See Part IV, line 11 13 Investments - program-related. See Part IV, line 11 14 Intangible assets 15 Other assets. See Part IV, line 11 16 Total assets. Add lines 1 through 15 (must equal line 34) 17 Accounts payable and accrued expenses 18 Grants payable 19 Deferred revenue 20 Tax-exempt bond liabilities 21 Escrow or custodial account liability. Complete Part IV of Schedule D 22 Loans and other payables to current and former officers, directors, trustees, key employees, highest compensated employees, and disqualified persons. Complete Part II of Schedule L 23 Secured mortgages and notes payable to unrelated third parties 24 Unsecured notes and loans payable to unrelated third parties 25 Other liabilities (including federal income tax, payables to related third parties, and other liabilities not included on lines 17-24). Complete Part X of Schedule D 26 Total liabilities. Add lines 17 through 25 X and Organizations that follow SFAS 117 (ASC 958), check here complete lines 27 through 29, and lines 33 and 34. 7 8 9 10 a 27 28 29 JSA 3E1053 1.000 mmmmmmmmmmmmmmmmmmmmm (A) Beginning of year (B) End of year 9,100,000. 0 0 0 1 2 3 4 13,951,779. 0 0 0 0 5 0 0 0 0 0 0 0 0 0 6 7 8 9 mmmmmmmmmm mmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmm mmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm m m m m m m m m m m m m m m mm mm mm mm mm mm mm mm mm mm mmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmm mmmm 0 10c 0 11 0 12 0 13 0 14 0 15 9,100,000. 16 0 17 0 18 0 19 0 20 0 21 0 23,533,284. 0 0 0 0 37,485,063. 0 0 0 0 0 mmmmmmmmmmmmmm mmmmmmm mmmmmmmmm 0 22 0 23 0 24 0 0 0 0 25 0 26 0 0 9,100,000. 27 0 28 0 29 37,485,063. 0 0 m m m m m m m m m m m m m m mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm I mmmmmmmmmmmmmmmmmmmmmmmmmmmmm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm I mmmmmmmmmmmmmmmm mmmmmmmm mmmm m m m m m m mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm Unrestricted net assets Temporarily restricted net assets Permanently restricted net assets Organizations that do not follow SFAS 117 (ASC 958), check here complete lines 30 through 34. 30 31 32 33 34 11 Capital stock or trust principal, or current funds Paid-in or capital surplus, or land, building, or equipment fund Retained earnings, endowment, accumulated income, or other funds Total net assets or fund balances Total liabilities and net assets/fund balances and 30 31 32 9,100,000. 33 9,100,000. 34 37,485,063. 37,485,063. Form 990 (2013) WWP_0000341 SJC 106 Form 990 (2013) Part XI 1 2 3 4 5 6 7 8 9 10 Page m m m m m m m m m m m m m 28,417,364. mmmmmm mmmmmmmmmmmmmmmmmmmmmmm 134,721. mmmmmmmmmmmmmmmmmmmmmmm 28,282,643. mmmmmmmmmmmmmmmmmmmmmmmmmm 9,100,000. mmmmm 102,420. mmmmmmmmmmmmmmmmmmmmmmmmmmmmm 0 mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 0 mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 0 mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 0 mmmmmmmmmmmmmmmm 37,485,063. mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm Financial Statements and Reporting Check if Schedule O contains a response or note to any line in this Part XII m m m m m m m m m m m m m m m m m m m X Total revenue (must equal Part VIII, column (A), line 12) Total expenses (must equal Part IX, column (A), line 25) Revenue less expenses. Subtract line 2 from line 1 Net assets or fund balances at beginning of year (must equal Part X, line 33, column (A)) Net unrealized gains (losses) on investments Donated services and use of facilities Investment expenses Prior period adjustments Other changes in net assets or fund balances (explain in Schedule O) Net assets or fund balances at end of year. Combine lines 3 through 9 (must equal Part X, line 33, column (B)) Part XII 12 Reconciliation of Net Assets Check if Schedule O contains a response or note to any line in this Part XI 1 2 3 4 5 6 7 8 9 10 Yes X Accrual Accounting method used to prepare the Form 990: Cash Other If the organization changed its method of accounting from a prior year or checked "Other," explain in Schedule O. 2 a Were the organization's financial statements compiled or reviewed by an independent accountant? If "Yes," check a box below to indicate whether the financial statements for the year were compiled or reviewed on a separate basis, consolidated basis, or both: No 1 Separate basis Consolidated basis mmmmmm 2a mmmmmmmmmmmmmm 2b Both consolidated and separate basis b Were the organization's financial statements audited by an independent accountant? If "Yes," check a box below to indicate whether the financial statements for the year were audited on a separate basis, consolidated basis, or both: Separate basis X Consolidated basis mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 2c X 3a X 3b Form JSA X Both consolidated and separate basis c If "Yes" to line 2a or 2b, does the organization have a committee that assumes responsibility for oversight of the audit, review, or compilation of its financial statements and selection of an independent accountant? If the organization changed either its oversight process or selection process during the tax year, explain in Schedule O. 3 a As a result of a federal award, was the organization required to undergo an audit or audits as set forth in the Single Audit Act and OMB Circular A-133? b If "Yes," did the organization undergo the required audit or audits? If the organization did not undergo the required audit or audits, explain why in Schedule O and describe any steps taken to undergo such audits. 3E1054 1.000 X 990 (2013) WWP_0000342 SJC 107 (Form 990 or 990-EZ) Department of the Treasury Internal Revenue Service OMB No. 1545-0047 Public Charity Status and Public Support SCHEDULE A À¾µ· Complete if the organization is a section 501(c)(3) organization or a section 4947(a)(1) nonexempt charitable trust. I I Attach to Form 990 or Form 990-EZ. Information about Schedule A (Form 990 or 990-EZ) and its instructions is at www.irs.gov/form990. Name of the organization Open to Public Inspection Employer identification number WOUNDED WARRIOR PROJECT LT SUPPORT TRUST 37-6558533 Reason for Public Charity Status (All organizations must complete this part.) See instructions. Part I The organization is not a private foundation because it is: (For lines 1 through 11, check only one box.) 1 A church, convention of churches, or association of churches described in section 170(b)(1)(A)(i). 2 A school described in section 170(b)(1)(A)(ii). (Attach Schedule E.) 3 A hospital or a cooperative hospital service organization described in section 170(b)(1)(A)(iii). 4 A medical research organization operated in conjunction with a hospital described in section 170(b)(1)(A)(iii). Enter the hospital's name, city, and state: 5 An organization operated for the benefit of a college or university owned or operated by a governmental unit described in section 170(b)(1)(A)(iv). (Complete Part II.) 6 A federal, state, or local government or governmental unit described in section 170(b)(1)(A)(v). 7 An organization that normally receives a substantial part of its support from a governmental unit or from the general public described in section 170(b)(1)(A)(vi). (Complete Part II.) 8 A community trust described in section 170(b)(1)(A)(vi). (Complete Part II.) 9 An organization that normally receives: (1) more than 33 1/3 % of its support from contributions, membership fees, and gross receipts from activities related to its exempt functions - subject to certain exceptions, and (2) no more than 33 1/3 % of its support from gross investment income and unrelated business taxable income (less section 511 tax) from businesses acquired by the organization after June 30, 1975. See section 509(a)(2). (Complete Part III.) 10 An organization organized and operated exclusively to test for public safety. See section 509(a)(4). X An organization organized and operated exclusively for the benefit of, to perform the functions of, or to carry out the 11 purposes of one or more publicly supported organizations described in section 509(a)(1) or section 509(a)(2). See section 509(a)(3). Check the box that describes the type of supporting organization and complete lines 11e through 11h. X Type I a b Type II c Type III-Functionally integrated d Type III-Non-functionally integrated e X By checking this box, I certify that the organization is not controlled directly or indirectly by one or more disqualified persons other than foundation managers and other than one or more publicly supported organizations described in section 509(a)(1) or section 509(a)(2). f If the organization received a written determination from the IRS that it is a Type I, Type II, or Type III supporting X organization, check this box g Since August 17, 2006, has the organization accepted any gift or contribution from any of the following persons? Yes No (i) A person who directly or indirectly controls, either alone or together with persons described in (ii) and 11g(i) X (iii) below, the governing body of the supported organization? 11g(ii) X (ii) A family member of a person described in (i) above? 11g(iii) X (iii) A 35% controlled entity of a person described in (i) or (ii) above? h Provide the following information about the supported organization(s). mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmm (i) Name of supported organization (ii) EIN (iii) Type of organization (described on lines 1-9 above or IRC section (see instructions)) (iv) Is the organization in col. (i) listed in your governing document? Yes (A) No (v) Did you notify (vi) Is the the organization organization in in col. (i) of your col. (i) organized support? in the U.S.? Yes No Yes (vii) Amount of monetary support No ATTACHMENT 1 (B) (C) (D) (E) Total For Paperwork Reduction Act Notice, see the Instructions for Form 990 or 990-EZ. JSA 3E1210 1.000 Schedule A (Form 990 or 990-EZ) 2013 WWP_0000343 SJC 108 Schedule A (Form 990 or 990-EZ) 2013 Page 2 Part II Support Schedule for Organizations Described in Sections 170(b)(1)(A)(iv) and 170(b)(1)(A)(vi) (Complete only if you checked the box on line 5, 7, or 8 of Part I or if the organization failed to qualify under Part III. If the organization fails to qualify under the tests listed below, please complete Part III.) Section A. Public Support Calendar year (or fiscal year beginning in) I 1 Gifts, grants, contributions, and membership fees received. (Do not include any "unusual grants.") 2 Tax revenues levied for the organization's benefit and either paid to or expended on its behalf 3 The value of services or facilities furnished by a governmental unit to the organization without charge 4 Total. Add lines 1 through 3 5 The portion of total contributions by each person (other than a governmental unit or publicly supported organization) included on line 1 that exceeds 2% of the amount shown on line 11, column (f) Public support. Subtract line 5 from line 4. 6 (a) 2009 (b) 2010 (c) 2011 (d) 2012 (e) 2013 (f) Total (a) 2009 (b) 2010 (c) 2011 (d) 2012 (e) 2013 (f) Total mmmmmm mmmmmmm mmmmmmm mmmmmmm mmmmmmm Section B. Total Support m m m m m m m m mIm Calendar year (or fiscal year beginning in) 7 8 Amounts from line 4 Gross income from interest, dividends, payments received on securities loans, rents, royalties and income from similar sources mmmmmmmmmmmmmmmmm 9 Net income from unrelated business activities, whether or not the business is regularly carried on 10 Other income. Do not include gain or loss from the sale of capital assets (Explain in Part IV.) mmmmmmmmmm mmmmmmmmmmm mm Total support. Add lines 7 through 10 mmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmI Section C. Computation of Public Support Percentage mmmmmmmm mmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmI mmmmmmmmmmmmmmmmmI 11 12 13 Gross receipts from related activities, etc. (see instructions) 12 First five years. If the Form 990 is for the organization's first, second, third, fourth, or fifth tax year as a section 501(c)(3) organization, check this box and stop here 14 14 Public support percentage for 2013 (line 6, column (f) divided by line 11, column (f)) 15 15 Public support percentage from 2012 Schedule A, Part II, line 14 16a 33 1/3 % support test - 2013. If the organization did not check the box on line 13, and line 14 is 33 1/3 % or more, check this box and stop here. The organization qualifies as a publicly supported organization b 33 1/3 % support test - 2012. If the organization did not check a box on line 13 or 16a, and line 15 is 33 1/3 % or more, check this box and stop here. The organization qualifies as a publicly supported organization 17a 10%-facts-and-circumstances test - 2013. If the organization did not check a box on line 13, 16a, or 16b, and line 14 is 10% or more, and if the organization meets the "facts-and-circumstances" test, check this box and stop here. Explain in Part IV how the organization meets the "facts-and-circumstances” test. The organization qualifies as a publicly supported organization b 10%-facts-and-circumstances test - 2012. If the organization did not check a box on line 13, 16a, 16b, or 17a, and line 15 is 10% or more, and if the organization meets the "facts-and-circumstances" test, check this box and stop here. Explain in Part IV how the organization meets the "facts-and-circumstances" test. The organization qualifies as a publicly supported organization 18 Private foundation. If the organization did not check a box on line 13, 16a, 16b, 17a, or 17b, check this box and see instructions % % mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmI mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmI mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmI Schedule A (Form 990 or 990-EZ) 2013 JSA 3E1220 1.000 WWP_0000344 SJC 109 Schedule A (Form 990 or 990-EZ) 2013 Page 3 Support Schedule for Organizations Described in Section 509(a)(2) (Complete only if you checked the box on line 9 of Part I or if the organization failed to qualify under Part II. If the organization fails to qualify under the tests listed below, please complete Part II.) Section A. Public Support Part III Calendar year (or fiscal year beginning in) 1 I (a) 2009 (b) 2010 (c) 2011 (d) 2012 (e) 2013 (f) Total (a) 2009 (b) 2010 (c) 2011 (d) 2012 (e) 2013 (f) Total Gifts, grants, contributions, and membership fees received. (Do not include any "unusual grants.") 2 Gross receipts from admissions, merchandise sold or services performed, or facilities furnished in any activity that is related to the organization's tax-exempt purpose 3 mmmmmm m Gross receipts from activities that are not an unrelated trade or business under section 513 4 Tax revenues levied for the organization's benefit and either paid to or expended on its behalf 5 The value of services mmmmmmm or facilities furnished by a governmental unit to the organization without charge 6 Total. Add lines 1 through 5 mmmmmmm mmmmmmm mmmm 7 a Amounts included on lines 1, 2, and 3 received from disqualified persons b Amounts included on lines 2 and 3 received from other than disqualified persons that exceed the greater of $5,000 or 1% of the amount on line 13 for the year mmmmmmmmmmm mmmmmmmmmmmmmmmmm Section B. Total Support m m m m m m m m m m Im 8 c Add lines 7a and 7b Public support (Subtract line 7c from line 6.) Calendar year (or fiscal year beginning in) 9 Amounts from line 6 10 a Gross income from interest, dividends, payments received on securities loans, rents, royalties and income from similar sources mmmmmmmmmmmmmmmmm b Unrelated business taxable income (less section 511 taxes) from businesses mmmmmm mmmmmmmmm acquired after June 30, 1975 c Add lines 10a and 10b 11 Net income from unrelated business activities not included in line 10b, whether or not the business is regularly carried on Other income. Do not include gain or loss from the sale of capital assets (Explain in Part IV.) mmmmmmmmmmmmmmm 12 mmmmmmmmmmm mmmmmmmmmmmmmmmm 13 Total support. (Add lines 9, 10c, 11, 14 First five years. If the Form 990 is for the organization's first, second, third, fourth, or fifth tax year as a section 501(c)(3) and 12.) organization, check this box and stop here m m m m m m m m m m m m m m m m m m m m m m m m m m m m m m m m m m m m m m m m m m m m m m mI m m m m m m m m m mm mm mm mm mm mm mm mm mm mm mm mm mm mm Section C. Computation of Public Support Percentage 15 Public support percentage for 2013 (line 8, column (f) divided by line 13, column (f)) 15 16 Public support percentage from 2012 Schedule A, Part III, line 15 16 Section D. Computation of Investment Income Percentage mmmmmmmmmm mmmmmmmmmmmmmmmmmmmm 17 Investment income percentage for 2013 (line 10c, column (f) divided by line 13, column (f)) 17 18 Investment income percentage from 2012 Schedule A, Part III, line 17 18 % % % % 19 a 33 1/3 % support tests - 2013. If the organization did not check the box on line 14, and line 15 is more than 33 1/3 %, and line I I I WWP_0000345 17 is not more than 33 1/3 %, check this box and stop here. The organization qualifies as a publicly supported organization b 33 1/3 % support tests - 2012. If the organization did not check a box on line 14 or line 19a, and line 16 is more than 33 1/3 %, and 20 line 18 is not more than 33 1/3 %, check this box and stop here. The organization qualifies as a publicly supported organization Private foundation. If the organization did not check a box on line 14, 19a, or 19b, check this box and see instructions JSA 3E1221 1.000 Schedule A (Form 990 or 990-EZ) 2013 SJC 110 Schedule A (Form 990 or 990-EZ) 2013 Part IV Page 4 Supplemental Information. Provide the explanations required by Part II, line 10; Part II, line 17a or 17b; and Part III, line 12. Also complete this part for any additional information. (See instructions). ATTACHMENT 1 SCHEDULE A, PART I - INFORMATION ABOUT SUPPORTED ORGANIZATIONS (I) NAME OF SUPPORTED ORGANIZATION WOUNDED WARRIOR PROJECT, INC. TOTAL AMOUNT OF SUPPORT JSA 3E1225 2.000 (II) EIN 20-2370934 (III) TYPE OF (IV) ORGANIZATION YES NO YES NO (V) 07 X X (VI) YES NO X (VII) AMOUNT OF SUPPORT 0 0 Schedule A (Form 990 or 990-EZ) 2013 WWP_0000346 SJC 111 SCHEDULE D (Form 990) Department of the Treasury Internal Revenue Service Name of the organization OMB No. 1545-0047 Supplemental Financial Statements I I Complete if the organization answered "Yes," to Form 990, Part IV, line 6, 7, 8, 9, 10, 11a, 11b, 11c, 11d, 11e, 11f, 12a, or 12b. À¾µ· Attach to Form 990. Information about Schedule D (Form 990) and its instructions is at www.irs.gov/form990. Open to Public Inspection I Employer identification number WOUNDED WARRIOR PROJECT LT SUPPORT TRUST 37-6558533 Organizations Maintaining Donor Advised Funds or Other Similar Funds or Accounts. Part I Complete if the organization answered "Yes" to Form 990, Part IV, line 6. mmmmmmmmmmm mmmm mmmmmmm mmmmmmmmmm (a) Donor advised funds (b) Funds and other accounts Total number at end of year Aggregate contributions to (during year) Aggregate grants from (during year) Aggregate value at end of year Did the organization inform all donors and donor advisors in writing that the assets held in donor advised funds are the organization's property, subject to the organization's exclusive legal control? Did the organization inform all grantees, donors, and donor advisors in writing that grant funds can be used only for charitable purposes and not for the benefit of the donor or donor advisor, or for any other purpose conferring impermissible private benefit? 1 2 3 4 5 6 mmmmmmmmmmm Yes No mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm Yes No Conservation Easements. Complete if the organization answered "Yes" to Form 990, Part IV, line 7. Part II Purpose(s) of conservation easements held by the organization (check all that apply). Preservation of land for public use (e.g., recreation or education) Preservation of an historically important land area Protection of natural habitat Preservation of a certified historic structure Preservation of open space Complete lines 2a through 2d if the organization held a qualified conservation contribution in the form of a conservation easement on the last day of the tax year. 1 2 mmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmm mmmmmm mmmmmmmmmmmmmmmmmmmmmmmmm Held at the End of the Tax Year 6 2a Total number of conservation easements 2b Total acreage restricted by conservation easements 2c Number of conservation easements on a certified historic structure included in (a) Number of conservation easements included in (c) acquired after 8/17/06, and not on a 2d historic structure listed in the National Register Number of conservation easements modified, transferred, released, extinguished, or terminated by the organization during the tax year Number of states where property subject to conservation easement is located Does the organization have a written policy regarding the periodic monitoring, inspection, handling of violations, and enforcement of the conservation easements it holds? Yes No Staff and volunteer hours devoted to monitoring, inspecting, and enforcing conservation easements during the year 7 Amount of expenses incurred in monitoring, inspecting, and enforcing conservation easements during the year 8 Does each conservation easement reported on line 2(d) above satisfy the requirements of section 170(h)(4)(B) (i) and section 170(h)(4)(B)(ii)? Yes In Part XIII, describe how the organization reports conservation easements in its revenue and expense statement, and balance sheet, and include, if applicable, the text of the footnote to the organization's financial statements that describes the organization's accounting for conservation easements. a b c d 3 I 4 5 I I I mmmmmmmmmmmmmmmmmmmmmmm $ mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 9 Part III 1a b 2 a b No Organizations Maintaining Collections of Art, Historical Treasures, or Other Similar Assets. Complete if the organization answered "Yes" to Form 990, Part IV, line 8. If the organization elected, as permitted under SFAS 116 (ASC 958), not to report in its revenue statement and balance sheet works of art, historical treasures, or other similar assets held for public exhibition, education, or research in furtherance of public service, provide, in Part XIII, the text of the footnote to its financial statements that describes these items. If the organization elected, as permitted under SFAS 116 (ASC 958), to report in its revenue statement and balance sheet works of art, historical treasures, or other similar assets held for public exhibition, education, or research in furtherance of public service, provide the following amounts relating to these items: (i) Revenues included in Form 990, Part VIII, line 1 $ (ii) Assets included in Form 990, Part X $ If the organization received or held works of art, historical treasures, or other similar assets for financial gain, provide the following amounts required to be reported under SFAS 116 (ASC 958) relating to these items: Revenues included in Form 990, Part VIII, line 1 $ Assets included in Form 990, Part X $ mmmmmmmmmmmmmmmmmmmmmmmmmmmmm m m m m m m m m m m m m m m m m m m m m m m m m m m m m m m m m m m m II m m m m m m mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm II For Paperwork Reduction Act Notice, see the Instructions for Form 990. JSA 3E1268 2.000 Schedule D (Form 990) 2013 WWP_0000347 SJC 112 Schedule D (Form 990) 2013 Part III 3 Page 2 Organizations Maintaining Collections of Art, Historical Treasures, or Other Similar Assets (continued) Using the organization's acquisition, accession, and other records, check any of the following that are a significant use of its collection items (check all that apply): Public exhibition Loan or exchange programs a d Scholarly research Other b e Preservation for future generations c 4 Provide a description of the organization's collections and explain how they further the organization's exempt purpose in Part XIII. 5 During the year, did the organization solicit or receive donations of art, historical treasures, or other similar assets to be sold to raise funds rather than to be maintained as part of the organization's collection? Yes No mmmmmm Part IV Escrow and Custodial Arrangements. Complete if the organization answered "Yes" to Form 990, Part IV, line 9, or reported an amount on Form 990, Part X, line 21. 1a Is the organization an agent, trustee, custodian or other intermediary for contributions or other assets not included on Form 990, Part X? b If "Yes," explain the arrangement in Part XIII and complete the following table: Amount c Beginning balance 1c d Additions during the year 1d e Distributions during the year 1e f Ending balance 1f 2a Did the organization include an amount on Form 990, Part X, line 21? b If "Yes," explain the arrangement in Part XIII. Check here if the explanation has been provided in Part XIII mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm m m m m m m m m m m m m m m m m m m mm mm mm mm m m m m m Part V Yes No Yes No Endowment Funds. Complete if the organization answered "Yes" to Form 990, Part IV, line 10. (a) Current year mmmm mmmmmmmmmmm mmmmmmmmmmmmm mmmmmm mmmmmmmmmmm mmmmm mmmmmmmm (b) Prior year (c) Two years back (d) Three years back (e) Four years back 1a Beginning of year balance b Contributions c Net investment earnings, gains, and losses d Grants or scholarships e Other expenditures for facilities and programs f Administrative expenses g End of year balance Provide the estimated percentage of the current year end balance (line 1g, column (a)) held as: Board designated or quasi-endowment % Permanent endowment % Temporarily restricted endowment % The percentages in lines 2a, 2b, and 2c should equal 100%. 3a Are there endowment funds not in the possession of the organization that are held and administered for the organization by: (i) unrelated organizations (ii) related organizations b If "Yes" to 3a(ii), are the related organizations listed as required on Schedule R? 4 Describe in Part XIII the intended uses of the organization's endowment funds. 2 a b c I I I mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmm Part VI No Land, Buildings, and Equipment. Complete if the organization answered "Yes" to Form 990, Part IV, line 11a. See Form 990, Part X, line 10. Description of property mmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmm mmmmmmmmmm mmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmm (a) Cost or other basis (investment) (b) Cost or other basis (other) (c) Accumulated depreciation 1a Land b Buildings c Leasehold improvements d Equipment e Other Total. Add lines 1a through 1e. (Column (d) must equal Form 990, Part X, column (B), line 10(c).) JSA 3E1269 2.000 Yes 3a(i) 3a(ii) 3b mmmmmmI (d) Book value Schedule D (Form 990) 2013 WWP_0000348 SJC 113 Schedule D (Form 990) 2013 Part VII Page (a) Description of security or category (including name of security) (b) Book value mmmmmmmmmmmmmmmmm mmmmmmmmmmmmm (1) Financial derivatives (2) Closely-held equity interests (3) Other (A) (B) (C) (D) (E) (F) (G) (H) Total. (Column (b) must equal Form 990, Part X, col. (B) line 12.) Part VIII (c) Method of valuation: Cost or end-of-year market value I Investments - Program Related. Complete if the organization answered "Yes" to Form 990, Part IV, line 11c. See Form 990, Part X, line 13. (a) Description of investment (1) (2) (3) (4) (5) (6) (7) (8) (9) Total. (Column (b) must equal Form 990, Part X, col. (B) line 13.) Part IX (b) Book value (c) Method of valuation: Cost or end-of-year market value I Other Assets. Complete if the organization answered "Yes" to Form 990, Part IV, line 11d. See Form 990, Part X, line 15. (a) Description (1) (2) (3) (4) (5) (6) (7) (8) (9) Total. (Column (b) must equal Form 990, Part X, col. (B) line 15.) Part X (b) Book value mmmmmmmmmmmmmmmmmmmmmmmmmm I Other Liabilities. Complete if the organization answered "Yes" to Form 990, Part IV, line 11e or 11f. See Form 990, Part X, line 25. (a) Description of liability 1. (1) Federal income taxes (2) (3) (4) (5) (6) (7) (8) (9) Total. (Column (b) must equal Form 990, Part X, col. (B) line 25.) (b) Book value I 2. Liability for uncertain tax positions. In Part XIII, provide the text of the footnote to the organization's financial statements that reports the organization's liability for uncertain tax positions under FIN 48 (ASC 740). Check here if the text of the footnote has been provided in Part XIII JSA 3E1270 1.000 3 Investments - Other Securities. Complete if the organization answered "Yes" to Form 990, Part IV, line 11b. See Form 990, Part X, line 12. X Schedule D (Form 990) 2013 WWP_0000349 SJC 114 Schedule D (Form 990) 2013 Part XI 1 2 a b c d e 3 4 a b c 5 a b c d e 3 4 a b c 5 1 28,385,063. 2e 3 102,420. 28,282,643. 134,721. mmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmm m m m m m m m m m m m m m m m m m m m m m m m m m m m m m m m mm mm mm mm mm mm mm mm mm mm mm mm mm mm 4c 5 134,721. 28,417,364. 2a 2b 2c 2d 4a 4b Reconciliation of Expenses per Audited Financial Statements With Expenses per Return. Complete if the organization answered "Yes" to Form 990, Part IV, line 12a. mmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmm m m mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm 134,721. mmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmm m m m m m m m m m m m m m m m m m m m m m m m m m m m m m m m mm mm mm mm mm mm mm mm mm mm mm mm mm mm Total expenses and losses per audited financial statements Amounts included on line 1 but not on Form 990, Part IX, line 25: Donated services and use of facilities Prior year adjustments Other losses Other (Describe in Part XIII.) Add lines 2a through 2d Subtract line 2e from line 1 Amounts included on Form 990, Part IX, line 25, but not on line 1: Investment expenses not included on Form 990, Part VIII, line 7b Other (Describe in Part XIII.) Add lines 4a and 4b Total expenses. Add lines 3 and 4c. (This must equal Form 990, Part I, line 18.) Part XIII 4 mmmmmmmmmmmmmmmmm 102,420. mmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmm m m mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm Total revenue, gains, and other support per audited financial statements Amounts included on line 1 but not on Form 990, Part VIII, line 12: Net unrealized gains on investments Donated services and use of facilities Recoveries of prior year grants Other (Describe in Part XIII.) Add lines 2a through 2d Subtract line 2e from line 1 Amounts included on Form 990, Part VIII, line 12, but not on line 1: Investment expenses not included on Form 990, Part VIII, line 7b Other (Describe in Part XIII.) Add lines 4a and 4b Total revenue. Add lines 3 and 4c. (This must equal Form 990, Part I, line 12.) Part XII 1 2 Page Reconciliation of Revenue per Audited Financial Statements With Revenue per Return. Complete if the organization answered "Yes" to Form 990, Part IV, line 12a. 1 2a 2b 2c 2d 2e 3 4a 4b 4c 5 134,721. 134,721. Supplemental Information. Provide the descriptions required for Part II, lines 3, 5, and 9; Part III, lines 1a and 4; Part IV, lines 1b and 2b; Part V, line 4; Part X, line 2; Part XI, lines 2d and 4b; and Part XII, lines 2d and 4b. Also complete this part to provide any additional information. SEE PAGE 5 JSA 3E1271 1.000 Schedule D (Form 990) 2013 WWP_0000350 Schedule DSJC (Form115 990) 2013 Part XIII Page 5 Supplemental Information (continued) LIABILITY FOR UNCERTAIN TAX POSITION (ASC 740) SCHEDULE D, PART X, LINE 2 FOOTNOTE FROM CONSOLIDATED FINANCIAL STATEMENTS: THE ORGANIZATION FOLLOWS AUTHORITATIVE GUIDANCE WHICH REQUIRES THE ORGANIZATION TO EVALUATE ITS TAX POSITIONS FOR ANY UNCERTAINTIES BASED ON THE TECHNICAL MERITS OF THE POSITION TAKEN. THE ORGANIZATION RECOGNIZES THE TAX BENEFIT FROM AN UNCERTAIN TAX POSITION ONLY IF IT IS MORE LIKELY THAN NOT THAT THE TAX POSITION WILL BE UPHELD ON EXAMINATION BY TAXING AUTHORITIES. AS OF SEPTEMBER 30, 2014, THE ORGANIZATION DOES NOT BELIEVE IT HAS ANY UNCERTAIN TAX POSITIONS. THE ORGANIZATION HAS FILED FOR AND RECEIVED INCOME TAX EXEMPTIONS IN THE JURISDICTIONS WHERE IT IS REQUIRED TO DO SO. ADDITIONALLY, THE ORGANIZATION HAS FILED INTERNAL REVENUE SERVICE FORM 990 TAX RETURNS AS REQUIRED AND ALL OTHER APPLICABLE RETURNS IN THOSE JURISDICTIONS WHERE IT IS REQUIRED. THE ORGANIZATION BELIEVES THAT IT IS NO LONGER SUBJECT TO U.S. FEDERAL, STATE AND LOCAL, OR NON-U.S. INCOME TAX EXAMINATIONS BY TAX AUTHORITIES FOR YEARS PRIOR TO FISCAL 2011. HOWEVER, THE ORGANIZATION IS STILL OPEN TO EXAMINATION BY TAXING AUTHORITIES FROM FISCAL YEAR 2011 FORWARD. NO INTEREST OR PENALTIES HAVE BEEN RECORDED IN THE CONSOLIDATED FINANCIAL STATEMENTS RELATED TO ANY UNCERTAIN TAX POSITIONS. Schedule D (Form 990) 2013 JSA 3E1226 1.000 WWP_0000351 SJC 116 SCHEDULE O (Form 990 or 990-EZ) Department of the Treasury Internal Revenue Service Supplemental Information to Form 990 or 990-EZ Complete to provide information for responses to specific questions on Form 990 or 990-EZ or to provide any additional information. Attach to Form 990 or 990-EZ. I Name of the organization OMB No. 1545-0047 À¾µ· Open to Public Inspection Employer identification number WOUNDED WARRIOR PROJECT LT SUPPORT TRUST 37-6558533 FORM 990, PART VI, SECTION B, LINE 11 BARCLAYS WEALTH TRUSTEES (U.S.), N.A., REVIEWS THE FORM 990. FORM 990, PART VI, SECTION B, LINE 12C ANNUALLY, THE TRUSTEE SHALL SIGN A STATEMENT THAT AFFIRMS IT HAS RECEIVED A COPY OF THE TRUST'S CONFLICT OF INTEREST POLICY, HAS READ AND UNDERSTANDS THE TRUST'S POLICY, HAS AGREED TO COMPLY WITH THE TRUST'S POLICY AND UNDERSTANDS THE TRUST HAS RECEIVED TAX EXEMPT STATUS AND, IN ORDER TO MAINTAIN ITS FEDERAL TAX EXEMPTION, IT MUST ENGAGE PRIMARILY IN ACTIVITIES THAT ACCOMPLISH ONE OR MORE OF ITS TAX-EXEMPT PURPOSES. NONCOMPLIANCE WITH THE POLICY IS DEALT WITH EXPEDITIOUSLY. FORM 990, PART VI, SECTION C, LINE 19 FORM 990 AND FINANCIAL STATEMENTS ARE MADE AVAILABLE TO THE PUBLIC UPON REQUEST THROUGH BARCLAYS WEALTH TRUSTEES (U.S.), N.A. FORM 990, PART XII, LINE 2C WITH THE ASSISTANCE OF ITS INDEPENDENT ACCOUNTANT, THE ORGANIZATION PREPARED THE RETURN AND REVIEWED IT CONSISTENT WITH ITS AUDITED FINANCIALS. THE TRUSTEE REVIEWED THE SAME AND APPROVED FOR FILING. DURING FISCAL YEAR 2014, THE PARENT ORGANIZATION, WOUNDED WARRIOR PROJECT, INC., APPROVED THE CHANGE IN INDEPENDENT AUDITOR AND TAX ADVISOR. For Privacy Act and Paperwork Reduction Act Notice, see the Instructions for Form 990 or 990-EZ. JSA 3E1227 1.000 Schedule O (Form 990 or 990-EZ) (2013) WWP_0000352 SJC 117 Schedule O (Form 990 or 990-EZ) 2013 Name of the organization Page 2 Employer identification number WOUNDED WARRIOR PROJECT LT SUPPORT TRUST ATTACHMENT 1 FORM 990, PART III, LINE 1 - ORGANIZATION'S MISSION TO PROVIDE THE ECONOMIC MEANS FOR SUPPORTIVE SERVICES TO MAINTAIN WOUNDED WARRIORS IN SETTINGS THAT ARE AS INDEPENDENT AS POSSIBLE, AND TO ASSIST WITH LONG TERM CARE NEEDS IN THE EVENT OF THE WARRIOR'S SEPARATION FROM HIS OR HER CURRENT CAREGIVER, BY REASON OF THE CAREGIVER'S DEATH, DISABILITY, OR OTHER REASONS. THE TRUST WILL MAKE DISTRIBUTIONS TO PROVIDE FOR THE NEEDS OF WARRIORS, RELATING TO THE DISABILITIES THEY HAVE SUFFERED IN THE COURSE OF, OR AS A RESULT OF, SERVICE IN THE ARMED FORCES OF THE UNITED STATES OF AMERICA ON OR AFTER SEPTEMBER 11, 2001. JSA 3E1228 1.000 Schedule O (Form 990 or 990-EZ) 2013 WWP_0000353 SJC 118 SCHEDULE R (Form 990) I I OMB No. 1545-0047 Related Organizations and Unrelated Partnerships À¾µ· Complete if the organization answered "Yes" on Form 990, Part IV, line 33, 34, 35b, 36, or 37. Department of the Treasury Internal Revenue Service I Attach to Form 990. I See separate instructions. Open to Public Inspection Information about Schedule R (Form 990) and its instructions is at www.irs.gov/form990. Name of the organization Employer identification number WOUNDED WARRIOR PROJECT LT SUPPORT TRUST Part I 37-6558533 Identification of Disregarded Entities Complete if the organization answered "Yes" on Form 990, Part IV, line 33. (a) Name, address, and EIN (if applicable) of disregarded entity (b) Primary activity (c) Legal domicile (state or foreign country) (d) Total income (e) End-of-year assets (f) Direct controlling entity (1) (2) (3) (4) (5) (6) Part II Identification of Related Tax-Exempt Organizations Complete if the organization answered "Yes" on Form 990, Part IV, line 34 because it had one or more related tax-exempt organizations during the tax year. (a) Name, address, and EIN of related organization (b) Primary activity (c) Legal domicile (state or foreign country) (d) Exempt Code section (e) Public charity status (if section 501(c)(3)) (f) Direct controlling entity (g) Section 512(b)(13) controlled entity? Yes (1) WOUNDED WARRIOR PROJECT, INC. 4899 BELFORT ROAD, SUITE 300 No 20-2370934 JACKSONVILLE, FL 32256 VETERAN ASSIS FL 501(C)(3) 07 N/A X (2) (3) (4) (5) (6) (7) For Paperwork Reduction Act Notice, see the Instructions for Form 990. JSA 3E1307 1.000 Schedule R (Form 990) 2013 WWP_0000354 SJC 119 Schedule R (Form 990) 2013 Page 2 Identification of Related Organizations Taxable as a Partnership Complete if the organization answered "Yes" on Form 990, Part IV, line 34 because it had one or more related organizations treated as a partnership during the tax year. Part III (a) Name, address, and EIN of related organization (b) Primary activity (c) Legal domicile (state or foreign country) (d) Direct controlling entity (e) Predominant income (related, unrelated, excluded from tax under sections 512-514) (f) Share of total income (g) Share of end-ofyear assets (h) Disproportionate allocations? Yes No (i) Code V-UBI amount in box 20 of Schedule K-1 (Form 1065) (j) (k) Percentage ownership General or managing partner? Yes No (1) (2) (3) (4) (5) (6) (7) Part IV Identification of Related Organizations Taxable as a Corporation or Trust Complete if the organization answered "Yes" on Form 990, Part IV, line 34 because it had one or more related organizations treated as a corporation or trust during the tax year. (a) Name, address, and EIN of related organization (b) Primary activity (c) Legal domicile (state or foreign country) (d) Direct controlling entity (e) Type of entity (C corp, S corp, or trust) (f) Share of total income (g) Share of end-of-year assets (h) Percentage ownership (i) Section 512(b)(13) controlled entity? Yes No (1) (2) (3) (4) (5) (6) (7) JSA 3E1308 1.000 Schedule R (Form 990) 2013 WWP_0000355 SJC 120 Schedule R (Form 990) 2013 Part V Page 3 Transactions With Related Organizations Complete if the organization answered "Yes" on Form 990, Part IV, line 34, 35b, or 36. Note. Complete line 1 if any entity is listed in Parts II, III, or IV of this schedule. 1 During the tax year, did the organization engage in any of the following transactions with one or more related organizations listed in Parts II-IV? a Receipt of (i) interest (ii) annuities (iii) royalties or (iv) rent from a controlled entity b Gift, grant, or capital contribution to related organization(s) c Gift, grant, or capital contribution from related organization(s) d Loans or loan guarantees to or for related organization(s) e Loans or loan guarantees by related organization(s) Yes mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm m mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm mm 1a 1b 1c 1d 1e No X X X X X f g h i j Dividends from related organization(s) Sale of assets to related organization(s) Purchase of assets from related organization(s) Exchange of assets with related organization(s) Lease of facilities, equipment, or other assets to related organization(s) 1f 1g 1h 1i 1j X X X X X k l m n o Lease of facilities, equipment, or other assets from related organization(s) Performance of services or membership or fundraising solicitations for related organization(s) Performance of services or membership or fundraising solicitations by related organization(s) Sharing of facilities, equipment, mailing lists, or other assets with related organization(s) Sharing of paid employees with related organization(s) 1k 1l 1m 1n 1o X X X X X p q Reimbursement paid to related organization(s) for expenses Reimbursement paid by related organization(s) for expenses 1p 1q X X r s Other transfer of cash or property to related organization(s) 1r Other transfer of cash or property from related organization(s) 1s If the answer to any of the above is "Yes," see the instructions for information on who must complete this line, including covered relationships and transaction thresholds. 2 (a) Name of related organization (1) WOUNDED WARRIOR PROJECT, INC. (b) Transaction type (a-s) C (c) Amount involved 28,000,000. X X (d) Method of determining amount involved FMV (2) (3) (4) (5) (6) JSA 3E1309 1.000 Schedule R (Form 990) 2013 WWP_0000356 SJC 121 Schedule R (Form 990) 2013 Part VI Page 4 Unrelated Organizations Taxable as a Partnership Complete if the organization answered "Yes" on Form 990, Part IV, line 37. Provide the following information for each entity taxed as a partnership through which the organization conducted more than five percent of its activities (measured by total assets or gross revenue) that was not a related organization. See instructions regarding exclusion for certain investment partnerships. (a) Name, address, and EIN of entity (b) Primary activity (c) Legal domicile (state or foreign country) (d) Predominant income (related, unrelated, excluded from tax under section 512-514) (e) Are all partners section 501(c)(3) organizations? Yes No (f) Share of total income (g) Share of end-of-year assets (h) Disproportionate allocations? Yes No (i) Code V-UBI amount in box 20 of Schedule K-1 (Form 1065) (j) General or managing partner? Yes (k) Percentage ownership No (1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11) (12) (13) (14) (15) (16) JSA 3E1310 1.000 Schedule R (Form 990) 2013 WWP_0000357 SJC 122 Exhibit SJC 123 DEPARTMENT OF THE TREASURY INTERNAL REVENUE SERVICE P. 0. BOX 2508 CINCINNATI, OH 4520l Date: P.U GZ81014 WOUNDED WARRIOR PROJECT LONG TERM SUPPORT TRUST 4899 BELFORT RD STE 300 JACKSONVILLE, FL 32256 Employer Identification Number: 37-6558533 DLN: 17053042306004 contact Person: CUSTOMER SERVICE Contact Telephone Number: (877) 829-5500 Accounting Period Ending: September 30 Public Charity Status: 509 (a) (3) -Form 990 Required: Yes Effective Date of Exemption: September 27, 20l3 Contribution Deductibility: Yes Addendum Applies: Yes ID# 3l954 Dear Applicant: We are pleased to inform you that upon review of your application for tax exempt status we have determined that you are exempt from Federal income tax under section SOl(c) (3) of the Internal Revenue Code. Contributions to you are deductible under section 170 of the Code. You are also qualified to receive tax deductible bequests, devises, transfers or gifts under section 2055, 2106 or 2522 of the Code. Because this letter could help resolve any questions regarding your exempt status, you should keep it in your permanent records. Organizations exempt under section SOl(c) (3) of the Code are further classified as either public charities or private foundations. We determined that you are a public charity under the Code section(s) listed in the heading of this letter. Specifically, we have determined that you are a Type I supporting organization under section 509(a) (3). A Type I supporting organization is operated, supervised, or controlled by one or more publicly supported organizations. For important information about your responsibilities as a tax-exempt organization, go to www.irs.gov/charities. Enter 11 4221-PC 11 in the search bar to view Publication 422l-PC, Compliance Guide for 50l(c) (3) Public Charities, which describes your recordkeeping, reporting, and disclosure requirements. Letter 947 WWP_0000359 SJC 124 -2- WOUNDED WARRIOR PROJECT LONG TERM We have sent a copy of this letter to your representative as indicated in your power of attorney. Sincerely, Director, Exempt Organizations Letter 947 WWP_0000360 SJC 125 Exhibit 0 SJC 126 THE SECRETARY OF VETERANS AFFAIRS WASHINGTON September 10, 2008 Mr. Ronald Drach President, Board of Directors Wounded Warrior Project 7020 A.C. Skinner Pkwy, Suite 100 Jacksonville, FL 32256 Dear Mr. Drach: I am pleased to extend recogn ition to the VVounded V\/arrior Project as a national organization for purposes of preparation, presentation, and prosecution of claims under laws administered by the Department of Veterans Affairs (VA). This recognition is accorded pursuant to 38 U.S.C. § 5902(a)(1) and 38 C.F.R. § 14.628(a) and is solely for the purpose of representation of claimants before this Department. This recognition will take effect immediately upon the date of this letter. I look forward to a productive relationship between VA and your organization in service to our Nation's veterans and their families. Sincerely yours, ~L-- James B. Peake, M.D. WWP_0000362 SJC 127 Exhibit SJC 128 Training Manual I, Adjudication of VA Benefits and Other Programs __________________________________________________________________ Training Manual I, Adjudication of VA Benefits and Other Programs Chapter 1, Lesson 1, General Information I. GENERAL INFORMATION. 38 C.F.R. §§ 3.1 – 3.43 A. B. C. D. E. F. G. Introduction to General Information 38 C.F.R. §§ 3.1 – 3.43 Definitions. 38 C.F.R. § 3.1 Periods of War. 38 C.F.R. § 3.2 Compensation. 38 C.F.R. § 3.4 Duty Periods. 38 C.F.R. § 3.6 Homicide. 38 C.F.R. § 3.11 Character of discharge. 38 C.F.R. § 3.12; Minimum active-duty service requirement. H. Major Points of Lesson. 38 C.F.R. §§ 3.1 – 3.43 II. U.S. COURT OF APPEALS FOR VETERANS CLAIMS DECISIONS. Chapter 2, Lesson 1, Relationship I. RELATIONSHIP. 38 C.F.R. §§ 3.50-3.60 A. B. C. D. E. F. Introduction Relationship. 38 C.F.R. §§ 3.50-3.60 Spouse and surviving spouse. 38 C.F.R. § 3.50 Marriage deemed valid. 38 C.F.R. § 3.52 Continuous cohabitation. 38 C.F.R. § 3.53 Marriage dates. 38 C.F.R. § 3.54 Reinstatement of benefits eligibility based on terminated marriage relationship. 38 C.F.R. § 3.55 G. Child. 38 C.F.R. § 3.57 H. Major Points of Lesson Relationship. 38 C.F.R. §§ 3.50-3.60 III. U.S. COURT OF APPEALS FOR VETERANS CLAIMS DECISIONS WWP_0000364 SJC 129 Training Manual I, Adjudication of VA Benefits and Other Programs __________________________________________________________________ Chapter 3, Lesson 1, Administrative I. ADMINISTRATIVE A. B. C. D. E. F. G. H. Introduction Administrative. 38 C.F.R. §§ 3.101-3.114 Delegations of authority. 38 C.F.R. § 3.100 Reasonable doubt. 38 C.F.R. § 3.102 Procedural due process and appellate rights. 38 C.F.R. § 3.103 Finality of decisions. 38 C.F.R. § 3.104 Revision of decisions. 38 C.F.R. § 3.105 Renouncement. 38 C.F.R. § 3.106 State Department as Agent of Department of Veterans Affairs. 38 C.F.R. 3.108 I. Time limit. 38 C.F.R. § 3.109; J. Computation of time limit. 38 C.F.R. § 3.110 K. Change of law or Department of Veterans Affairs issue. 38 C.F.R. § 3.114 L. Major Points of Lesson Administrative. 38 C.F.R. §§ 3.101-3.114 II. U. S. COURT OF APPEALS FOR VETERANS CLAIMS DECISIONS Chapter 4, Lesson 1, Claims I. CLAIMS A. B. C. D. E. F. G. H. I. J. Introduction Claims. 38 C.F.R. §§ 3.150-3.159 Forms to be furnished. 38 C.F.R. § 3.150 Claims for disability benefits. 38 C.F.R. § 3.151 Claims for death benefits. 38 C.F.R. § 3.152 Claims filed with Social Security. 38 C.F.R. § 3.153 Injury due to hospital treatment, etc. 38 C.F.R. § 3.154 How to file a claim. 38 C.F.R. § 3.155 New and material evidence. 38 C.F.R. § 3.156 Abandoned claims. 38 C.F.R. § 3.158 Department of Veterans Affairs assistance in developing claims. 38 C.F.R. § 3.159 K. Types of claims. 38 C.F.R. 3.160 M. Major Points of Lesson Claims. 38 C.F.R. § 3.150-3.160 II. U. S. COURT OF APPEALS FOR VETERANS CLAIMS DECISIONS WWP_0000365 SJC 130 Training Manual I, Adjudication of VA Benefits and Other Programs __________________________________________________________________ Chapter 5, Lesson 1, Service Connection General I. SERVICE CONNECTION. 38 C.F.R. §§ 3.303-3.317 and 3.383 A. B. C. D. E. F. G. H. I. J. K. L. M. N. O. P. Introduction Service Connection. 38 C.F.R. §§ 3.303-3.317 and 3.383 Primary methods to establish service connection General principles for service connection. 38 C.F.R. § 3.303 Direct service connection. General. 38 C.F.R. § 3.304(a) Direct service connection. Presumption of soundness. 38 C.F.R. 3.304(b) Direct service connection. Combat. 38 C.F.R. 3.304(d) Direct service connection. Prisoners of war. 38 C.F.R. 3.304(e) Direct service connection. Post traumatic stress disorder. 38 C.F.R. 3.340(f) Aggravation of pre-service disability. General. 38 C.F.R. § 3.306(a) Aggravation of pre-service disability. Wartime service. 38 C.F.R. § 3.304(b) Secondary service connection. General. 38 C.F.R. § 3.310(a) Secondary service connection. Aggravation. 38 C.F.R. § 3.310(b) Secondary service connection. Cardiovascular. 38 C.F.R. 3.310(c) Service Connection on the basis of paired organs, 38 C.F.R. § 3.383 Compensation for certain disabilities due to undiagnosed Illnesses. 38 C.F.R. § 3.317 Major points of Lesson Service Connection. 38 C.F.R. §§ 3.303-3.317 and 3.383 II. U.S. COURT OF APPEALS FOR VETERANS CLAIMS DECISIONS Chapter 5, Lesson 2, Presumptive Service Connection I. PRESUMPTIVE SERVICE CONNECTION. 38 C.F.R. §§ 3.303, 3.307, 3.309, 3.318 A. B. C. D. E. F. Introduction. . 38 C.F.R. §§ 3.303, 3.307, 3.309, 3.318 Principles of presumptive service connection. 38 C.F.R. § 3.307 Chronic diseases. 38 C.F.R. § 3.309(a) Tropical diseases. 38 C.F.R. § 3.309(b) Diseases specific to former prisoners of war. 38 C.F.R. § 3.309(c) Diseases associated with exposure to certain herbicide agents. 38 C.F.R. § 3.309(e) G. Service connection for amyotrophic lateral sclerosis. 38 C. F. R. § 3.318 H. Major points of Lesson. 38 C.F.R. §§ 3.303, 3.307, 3.309, 3.318 II. U.S. COURT OF APPEALS FOR VETERANS CLAIMS DECISIONS WWP_0000366 SJC 131 Training Manual I, Adjudication of VA Benefits and Other Programs __________________________________________________________________ Chapter 6, Lesson 1, Special Monthly Compensation, 38 U.S.C. § 1114(k) I. SPECIAL MONTHLY COMPENSATION. 38 U.S.C. § 1114(k), 38 C.F.R. § 3.350 A. Introduction. 38 U.S.C. § 1114(k), 38 C.F.R. § 3.350 B. Basic Levels of Special Monthly Compensation C. SMC(k) for Loss or Loss of use of a Creative Organ. 38 C.F.R. § 3.350(a)(1) D. SMC(k) for Loss of Loss of Use of a Foot or Hand. 38 C.F.R. § 3.350(a)(2) D1. SMC(k) for Loss of Use of Hand D2. SMC(k) for Loss of Hand D3. SMC(k) for Loss of Use of Foot D4. SMC(k) for Loss of Use of Lower Extremity Presumptively E. SMC(k) for Loss of use of Both Buttocks. 38 C.F.R. § 3.350(a)(3) F. SMC(k) for Blindness in One Eye. 38 C.F.R. § 3.350(a)(4) G. SMC(k) for Deafness. 38 C.F.R. § 3.350(a)(5) H. SMC(k) for Aphonia. 38 C.F.R. § 3.350(a)(6) I. SMC(k) for Anatomical Loss of One or Both Breasts. 38 C.F.R. § 3.350(a) J. Major Points of Lesson. 38 U.S.C. § 1114(k), 38 C.F.R. § 3.350 II. U.S. COURT OF APPEALS FOR VETERANS CLAIMS DECISIONS Chapter 6, Lesson 2, Special Monthly Compensation, 38 U.S.C. §§ 1114(l)-(o) I. SPECIAL MONTHLY COMPENSATION. 38 U.S.C. §§ 1114(l)-(o), 38 C.F.R. §§ 3.350, 3.352 A. Introduction Special Monthly Compensation. 38 U.S.C. §§ 1114(l)-(o), 38 C.F.R. §§ 3.350, 3.352 B. Determining the Levels of Loss and Loss of Use for SMC (l) through (o). 38 C.F.R. § 3.350(b) through (e) C. SMC(l) – Ratings under 38 U.S.C. § 1114(l) C1. SMC(l), Example of Loss of Hand and Loss of Use of Foot C2. SMC(l), Example of Regular Aid and Attendance D. SMC(l 1/2) – Ratings under 38 U.S.C. § 1114(p)(l ½) E. SMC(m) – Ratings under 38 U.S.C. § 1114(m) F. SMC(m 1/2) – Ratings under 38 U.S.C. § 1114(p)(m ½) G. SMC(n) – Ratings under 38 U.S.C. § 1114(n) H. SMC(n 1/2) – Ratings under 38 U.S.C. § 1114(p)(n ½) I. SMC(o) – Ratings under 38 U.S.C. § 1114(o) J. Triple Extremity Rate WWP_0000367 SJC 132 Training Manual I, Adjudication of VA Benefits and Other Programs __________________________________________________________________ K. Additional Special Monthly Compensation Elevations for Independent Disabilities Rated 50% or 100% K1. Half Step Increase K2. Full Step Increase L. Half and Full Step Increases Based on Vision Loss. M. Major Points of Lesson Special Monthly Compensation. 38 U.S.C. §§ 1114(l)-(o), 38 C.F.R. §§ 3.350, 3.352 II U.S. COURT OF APPEALS FOR VETERANS CLAIMS DECISIONS Chapter 6, Lesson 3, Special Monthly Compensation, 38 C.F.R. §§ 3.350, 3.352 I. SPECIAL MONTHLY COMPENSATION RATINGS FOR AID AND ATTENDANCE AND HOUSEBOUND STATUS. 38 C.F.R. §§ 3.350, 3.352 A. Introduction Special Monthly Compensation. 38 C.F.R. §§ 3.350, 3.352 B. SMC(s) for Total Rating Plus 60 percent or Housebound Status. 38 U.S.C. § 1114(s), 38 C.F.R. § 3.350(i) B1. Total 100% Rating Plus 60 Percent B2. Permanently Housebound In Fact C. SMC(l) Regular Aid and Attendance Benefits (A &A) and Permanently Bedridden. 38 U.S.C. § 1114(l) D. Special Aid And Attendance Benefits. 38 U.S.C. § 1114(r-1) E. Special Aid and Attendance Benefits – Higher Level of Care. 38 U.S.C. § 1114(r-2) F. Special Aid and Attendance due to Traumatic Brain Injury (TBI). 38 U.S.C. 1114(t) G. Major Points of Lesson Special Monthly Compensation. 38 C.F.R. §§ 3.350, 3.352 II. U.S. COURT OF APPEALS FOR VETERANS CLAIMS DECISIONS Chapter 7, Lesson 1, General Rating Considerations and Ratings for Special Purposes I. GENERAL RATING CONSIDERATIONS. 38 C.F.R. §§ 3.321-3.343 A. B. C. D. Introduction. 38 C.F.R. §§ 3.321-3.344 General rating considerations. 38 C.F.R. § 3.321 Rating disabilities aggravated by service. 38 C.F.R. §§ 3.322 Multiple non-compensable service-connected disabilities. 38 C.F.R. § 3.324 E. Independent medical opinions. 38 C.F.R. § 3.328 WWP_0000368 SJC 133 Training Manual I, Adjudication of VA Benefits and Other Programs __________________________________________________________________ F. Total and permanent total ratings and unemployability. 38 C.F.R. § 3.340 G. Total disability ratings for compensation purposes. 38 C.F.R. § 3.341 H. Continuance of total disability ratings. 38 C.F.R. § 3.343 II. RATING FOR SPECIAL PURPOSES. 38 C.F.R. §§ 3.353-3.363 A. Introduction Ratings for Special Purposes. 38 C.F.R. §§ 3.353-3.363 B. Determinations of incompetency, competency and insanity. 38 C.F.R. § 3.353 C. Determinations of insanity. 38 C.F.R. §§ 3.353 and 3.354 D. Testamentary capacity for insurance purposes. 38 C.F.R. § 3.355 E. Conditions which determine permanent incapacity for self-support. 38 C.F.R. § 3.356 F. Civil service preference ratings. 38 C.F.R. § 3.357 G. Determinations for disability or death from hospitalization, medical or surgical treatment, examinations or vocational rehabilitation training. 38 C.F.R. § 3.358 H. Determinations of service connection for former members of the armed forces of Czechoslovakia or Poland. . 38 C.F.R. § 3.359 I. Service connected health care eligibility of certain persons administratively discharged under other than honorable condition. 38 C.F.R. § 3.360 J. Benefits under 38 U.S.C. § 1151(A) for additional disability or death due to hospital care, medical or surgical treatment, examination, training and rehabilitation services, or compensated work therapy program. 38 C.F.R. § 3.360 K. Offsets under 38 U.S.C. § 1151(B) of benefits awarded under 38 U.S.C. § 1151(A). 38 C.F.R. § 3.362. L. Bar to benefits under 38 U.S.C. § 1151. 38 C.F.R. § 3.363 III. U.S. COURT OF APPEALS FOR VETERANS CLAIMS DECISIONS Chapter 8,Lesson 1, Rating Considerations Relative to Specific Diseases I. RATING CONSIDERATIONS RELATIVE TO SPECIFIC DISEASES. 38 C.F.R. §§ 3.3.70-3.385 A. Introduction Rating Considerations Relative to Specific Diseases. 38 C.F.R. §§ 3.3.70-3.385 B. Pulmonary tuberculosis shown by X-ray in active service. 38 C.F.R. § 3.370 C. Presumptive service connection for tuberculosis disease; wartime and service on or after January 1, 1947. 38 C.F.R. § 3.371 D. Initial grant following inactivity of tuberculosis. 38 C.F.R. § 3.372 E. Effect of diagnosis of active tuberculosis. 38 C.F.R. § 3.374 WWP_0000369 SJC 134 Training Manual I, Adjudication of VA Benefits and Other Programs __________________________________________________________________ F. Determination of inactivity (complete arrest) in tuberculosis. 38 C.F.R. § 3.375 G. Changes from active tuberculosis pension cases. 38 C.F.R. § 3.378 H. Anterior poliomyelitis. 38 C.F.R. § 3.379 I. Diseases of allergic etiology. 38 C.F.R. § 3.380 J. Service connection of dental conditions for treatment purposes. 38 C.F.R. § 3.381 K. Special consideration for paired organs or extremities. 38 C.F.R. § 3.383 L. Psychosis. 38 C.F.R. § 3.384 M. Disability due to impaired hearing. 38 C.F.R. § 3.385 N. Major Points of Lesson Rating Considerations Relative to Specific Diseases. 38 C.F.R. §§ 3.3.70-3.385 II. U.S. COURT OF APPEALS FOR VETERANS CLAIMS DECISIONS Chapter 9, Lesson 1, Effective Dates 1 I. EFFECTIVE DATES – GENERAL. 38 C.F.R. §§ 3.400(a)-(r) A. B. C. D. E. F. G. H. I. J. K. L. M. N. O. P. Introduction Effective Dates - General. 38 C.F.R. §§ 3.400(a)-(r) Unless specifically provided. 38 C.F.R. § 3.400(a) Disability benefits. 38 C.F.R. § 3.400(b) Death benefits. 38 C.F.R. § 3.400(c) Apportionment. 38 C.F.R. § 3.400(e) Federal employees’ compensation cases. 38 C.F.R. § 3.400(f) Correction of military records. 38 C.F.R. § 3.400(g) Difference of opinion. 38 C.F.R. § 3.400(h) Disability or death due to hospitalization, etc. 38 C.F.R. § 3.400(i) Election of Department of Veterans Affairs benefits. 38 C.F.R. § 3.400(j) Error. 38 C.F.R. § 3.400(k) Foreign residence. 38 C.F.R. § 3.400(l) Forfeiture. 38 C.F.R. § 3.400(m) Guardian. 38 C.F.R. § 3.400(n) Increases. 38 C.F.R. § 3.400(o) Liberalizing laws and Department of Veterans Affairs issues. 38 C.F.R. § 3.400(p) Q. New and material evidence – reopened claim. 38 C.F.R. § 3.400(q) Q1. New and material evidence – service department records. 38 C.F.R. § 3.400(q) R. Reopened claims. 38 C.F.R. § 3.400(r) WWP_0000370 SJC 135 Training Manual I, Adjudication of VA Benefits and Other Programs __________________________________________________________________ Chapter 9, Lesson 2, Effective Dates 2 I. EFFECTIVE DATES – GENERAL. 38 C.F.R. §§ 3.400(s)-(z), 3.155, 3.157 A. Introduction Effective Dates – General. 38 C.F.R. §§ 3.400(s)-(z), 3.155, 3.157 B. Renouncement. 38 C.F.R. § 3.400(s) C. Whereabouts now known. 38 C.F.R. § 3.400(t) D. Void, annulled, or terminated marriage of a child. 38 C.F.R. § 3.400(u) E. Termination of remarriage of surviving spouse. 38 C.F.R. § 3.400(v) F. Termination of relationship. 38 C.F.R. § 3.400(w) G. Effective date of termination of incompetency. 38 C.F.R. § 3.400(x) H. Effective date of determination restoring competency. 38 C.F.R. § 3.400(y) I. Claims based on service in the Women’s Air Forces Service Pilots (WASP). 38 C.F.R. § 3.400(z) J. Informal Claims – General. 38 C.F.R. § 3.155. K. Report of Examination or Hospitalization as Informal Claim for Increase or to Reopen. 38 C.F.R. § 3.157 L. Major points of Section Effective Dates – General. 38 C.F.R. §§ 3.400(s)-(z), 3.155, 3.157 II. EFFECTIVE DATES – VETERANS. 38 C.F.R. §§ 3.401(a)-(i) A. Introduction Effective Dates – Veterans. 38 C.F.R. §§ 3.401(a)-(i) B. Aid and Attendance and housebound benefits. 38 C.F.R. § 3.400(a) C. Dependent, additional compensation or pension for. 38 C.F.R. § 3.400(b) D. Divorce of Veteran and spouse. 38 C.F.R. § 3.400(c) E. Institutional awards. 38 C.F.R. § 3.400(d) F, Retirement pay. 38 C.F.R. § 3.400(e) III. U. S. COURT OF APPEALS FOR VETERANS CLAIMS DECISIONS Chapter 10, Lesson 1, Apportionments I. APPORTIONMENTS. 38 C.F.R. §§ 3.450-3.461 A. B. C. D. Introduction Apportionments. 38 C.F.R. §§ 3.450-3.461 General. 38 C.F.R. § 3.450 Special Apportionments. 38 C.F.R. § 3.451 Veterans benefits apportioned. 38 C.F.R. § 3.452 WWP_0000371 SJC 136 Training Manual I, Adjudication of VA Benefits and Other Programs __________________________________________________________________ E. Veterans compensation or service pension or retirement pay. 38 C.F.R. § 3.453 F. Veterans disability pension. 38 C.F.R. § 3.454 G. Veteran’s benefits not apportionable. 38 C.F.R. § 3.458 H. Death Compensation. 38 C.F.R. § 3.459 I. Death Pension. 38 C.F.R. § 3.460 J. Dependency and indemnity compensation. 38 C.F.R. § 3.461 K. Major Points of Lesson Apportionments. 38 C.F.R. §§ 3.450-3.461 Chapter 11, Lesson 1, Reductions and Discontinuances I. REDUCTIONS AND DISCONTINUANCES. 38 C.F.R. §§ 3.500-3.504 A. Introduction Reductions and Discontinuances. 38 C.F.R. §§ 3.5003.504 B. General. 38 C.F.R. § 3.500 C. Veterans. 38 C.F.R. § 3.501 D. Surviving spouses. 38 C.F.R. § 3.502 E. Children. 38 C.F.R. § 3.503 F. Parents; aid and attendance. 38 C.F.R. § 3.504 G. Major Points of Lesson Reductions and Discontinuances. 38 C.F.R. §§ 3.500-3.504 Chapter 12, Lesson 1, Adjustments and Resumptions I. ADJUSTMENTS AND RESUMPTIONS. 38 C.F.R. §§ 3.650-3.669 A. B. C. D. E. F. G. H. I. J. K. L. Introduction Adjustments and Resumptions. 38 C.F.R. §§ 3.650-3.669 Rate for additional dependent. 38 C.F.R. § 3.650 Change in status of dependents. 38 C.F.R. § 3.651 Periodic certification of continued eligibility. 38 C.F.R. § 3.652 Foreign residence. 38 C.F.R. § 3.653 Active service pay. 38 C.F.R. § 3.654 Failure to report for Department of Veterans Affairs examination. 38 C.F.R. § 3.655. Disappearance of veterans. 38 C.F.R. § 3.656. Eligibility verification reports. 38 C.F.R. § 3.661 Incarcerated beneficiaries and fugitive felons – compensation. 38 C.F.R. § 3.665. Pension. 38 C.F.R. § 3.666. School Attendance. 38 C.F.R. § 3.667. Forfeiture. 38 C.F.R. § 3.669 WWP_0000372 SJC 137 Training Manual I, Adjudication of VA Benefits and Other Programs __________________________________________________________________ Chapter 13, Lesson 1, Concurrent Benefits and Elections and Retirement I. CONCURRENT BENEFITS AND ELECTIONS. 38 C.F.R. §§ 3.700-3.715 A. Introduction Concurrent Benefits and Elections. 38 C.F.R. §§ 3.7003.715 B. General. 38 C.F.R. § 3.700 C. Elections of pension or compensation. 38 C.F.R. § 3.701 D. Dependency and indemnity compensation. 38 C.F.R. § 3.702 E. Dependents’ educational assistance. 38 C.F.R. § 3.703 F. Federal Employees’ Compensation. 38 C.F.R. § 3.708 H. Major Points of Lesson Concurrent Benefits and Elections. 38 C.F.R. §§ 3.700-3.715 II. RETIREMENT. 38 C.F.R. §§ 3.750-3.753 A. Introduction Retirement. 38 C.F.R. §§ 3.750-3.753 B. Retirement pay. 38 C.F.R. § 3.750 C. Statutory awards; retired service personnel. 38 C.F.R. § 3.751 D. Public Health Service. 38 C.F.R. § 3.753 III. U. S. COURT OF APPEALS FOR VETERANS CLAIMS DECISIONS Chapter 14, Lesson 1, Special Benefits I. SPECIAL BENEFITS. 38 C.F.R. §§ 3.800-3.816 A. B. C. D. E. F. G. H. I. J. K. L. Introduction Special Benefits. 38 C.F.R. §§ 3.800-3.816 Medal of Honor. 38 C.F.R. § 3.802 Loan guarantee for surviving spouses; certification. 38 C.F.R. § 3.807 Death gratuity; certification. 38 C.F.R. § 3.806 Dependents educational assistance; certification. 38 C.F.R. § 3.807 Automobiles or other conveyances; certification. 38 C.F.R. § 3.808. Specially adapted housing under 38 U.S.C. § 2101(a). 38 C.F.R. § 3.809 Special home adaptation grant under 38 U.S.C. § 2101(b). 38 C.F.R. § 3.809a Clothing allowance. 38 C.F.R. § 3.810 Awards under the Nehmer court orders for disability or death caused by a condition presumptively associated with herbicide exposure. 38 C.F.R. § 3.816 Federal Register/ Vol. 75, No 173, September 8, 2010 Major Points of Lesson Special Benefits. 38 C.F.R. §§ 3.800-3.816 Chapter 15, Lesson 1, Incompetents, Forfeiture, and Protection WWP_0000373 SJC 138 Training Manual I, Adjudication of VA Benefits and Other Programs __________________________________________________________________ I. INCOMPETENTS, GUARDIANSHIP AND INSTITUTIONAL AWARDS. 38 C.F.R. §§ 3.850–3.857 A. Introduction Incompetents, Guardianship, and Institutional Awards 38 C.F.R. §§ 3.850–3.857 B. General. 38 C.F.R. § 3.850 C. Institutional awards. 38 C.F.R. § 3.852 D. Incompetents, estate over $25,000. 38 C.F.R. § 3.853 E. Limitation of payments for minor. 38 C.F.R. § 3.854 F. Beneficiary rated or reported incompetent. 38 C.F.R. § 3.855 G. Children’s benefits to fiduciary of surviving spouse. 38 C.F.R. § 3.857 II. FORFEITURE. 38 C.F.R. §§ 3.900-3.904 A. B. C. E. F. G. Introduction Forfeiture. 38 C.F.R. §§ 3.900-3.904 Forfeiture. 38 C.F.R. § 3.900 Fraud. 38 C.F.R. § 3.901 Treasonable acts. 38 C.F.R. § 3.902 Subversive activities. 38 C.F.R. § 3.903 Effect of forfeiture after a veteran’s death. 38 C.F.R.§ 3.904 III. PROTECTION. 38 C.F.R. §§ 3.900-3.951-3.960 A. B. C. E. F. G. H. I. IV. Introduction Protection. 38 C.F.R. §§ 3.900-3.951-3.960 Preservation of disability ratings. 38 C.F.R. § 3.951 Protected ratings. 38 C.F.R. § 3.952 Burial allowance. 38 C.F.R. § 3.954 Service connection. 38 C.F.R. § 3.957 Tuberculosis. 38 C.F.R. § 3.959 Section 306 and Old-Law Pension protection. 38 C.F.R. § 3.960 Major Points of Lesson Protection. 38 C.F.R. §§ 3.900-3.951-3.960 U.S. COURT OF APPEALS FOR VETERANS CLAIMS DECISIONS Chapter 16, Lesson 1, Appeals I. ACTIONS AND APPEAL ACTIONS AT THE AGENCY OF ORIGINAL JURISDICTION (AOJ) A. Introduction Appeals at the Agency of Original Jurisdiction B. Applicability of provisions concerning Notice of Disagreement. 38 C.F.R. 19.23 C. Action of agency or original jurisdiction on Notice of Disagreement required on standardized form. 38 C.F.R. 19.24 WWP_0000374 SJC 139 Training Manual I, Adjudication of VA Benefits and Other Programs __________________________________________________________________ D. Notification by Agency of Original Jurisdiction or right to appeal. 38 C.F.R. § 19.25 E. Action by agency of original jurisdiction on notice of disagreement. 38 C.F.R. § 19.26 F. Statement of the Case. 38 C.F.R. § 19.29 G. The Supplemental Statement of the Case (SSOC) 38 C.F.R. § 19.31 H. Notification of certification of appeal and transfer of appellate record. 38 C.F.R. § 19.36 I. Major Points of Lesson Appeals at the Agency of Original Jurisdiction II. ACTIONS TAKEN BY THE BOARD OF VETERANS APPEALS UPON RECEIPT OF THE APPEAL FROM THE AGENCY OF ORIGINAL JURISDICTION (AOJ). A. B. C. D. E. F. G. H. I. J. K. L. Introduction Appeals at the Board of Veterans’ Appeals Definitions. 38 C.F.R. 20.3 What constitutes an appeal. 38 C.F.R. 20.200 Notice of disagreement. 38 C.F.R. 20.201 Substantive appeal – Form 9. 38 C.F.R. 20.202 Request for change in representation, request for personal hearing, or submission of additional evidence following certification of an appeal to the Board of Veterans’ Appeals. 38 C.F.R. § 20.1304 Hearings before the Board on Appeal. 38 C.F.R. § 20.700 Withdrawal of Notice of Disagreement or Substantive Appeal. 38 C.F.R. § 20.204 Development at the Board of Veterans’ Appeals. 38 C.F.R. § 20.901 Decisions by the Board of Veterans’ Appeals. 38 C.F.R. § 19.7 Action by the agency of original jurisdiction when remand received. 38 C.F.R. § 19.38 Major Points of Section Appeals at the Board of Veterans’ Appeals III. U.S. COURT OF APPEALS FOR VETERANS CLAIMS DECISIONS Chapter 17, Lesson 1, Non-Service-Connected Pension I. NON-SERVICE-CONNECTED PENSION. 38 C. F. R. §§ 3.1(w) - 3.3(a)(3) A. B. C. D. E. F. G. Introduction Prior Pension Programs. 38 C. F. R. §§ 3.1(w) - 3.3(a)(3) Improved Pension Plan under 38 C. F. R. §§ 3.1(w) - 3.3(a)(3) Service Requirement. 38 C.F.R. § 3.3 Qualifying Periods of War. 38 C.F.R. § 3.2 Disability Requirement. 38 C.F.R. § 3.3(3) Income Requirement. 38 C.F.R. § 3.3(3) Aid and Attendance and Housebound Benefits for Pension Purposes WWP_0000375 SJC 140 Training Manual I, Adjudication of VA Benefits and Other Programs __________________________________________________________________ H. Major Points of Lesson Pension Programs. 38 C. F. R. §§ 3.1(w) 3.3(a)(3) II. U.S. COURT OF APPEALS FOR VETERANS CLAIMS DECISIONS Chapter 18, Lesson 1, Death Benefits I. DEATH COMPENSATION AND DEPENDENCY AND INDEMNITY COMPENSATION A. Introduction Death Indemnity and Death Indemnity Compensation B. Dependency and Indemnity Compensation (DIC). 38 C.F.R. § 3.5 C. DIC Benefits for Survivors of Certain Veterans Rated Totally Disabled at Time of Death. 38 C.F.R. § 3.22 D. Surviving Spouses Rate of DIC. 38 C.F.R. § 3.10 E. Cause of Death. 38 C.F.R. § 3.312 F. Special monthly dependency and indemnity compensation, death compensation, pension and spouse's compensation ratings. 38 C. F. R. § 3.351 G. Major Points of Lesson Death Indemnity and Death Indemnity Compensation II. IMPROVED DEATH PENSION A. Introduction Improved Death Pension B. Pension. Improved Death Pension, Public Law 95-588. 38 C.F.R. § 3.3(b)(4) C. Improved pension rates – Veterans and surviving spouses. 38 C.F.R. § 3.23 D. Improved pension rates – Surviving Children. 38 C.F.R. § 3.24 E. Marriage dates. 38 C.F.R. § 3.54 F. Major Points of Lesson Improved Death Pension III. BURIAL BENEFITS A. B. C. D. Introduction Burial Benefits Payment of Burial Expenses of deceased veterans. 38 C. F. R. § 3.1600 Claims and Evidence. 38 C. F. R. § 3.1601 Major Points of Lesson Burial Benefits IV. U. S. COURT OF APPEALS FOR VETERANS CLAIMS DECISIONS WWP_0000376 SJC 141 Training Manual I, Adjudication of VA Benefits and Other Programs __________________________________________________________________ Chapter 19, Lesson 1, Medical Benefits I. ENROLLMENT – PROVISION OF HOSPITAL AND OUTPATIENT CARE TO VETERANS A. B. C. D. E, F. Introduction Enrollment Enrollment requirements for veterans. 38 C.F.R. § 17.36(a) Categories of veterans eligible to be enrolled. 38 C.F.R. § 17.36(b) Federal Register Notification of eligible enrollees. 38 C.F.R. § 17.36(c) Enrollment and disenrollment proves. 38 C.F.R. § 17.36(d) Catastrophically disabled. 38 C.F.R. § 17.36(d) II. MEDICAL BENEFITS PACKAGE A. Introduction Medical Benefits Package B. Basic Care. 38 C.F.R. § 17.38(a)(1) C. Preventive care. 38 C.F.R. § 17.38(a)(2) III. EXAMINATIONS A. Introduction Examinations B. Persons eligible for hospital observation and physical examinations. 38 C.F.R. § 17.41 C. Examinations on an outpatient basis. 38 C.F.R. § 17.42 IV. HOSPITAL, DOMICILIARY, NURSING HOME, AND PRIVATE HOSPITAL CARE A. Persons entitled to hospital and domiciliary care. 38 C.F.R. § 17.42 B. Eligibility for hospital, domiciliary or nursing home care of persons discharged or released from active military or air service. 38 C.F.R. § 17.46 C. Hospital care and medical services in non-VA facilities. 38 C.F.R. § 17.52 WWP_0000377 SJC 142 Training Manual I, Adjudication of VA Benefits and Other Programs __________________________________________________________________ Chapter 20, Lesson 1, Educational Benefits I. G.I. BILL A. Introduction GI Bill B. Post 9/11 GI Bill, Chapter 33, US Code C. Montgomery GI Bill Active Duty (MGIB), Chapter 30, US Code D. Montgomery GI Bill Reserves, Chapter 1606, US Code E. Reserve Educational Assistance Program (REAP), Chapter 1607 US Code II. VOCATIONAL REHABILITATION, CHAPTER 31 A. B. C. D. E. F. G. H. I. J. K. L. Introduction Vocational Rehabilitation Vocational Rehabilitation – Basic Requirements Definitions. 38 C.F.R. § 21.35 Basic entitlement to vocational rehabilitation benefits and services. 38 C.F.R. § 21.40 Deferral or extension of the basic period of eligibility. 38 C.F.R. § 21.42 Extensions of Basis Period Of Eligibility Initial evaluation. 38 C.F.R. § 21.50 Determining employment handicap. 38 C.F.R. § 21.51 Determining serious employment handicap. 38 C.F.R. § 21.52 Reasonable feasibility of achieving a vocational goal. 38 C.F.R. § 21.53. Other Considerations Major Points of Lesson Vocational Rehabilitation III. U.S. COURT OF APPEALS FOR VETERANS CLAIMS DECISIONS Chapter 21, Lesson 1, Insurance Benefits I. SERVICEMEMBERS’ GROUP LIFE INSURANCE AND VETERANS’ GROUP LIFE INSURANCE. 38 C.F.R. §§ 9.1-9.15 A. B C. D. E. F. G. H. I. J. Introduction. 38 C.F.R. §§ 9.1-9.15 Definitions, 38 C.F.R. § 9.1 Effective Date, Applications, 38 C.F.R. § 9.2 Waiver or reduction of coverage, 38 C.F.R. § 9.3 Beneficiaries and options, 38 C.F.R. § 9.4 Payment of proceeds, 38 C.F.R. § 9.5 Assignments, 38 C.F.R. § 9.6 Administrative decisions, 38 C.F.R. § 9.7 Termination of coverage, 38 C.F.R. § 9.8 Conversion privilege, 38 C.F.R. § 9.9 WWP_0000378 SJC 143 Training Manual I, Adjudication of VA Benefits and Other Programs __________________________________________________________________ K. L. M. N. O. P. Q. Health standards, 38 C.F.R. § 9.10 Criteria for resinsurers and converters, 38 C.F.R. § 9.11 Reinsurance formula, 38 C.F.R. § 9.12 Actions for policy, 38 C.F.R. § 9.13 Accelerated Benefits, 38 C.F.R. § 9.14 Traumatic injury protection, 38 C.F.R. § 9.15 Major Points of Lesson Insurance Benefits. 38 C.F.R. §§ 9.1-9.15 Chapter 22, Lesson 1, Home Loan Guarantee I. VA HOME LOAN GURANTEE A. Introduction B. Military Eligibility Requirements C. Benefits of a VA Loan WWP_0000379 SJC 144 Training Manual II - Index 1945 Rating Schedule and Special Monthly Compensation TRAINING MANUAL II 1945 VA SCHEDULE FOR RATING DISABILITIES Chapter 1 - General Rating Policy Chapter 1, Lesson 1, General Rating Policy 1 I. GENERAL RATING POLICY. 38 C.F.R. §§ 4.1–4.14 A. B. C. D. E. F. G. H. I. J. K. Introduction. 38 C.F.R. §§ 4.1 – 4.14 Essentials in evaluative rating. 38 C.F.R. § 4.1 Interpretation of examination reports. 38 C.F.R. § 4.2 Resolution of reasonable doubt. 38 C.F.R. § 4.3 Evaluation of evidence. 38 C.F.R. § 4.6 Higher of two evaluations. 38 C.F.R. § 4.7 Congenital or developmental defects. 38 C.F.R. § 4.9 Functional impairment. 38 C.F.R. § 4.10 Effect of change of diagnosis. 38 C.F.R. § 4.13 Avoidance of pyramiding. 38 C.F.R. § 4.14 Major Points of Lesson. 38 C.F.R. §§ 4.1 – 4.14 II. TOTAL DISABILITY RATINGS (TDIU). 38 C.F.R. §§ 4.15-4.19 A. Introduction. 38 C.F.R. §§ 4.15 - 4.19 B. Total disability ratings. 38 C.F.R. § 4.15 C. Total disability ratings for compensation based on unemployability of the individual. 38 C.F.R. § 4.16 D. Total disability ratings for pension based on unemployability and age of the individual. 38 C.F.R. § 4.17 E. Misconduct etiology. 38 C.F.R. § 4.17a F. Unemployability. 38 C.F.R. § 4.18 G. Age in service-connected claims. 38 C.F.R. § 4.19 H. Major Points of Lesson. 38 C.F.R. §§ 4.15 - 4.19 III. VA OFFICE OF GENERAL COUNSEL PRECEDENT OPINIONS IV. U. S. COURT OF APPEALS FOR VETERANS CLAIMS DECISIONS WWP_0000380 SJC 145 Training Manual II - Index 1945 Rating Schedule and Special Monthly Compensation Chapter 1, Lesson 2, General Rating Policy 2 I. GENERAL RATING POLICY. 38 C.F.R. §§ 4.20–4.27 A. B. C. D. E. F. G. H. I. Introduction. 38 C.F.R. §§ 4.20 – 4.27 Analogous ratings. 38 C.F.R. § 4.20 Application of rating schedule. 38 C.F.R. § 4.21 Rating of disabilities aggravated by service. 38 C.F.R. § 4.22 Attitude of rating officers. 38 C.F.R. § 4.23 Combined ratings tables. 38 C.F.R. § 4.25 Bilateral factor. 38 C.F.R. § 4.26 Use of diagnostic code numbers. 38 C.F.R. § 4.27 Major Points of Lesson. 38 C.F.R. §§ 4.20 – 4.27 II. SPECIAL RATINGS. 38 C.F.R. §§ 4.28-4.31. A. Introduction. 38 C.F.R. §§ 4.28 - 4.31 B. Prestabilization rating from date of discharge from service. 38 C.F.R. § 4.28 C. Ratings for service-connected disabilities requiring hospital treatment or observation. 38 C.F.R. § 4.29 D. Convalescent ratings. 38 C.F.R. § 4.30 E. Zero percent evaluations. 38 C.F.R. § 4.31 F. Major Points of Lesson. 38 C.F.R. §§ 4.28 - 4.31 III. VA OFFICE OF GENERAL COUNSEL PRECEDENT OPINIONS V. U. S. COURT OF APPEALS FOR VETERANS CLAIMS DECISIONS WWP_0000381 SJC 146 Training Manual II - Index 1945 Rating Schedule and Special Monthly Compensation Chapter 2 - General Rating Policy – The Musculoskeletal System Chapter 2, Lesson 1, The Musculoskeletal System I. GENERAL RATING POLICY – THE MUSCULOSKELETAL SYSTEM. 38 C.F.R. §§ 4.41 – 4.46. A. B. C. D. Introduction. 38 C.F.R. §§ 4.41–4.46 Functional loss. 38 C.F.R. § 4.40 History of Injury. 38 C.F.R. § 4.41 Complete Medical Examinations of injury cases. 38 C.F.R. § 4.42 E. The bones. 38 C.F.R. § 4.44 F. Accurate measurement. 38 C. F. R. § 4.46 G. Major Points of Lesson. 38 C.F.R. §§ 4.41-4.46 II. GENERAL RATING POLICY – THE MUSCULOSKELETAL SYSTEM. 38 C.F.R. §§ 4.57 – 4.71. A. B. C. D. E. F. G. H. I. J. K. L. M. N. O. III. Introduction. 38 C.F.R. §§ 4.57 – 4.71 Static foot deformities. 38 C. F. R. § 4.57 Arthritis due to strain. 38 C. F. R. § 4.58 Painful motion. 38 C. F. R. § 4.59 Examination. 38 C. F. R. § 4.61 Circulatory disturbances. 38 C. F. R. § 4.62 Loss of use of hand or foot. 38 C. F. R. § 4.63 Loss of use of buttocks. 38 C. F. R. § 4.64 Sacroiliac joint. 38 C. F. R. § 4.66 Pelvic bones. 38 C. F. R. § 4.67 Amputation rule. 38 C. F. R. § 4.68 Dominant hand. 38 C. F. R. § 4.69 Inadequate examinations. 38 C. F. R. § 4.69 Measurement of ankylosis and joint motion. 38 C. F. R. § 4.71 Major Points of Lesson. 38 C.F.R. §§ 4.57 – 4.71 U. S. COURT OF APPEALS FOR VETERANS CLAIMS DECISIONS WWP_0000382 SJC 147 Training Manual II - Index 1945 Rating Schedule and Special Monthly Compensation Chapter 3- Rating Muscle Injuries Chapter 3, Lesson 1, Rating Muscle Injuries I. RATING INJURIES TO THE MUSCULOSKELETAL SYSTEM. 38 C.F.R. § 4.56 A. Introduction. 38 C.F.R. § 4.56 B. Gunshot or Shell Fragment Injury Examination ProtocolC. Individual Muscle Identification, 38 C.F.R. § 4.73 D. Basis Rules for Determining Degree of severity of the muscle injury 38 C.F.R. § 4.56 – Evaluation of Muscle Disabilities by Muscle Group E. Slight Disability of Muscles. 38 C.F.R. § 4.56(d)(1) F. Moderate Disability of Muscles. 38 C.F.R. § 4.56(d)(2) and 38 C.F.R. § 4.56(b) G. Moderately Severe Disability of Muscles. 38 C.F.R. § 4.56(d)(3) H. Severe Muscle Disabilities. 38 C.F.R. § 4.56(d)(4) and 38 C.F.R. § 4.56(a) I. Major Points of Lesson. 38 C.F.R. § 4.56 II. U. S. COURT OF APPEALS FOR VETERANS CLAIMS Chapter 3, Lesson 2, Principles of Combined Ratings I. PRINCIPLES OF COMBINED MUSCLE INJURY RATINGS. 38 C. F. R. § 4.55 A. Introduction. 38 C.F.R. § 4.55 B. Rating Muscle Damage and Peripheral Nerve Damage, 38 C.F.R. § 4.55(a) C. Skeletal Muscles of the Body, 38 C.F.R. § 4.55(b) D. Muscle Groups Acting on an Ankylosed Joint. 38 C.F.R. § 4.55(c) E. Muscle Groups Acting on a Single Unankylosed Joint, 38 C.F.R. § 4.55(d) F. Compensable Muscle Group Injuries in the Same Anatomical Region, 38 C.F.R. § 4.55(e) G. Muscle Group Injuries in Different Anatomical Regions, 38 C.F.R. § 4.55(f) H. Major Points of Lesson. 38 C.F.R. § 4.55 III. U. S. COURT OF APPEALS FOR VETERANS CLAIMS WWP_0000383 SJC 148 Training Manual II - Index 1945 Rating Schedule and Special Monthly Compensation Chapter 3, Lesson 3, Evaluation of Muscle injuries by Disgnostic Code I. SCHEDULE OF RATINGS – MUSCLE INJURIES. 38 C.F.R. §§ 4.73, DC 5301-5329 A. B. C. D. E. F. G. H. Introduction. 38 C.F.R. §§ 4.73, DC 5301-5329 DC 5301, Muscle group I, Extrinsic muscles of the shoulder girdle DC 5302, Muscle group II, Extrinsic muscles of the shoulder girdle DC 5303, Muscle group III, Intrinsic muscles of shoulder girdle DC 5304, Muscle group IV, Intrinsic muscles of shoulder girdle DC 5305, Muscle group V, Flexor muscles of elbow DC 5306, Muscle group VI, Extensor muscles of elbow DC 5307, Muscle group VII, Muscles arising from the internal condyle of humerus I. DC 5308, Muscle group VIII, Muscles arising mainly form the external condyle of humerus J. DC 5309, Muscle group IX, Intrinsic muscles of hand K. DC 5310, Muscle group X, Intrinsic muscles of foot L. DC 5311, Muscle group XI, Posterior and lateral crural muscles of the calf M. DC 5312, Muscle group XII, Anterior muscles of leg N. DC 5313, Muscle group XIII, Posterior thigh group O. DC 5314, Muscle group XIV, Anterior thigh group P. DC 5315, Muscle group XV, Mesial thigh group Q. DC 5316, Muscle group XVI, Pelvic girdle group 1 R. DC 5317, Muscle group XVII, Pelvic girdle group 2 S. DC 5318, Muscle group XVIII, Pelvic girdle group 3 T. DC 5319, Muscle group XIX, Muscles of the abdominal wall U. DC 5320, Muscle group XX, Spinal muscles V. DC 5321, Muscle group XXI, Muscles of respiration W. DC 5322, Muscle group XXII, Muscles of front of the neck X. DC 5323, Muscle group XXIII, Muscles of the side and back of neck Y. DC 5324, Diaphragm, rupture of, with herniation Z. DC 5325, Muscle injury, facial muscles AA. DC 5326, Muscle hernia, extensive BB. DC 5327, Muscle neoplasm of, malignant (excluding soft tissue sarcoma) CC. DC 5328, Muscle neoplasm, benign, postoperative DD. DC 5329, Sarcoma, soft tissue, (of muscle fat, or fibrous connective tissue) II. U. S. COURT OF APPEALS FOR VETERANS CLAIMS DECISIONS WWP_0000384 SJC 149 Training Manual II - Index 1945 Rating Schedule and Special Monthly Compensation Chapter 4 – Acute, Subacute, and Chronic Diseases of the Musculoskeletal System Chapter 4, Lesson 1, Acute, Subacute, and Chronic Diseases of the Musculoskeletal System I. ACUTE, SUBACUTE OR CHRONIC DISEASES OF THE MUSCULOSKELETAL SYSTEM, 38 C.F.R. § 4.71A, DC 5000-5025 Introduction. 38 C.F.R. §§ 4.71A, DC 5000-5025 DC 5000, Osteomyelitis, acute, subacute or chronic DC 5002, Rheumatoid Arthritis, (atrophic) as an active process DC 5003, Degenerative Arthritis, degenerative (hypertrophic or osteoarthritis) E. DC 5004, Arthritis, gonorrheal F. DC 5005, Arthritis, pneumococcic G. DC 5006, Arthritis, typhoid H. DC 5007, Arthritis syphilitic I. DC 5008, Arthritis, streptococcic J. DC 5009, Arthritis, other types (specify) K. DC 5010, Arthritis due to trauma, substantiated by X-ray findings L. DC 5011, Bones, caisson disease of M. DC 5012, Bones, new growths of, malignant N. DC 5013, Osteoporosis, with joint manifestations O. DC 5014, Osteomalacia P. DC 5015, Bones, new growths of, benign Q. DC 5016, Osteitis deformans R. DC 5017, Gout S. DC 5018, Hydrathrosis, intermittent T. DC 5019, Bursitis U. DC 5020, Synovitis V. DC 5021, Myositis W. DC 5022, Periostitis X. DC 5023, Myositis ossificans Y. DC 5024, Tenosynovitis Z. DC 5025, Fibromyalgia (fibrositis, primary fibromyalgia syndrome) AA. Major Points of Lesson. 38 C.F.R. §§ 4.71a, DC 5000-5025 A. B. C. D. II. VA OFFICE OF GENERAL COUNSEL PRECEDENT DECISIONS III. U. S. COURT OF APPEALS FOR VETERANS CLAIMS DECISIONS WWP_0000385 SJC 150 Training Manual II - Index 1945 Rating Schedule and Special Monthly Compensation Chapter 5 – Evaluation of Ankylosis and Limitation of Motion of the Musculoskeletal system. 38 C.F.R. § 4.71a, DC 5200-5297 and Prosthetic Implants38 C.F.R. § 4.71a, DC 5051-5056 Chapter 5, Lesson 1, Evaluation of Ankylosis and Limitation of Motion of the Musculoskeletal system, Upper Extremities I. EVALUATION OF ANKYLOSIS AND LIMITATION OF MOTION OF THEMUSCULOSKELETAL SYSTEM, UPPER EXTREMITIES. 38 C.F.R. § 4.71a, DC 5200-5215 A. B. C. D. E. F. G. H. I. J. K. L. M. N. O. P. Q. R. S. T. U. V. W. X. Y. Introduction. 38 C.F.R. § 4.71a, DC 5200-5215 Examinations for the Evaluation of Ankylosis and Limitation of Motion Definitions Useful for the Evaluation of Limitation of Motion Ankylosis Limitation of Motion Due to Painful Motion and Arthritis, 38 C.F.R. § 4.59 Limitation of Motion Due to Organic Effects, 38 C.F.R. § 4.40 Limitation of Motion Due Pain on Motion, 38 C.F.R. § 4.40 Limitation of motion Due to Weakened Movement, Excess Fatigability, and Incoordination, 38 C.F.R. § 4.45 Evaluation of Ankylosis and Limitation of Motion for Disabilities of the Upper Extremities 38 C.F.R. § 4.71a, DC 5200 – 5215 DC 5200, Scapulohumeral articulation, ankylosis of DC 5201, Arm, limitation of motion of DC 5202, Humerus, other impairment of DC 5203, Clavicle and scapula, impairment of DC 5205, Elbow, ankylosis of DC 5206, Forearm, limitation of flexion of DC 5207, Forearm, limitation of extension of DC 5208, Forearm, flexion limited to 100 degrees and extension limited to 45 degrees DC 5209, Elbow, other impairment of DC 5210, Radius and ulna, nonunion of with flail joint DC 5211, Ulna, impairment of DC 5212, Radius, impairment of DC 5213, Supination and pronation, impairment of DC 5214, Wrist, ankylosis of DC 5215, Wrist, limitation of motion of Major Points of Lesson. 38 C.F.R. § 4.71a, DC5200-5215 II. VA OFFICE OF GENERAL COUNSEL PRECEDENT DECISIONS III. U.S. COURT OF APPEALS FOR VETERANS CLAIMS DECISIONS WWP_0000386 SJC 151 Training Manual II - Index 1945 Rating Schedule and Special Monthly Compensation Chapter 5, Lesson 2, Evaluation of Ankylosis and Limitation of Motion of the Musculoskeletal system, Lower Extremities I. EVALUATION OF ANKYLOSIS AND LIMITATION OF MOTION OF THE MUSCULOSKELETAL SYSTEM, LOWER EXTREMITIES 38 C.F.R. § 4.71a, DC5250-5284 A. B. C. D. E. F. G. H. I. J. Introduction. 38 C.F.R. § 4.71a, DC5250-5284 DC 5250, Hip, ankylosis of DC 5251, Thigh, limitation of extension of DC 5252, Thigh, limitation of extension of DC 5253, Thigh, impairment of DC 5254, Hip, flail joint DC 5255, Femur, impairment of DC 5256, Knee, ankylosis of DC 5257, Knee, other impairment of DC 5258, Cartilage, semilunar, dislocated with frequent episodes of “locking,” pain, and effusion into the joint K. DC 5259, Cartilage, semilunar, removal of, symptomatic L. DC 5260, Leg, limitation of flexion of M. DC 5261, Leg, limitation of extension of N. DC 5262, Tibia and fibula, impairment of O. DC 5263, Genu recurvatum P. DC 5270, Ankle, ankylosis of Q. DC 5271, Ankle, limited motion of R. DC 5272, Subastragalar or tarsal, ankylosis of S. DC 5273, Os calcis or astragalus, malunion of T. DC 5274, Astralgectomy U. DC 7274, Bones, of the lower extremity, shortening of V. DC 5276, Flatfoot, acquired W. DC 5277, Weakfoot, bilateral X. DC 5278, Claw foot (pes cavus), acquired Y. DC 5279, Metatarsalgia, anterior (Morton’s disease), unilateral, or bilateral Z. DC 5280, Hallux valgus, unilateral AA. DC 5281, Hallux rigidus, unilateral, severe BB. DC 5282, Hammer toe CC. DC 5283, Tarsal, or metatarsal bones, malunion of, or nonunion of DD. DC 5284, Foot, injuries, other EE. Major Points of Section. 38 C.F.R. § 4.71a, DC 5250-5284 IV. VA OFFICE OF GENERAL COUNSEL PRECEDENT DECISIONS V. U.S. COURT OF APPEALS FOR VETERANS CLAIMS DECISIONS WWP_0000387 SJC 152 Training Manual II - Index 1945 Rating Schedule and Special Monthly Compensation Chapter 5, Lesson 3, Evaluation of Limitation of Motion of the Back and Prosthetic Implants, Skull, Ribs and Coccyx I. EVALUATION OF ANKYLOSIS AND LIMITATION OF MOTION OF THE MUSCULOSKELETAL SYSTEM. THE BACK. 38 C.F.R. § 4.71a, DC52355243 A. Introduction. 38 C.F.R. § 4.71a, DC5235-5243 B. Evaluation of Ankylosis and Limitation of Motion and Intervertebral Disc Syndrome of the Spine. 38 C.F.R. § 4.71a, DC 5235 – 5242 C. DC 5235, Vertebral fracture of dislocation D. DC 5236, Sacroiliac injury and weakness E. DC 5237, Lumbosacral or cervical strain F. DC 5238. Spinal stenosis G. DC 5239, Spondylothesis or segmental instability H. DC 5240, Ankylosing spondylolitis I. DC 5241, Spinal fusion J. DC 5242, Degenerative arthritis of the spine (see also diagnostic code 5003) K. DC 5243, Intervertebral disc syndrome II. EVALUATION OF PROSTHETIC IMPLANTS. 38 C.F.R. § 4.71a, DC50515056 A. B. C. D. E. F. G. Introduction. 38 C.F.R. § 4.71a, DC 5051-5056 DC 5051, Shoulder replacement (prosthesis) DC 5052, Elbow replacement (prosthesis) DC 5053, Wrist replacement (prosthesis) DC 5054, Hip replacement (prothesis) DC 5055, Knee replacement (prosthesis) DC 5056, Ankle replacement (prosthesis) III. EVALUATION OF THE SKULL, THE RIBS, AND THE COCCYX. 38 C.F.R. § 4.71a, DC5296-5298 A. J. K. L. Introduction. 38 C.F.R. § 4.71a, DC5296-5298 DC 5296, The Skull DC 5297, The Ribs DC 5298, The Coccyx IV. VA Office of General Counsel Precedent Decisions V. U.S. COURT OF APPEALS FOR VETERANS CLAIMS DECISIONS WWP_0000388 SJC 153 Training Manual II - Index 1945 Rating Schedule and Special Monthly Compensation Chapter 6 – Rating Codes for Amputations Chapter 6, Lesson 1, Rating Codes for Amputations I. RATING CODES FOR AMPUTATIONS. 38 C.F.R. §§ 4.71a, DC 5104-5173 AND ANKYLOSIS AND LIMITATION OF MOTION OF THE FINGERS. 38 C.F.R. §§ 4.71a, 5216-5230 A. B. C. D. E. F. G. H. I. Introduction. 38 C.F.R. §§ 4.71a, DC 5104-5173 AND 5216-5230 Combinations of Disabilities. DC 5104 - 5111 Amputations: Upper Extremities. DC 5120 - 5125 Multiple Finger Amputations. DC 5126 - 5151 Single Finger Amputations. DC 5152 - 5156 Ankylosis and Limitation of Motion of Fingers. DC 5216-5230 Limitation of Motion of Fingers. DC 5228 - 5230 Amputations: Lower Extremities. DC 5160 - 5173 Major Points of Chapter. 38 C.F.R. §§ 4.71a, DC 5104-5173 AND 52165230 II. U. S. COURT OF APPEALS FOR VETERANS CLAIMS DECISIONS Chapter 7 – Organs of Special Sense Chapter 7, Lesson 1, Evaluation of Visual Acuity I. EVALUATION OF VISUAL ACUITY. 38 C.F.R. §§ 4.75–4.79, DC 6000-6091 A. Introduction. 38 C.F.R. §§ 4.75–4.79, DC 6000-6091 B. General Considerations for Evaluating Visual Impairment. 38 C.F.R. § 4.75 C. Visual Acuity. 38 C.F.R. § 4.76 D. Computation of Average Concentric Contraction of Visual Fields. 38 C.F.R. § 4.76a E. Visual Fields. 38 C.F.R. § 4.77 F. Muscle Function. 38 C.F.R. § 4.78 G. Schedule of Ratings – The Eye. 38 C.F.R. § 4.79. Diseases of the Eye DC 6000 – 6009 H. DC 6000, Choroidopathy, including uveitis, iritis, and choroditis I. DC 6001, Keratopathy J. DC 6006, Retinopathy or maculopathy K. DC 6007, Intraocular hemorrhage L. DC 6008, Detachment of the retina M. DC 6009, Unhealed eye injury N. DC 6010, Tuberculosis of the eye O. DC 6011, Retinal scars, atrophy, or irregularities WWP_0000389 SJC 154 Training Manual II - Index 1945 Rating Schedule and Special Monthly Compensation P. DC 6012, Angle-closure glaucoma Q. DC 6013, Open-angle glaucoma R. DC 6014, Malignant neoplasms (eyeball only) S. DC 6015, Benign neoplasms (of eyeball or adnexa T. DC 6016, Nystagmus, central U. DC 6017, Trachomatous conjunctivitis V. DC 6018, Chronic conjunctivitis (nontrachomatous) W. DC 6019, Ptosis, unilateral or bilateral X. DC 6020, Ectropion Y. DC 6021, Entropion Z. DC 6022, Lagophthalmos AA. DC 6023, Loss of eyebrows, complete, unilateral or bilateral BB. DC 6024, Loss of eyelashes, complete, unilateral or bilateral CC. DC 6025, Definition of Disorders of the lacrimal apparatus (epiphora, dacryocystitis, etc.) DD. DC 6026, Optic neuropathy EE. DC 6027, Cataract of any type FF. DC 6029, Aphakia or dislocation of the crystalline lens GG. DC 6030, Paralysis of accommodation (due to neuropathy of the Oculomotor Nerve (cranial nerve III) HH, DC 6032, Loss of eyelids, partial or complete II. DC 6034, Ptergium JJ. DC 6035, Keratoconus KK. DC 6036, Status post corneal transplant LL. DC 6037, Pinguecula MM. Ratings for Impairment of Central Visual Acuity NN. Ratings for Impairment fo Visual Fields OO. DC 6081, Scotoma, unilateral PP. Ratings for Impairment of Muscle Function QQ. DC 6091, Symblepharon RR. Major Points of Lesson. 38 C.F.R. §§ 4.75–4.79, DC 6000-6091 Chapter 7, Lesson 2, Impairment of Auditory Acuity and Other Senses I. IMPAIRMENT OF AUDITORY ACUITY. 38 C.F.R. §§ 4.85-4.87, DC 62006260, 4.87A, DC 6275-6276 A. B. C, D, E. Introduction. §§ 4.85-4.87, DC 6200-6260, 4.87A, DC 6275-6276 Evaluation of Hearing Impairment. 38 C.F.R. § 4.85 Exceptional Patterns of Hearing Impairment. 38 C.F.R. § 4.86 Schedule of Ratings – Ear. 38 C.F.R. § 4.87 DC 6200, Chronic supporative otitis media, mastoiditis or cholesteatoma (or any combination)\ F. DC DC 6201, Chronic nonsupporative otitis media with effusion (serous otitis media) WWP_0000390 SJC 155 Training Manual II - Index 1945 Rating Schedule and Special Monthly Compensation G. DC 6202, Otosclerosis H. DC 6204, Peripheral vestibular disorders I. DC 6205, Meniere’s syndrome (endolymphatic hydrops) J. DC 6207, Loss of auricle K. DC 6208, Malignant meoplasm of the ear (other than skin only) L. DC 6209, Benign neoplasms of the ear (other than skin only) M. DC 6210, Chronic otitis externa N. DC 6211, Tympanic membrane, perforation of O. DC 6260, Tinnitus, recurrent P. . Major Points of Section. §§ 4.85-4.87, DC 6200-6260, II. SCHEDULE OF RATINGS – OTHER SENSE ORGANS. 38 C.F.R. § 4.87a A. Introduction. 38 C.F.R. § 4.87a, DC 6275-6276 B. DC 6275, Sense of smell, complete loss C. DC 7276, Sense of taste, complete loss Chapter 8 – Infectious Diseases, Immune Disorders and Nutritional Deficiencies Chapter 8, Lesson 1, Infectious Diseases, Immune Disorders and Nutritional Deficiencies I. SCHEDULE OF RATINGS – INFECTIOUS DISEASES, IMMUNE DISORDERS AND NUTRITIONAL DISORDERS A. B. C. D. E. F. G. H. I. J. K. L. M. N. O. P. Q. R. S. Introduction . 38 C.F.R. §§ 4.88a, DC 6300-6354 DC 6300, Cholera Asiatic DC 6301, Visceral Leishmaniasis DC 6302, Leprosy (Hansen’s Disease) DC 6304, Malaria DC 6305, Lymphatic Filariasis DC 6306, Bartonellosis DC 6307, Plague DC 6308, Relapsing Fever DC 6309, Rheumatic fever DC 6310, Syphilis, and other treponemal infections DC 6311, Tuberculosis, military DC 6313, Avitaminosis DC 6314, Beriberi DC 6315, Pellagra DC 6316, Brucellosis DC 6317, Typhus, scrub DC 6318, Melioidosis DC 6319, Lyme Disease WWP_0000391 SJC 156 Training Manual II - Index 1945 Rating Schedule and Special Monthly Compensation T. U. V. W. X. DC 6320, Parasitic diseases otherwise not specified DC 6350, Lupus erythematosis, systemic (disseminated) DC 6351, HIV Related Illness DC 6354, Chronic Fatigue Syndrome (CFS) Major Points of Section. 38 C.F.R. §§ 4.88a, DC 6300-6354 II. RATINGS FOR INACTIVE NONPULMONARY TUBERCULOSIS A. Introduction. 38 C.F.R. § 4.88c-4.89 B. Ratings for Inactive Nonpulmonary Tuberculosis in Effect on August 19, 1968 C. Ratings for Inactive Nonpulmonary Tuberculosis Initially Entitled After August 19, 1968 D. Major Points of Lesson. 38 C.F.R. § 4.88c-4.89 Chapter 9 – The Respiratory System Chapter 9, Lesson 1, Diseases of the Nose and Throat I. THE RESPIRATORY SYSTEM. 38 C.F.R. §§ 4.96, 4.97, DC 6502-6524 A. Introduction. 38 C.F.R. §§ 4.96, 4.97, DC 6502-6604 II. SPECIAL PROVISIONS REGARDING EVALUATION OF RESPIRATORY CONDITIONS, 38 C.F.R. § 4.96 A. Introduction to Special Provisions Regarding Evaluation of Respiratory Conditions. 38 C.F.R. § 4.96 B. Rating coexisting disorders. 38 C.F.R. 4.96(a) C. Rating Protected Tuberculosis cases. 38 C.F.R. 4.96(b) D. Special Monthly Compensation. 38 C.F.R. 4.96(c) E. Special Provisions for Application of DCs 6600, 6304, 6825-6833 and 6840-6845. 38 C.F.R. 4.96(d) III. DISEASES OF THE NOSE AND THROAT. 38 C.F.R. § 4.97, DC 6502-6524 A. B. C. D. E. F. G. H. I. J. Introduction. 38 C.F.R. § 4.97, DC 6502-6524 DC 6502, Septum, nasal, deviation of DC 6504, Nose, loss of part or, or scars General Rating Formula for Sinusitis (DC’s 6510 through 6514) DC 6510, Sinusitis, pansinusitis, chronic DC 6511, Sinusitis, ethmoid, chronic DC 6512, Sinusitis, frontal, chronic DC 6513, Sinusitis, maxillary, chronic DC 6514, Sinusitis, sphenoid, chronic DC 6615, Laryngitis, tuberculous, active or inactive WWP_0000392 SJC 157 Training Manual II - Index 1945 Rating Schedule and Special Monthly Compensation K. L. M. N. O. P. Q. R. DC 6516, Laryngitis, chronic DC 6518, Laryngectomy DC 6519, Aphonia, complete organic DC 6520, Larynx, stenosis of, including residuals of laryngeal trauma, (unilateral or bilateral) DC 6521, Pharynx, injuries to DC 6522 Alergic or vasomotor rhinitis DC 6523, Bacterial rhinitis DC 6524, Granulomatosis rhinitis IV. DISEASES OF THE TRACHEA AND BRONCHI. 38 C.F.R. § 4.97, DC 66006604 A. B. C. D. E. F. G. H. V. Introduction. 38 C.F.R. § 4.97, DC 6600-6604 General Rating Formula for Diseases of the Trachea and Bronchi DC 6600, Bronchitis, chronic DC 6601, Bronchiecstasis DC 6602, Asthma, bronchial DC 6603, Emphysema DC 6604, Chronic obstructive pulmonary disease (COPD) Major Points of Section. 38 C.F.R. § 4.97 DC 6600-6604 VA OFFICE OF GENERAL COUNSEL PRECEDENT OPINIONS VI. U.S. COURT OF APPEALS FOR VETERANS CLAIMS DECISIONS Chapter 9, Lesson 2, Diseases of the Lungs and Pleura - Tuberculosis I. DISEASES OF THE LUNGS AND PLEURA – TUBERCULOSIS. 38 C.F.R. §4.97, DC 6701-6732 A. Introduction B. Ratings for Pulmonary Tuberculosis Entitled on August 19, 1968 C. Ratings for Pulmonary Tuberculosis Initially Evaluated After August 19, 1968 D. DC 6731, Tuberculosis, pulmonary, chronic, inactive II. NONTUBERCULOUS DISEASE. 38 C.F.R. § 4.97, DC 6817-6820 A. Introduction to nontuberculous disease B. DC 6817, Pulmonary Vascular disease C. DC 6819, Neoplasms, malignant, any specified part of respiratory system exclusive of skin growths D. DC 6820, Neoplasms, benign WWP_0000393 SJC 158 Training Manual II - Index 1945 Rating Schedule and Special Monthly Compensation III. BACTERIAL INFECTIONS OF THE LUNG. 38 C.F.R. § 4.97, DC 6822-6824 A. B. C. D. E. Introduction to Bacterial infections of the lung General rating formula for Bacterial Infections of the lung DC 6822, Actinomycosis DC 6823, Nocardiosis DC 6824, Chronic lung abscess IV, INTERSTITIAL LUNG DISEASES. 38 C.F.R. § 4.97, DC 6825-6833 A. Introduction to Interstitial Lung Diseases B. General Rating Formula for Interstitial Lung Disease C. DC 6825, Diffuse interstitial fibrosis (interstitial pneumonitis fibrosing alveolitis) D. DC 6826, Desquamative interstitial pneumonitis E. DC 6827, Pulmonary alveolar proteinosis F. DC 6828, Eosinophilic granuloma of lung G. DC 6829, Drug-induced pulmonary pneumonitis and fibrosis H. DC 6830, Radiation-induced pulmonary pneumonitis and fibrosis I. DC 6831, Hypersensitivity pneumonitis (extrinsic allergic alveolitis) J. DC 6832, Pneumoconiosis (silicosis, anthracosis, etc.) K. DC 6833, Asbestosis V. MYCOTIC LUNG DISEASE. 38 C.F.R. § 4.97, DC 6834-6839 A. B. C. D. E. F. G. Introduction to Mycotic Lung diseases General Rating Formula for Mycotic Lung Disease DC 6834, Histoplasmosis of the lung DC 6835, Coccidiodomycosis DC 6836, Blastyomycosis DC 6838, Aspergillosis DC 6839, Mucormycosis VI. RESTRICTIVE LUNG DISEASE. 38 C.F.R. § 4.97, DC 6840-6847 A. Introduction to Restrictive lung disease B. General rating formula for Restrictive Lung Disease C. DC 6840, Diaphragm paralysis or paresis D. DC 6841, Spinal cord injury with respiratory E. DC 6842, Kyphoscoliosis, pectus excavatum, pectus carinatum F. DC 6843, Traumatic chest wall defect, pneumothorax, hernia, etc. G. DC 6844, Post-surgical residual (lobectomy, pneumonectomy, etc. H. DC 6845, Chronic pleural effusion or fibrosis I. DC 6846, Sarcoidosis WWP_0000394 SJC 159 Training Manual II - Index 1945 Rating Schedule and Special Monthly Compensation J. DC 6847, Sleep apnea syndromes (obstructive, Central, mixed). K. Major Points of Section. 38 C.F.R. § 4.97, DC 6822-6847 Chapter 10 – The Cardiovascular System Chapter 10, Lesson 1, Diseases of the Heart I. DISEASES OF THE HEART. 38 C.F.R. §§ 4.100, 4.104, DC 7000-7020 A. Introduction. 38 C.F.R. §§ 4.100, 4.104, DC 7000-7020 B. Application of the Evaluation Criteria for Diagnostic Codes 7000-7007, 7011, and 7015-7020 C. The Cardiovascular System D. Metabolic Equivalents (METS) E. Congestive Heart Failure (CFH). F. General Rating Formula for Cardiovascular Diseases Using Metabolic Equivalents (METs) and Congestive Heart Failure (CHF). G. Cardiovascular Diseases Evaluated Using Mets as the Primary Criteria for Evaluation H. DC 7000, Valvular heart disease, I. DC 7001, Endocarditis J. DC 7002, Pericarditis K. DC 7003, Pericardial adhesions L. DC 7004, Syphilitic heart disease M. DC 7005, Arteriosclerotic heart disease (Coronary Heart Disease N. DC 7006, Myocardial infarction O. DC 7007, Hypertensive heart disease P. DC 7008, Hyperthyroid heart disease Q, DC 7010, Supraventricular arrhythmias R, DC 7011, Ventricular arrhythmias (sustained) S. DC 7015, Atrioventricular block T. DC 7016, Heart valve replacement U. DC 7017, Coronary bypass surgery V. DC 7018, Implantable cardiac pacemakers W. DC 7019, Cardiac transplantation X. DC 7020, Cardiomyopathy Y. Major Points of Lesson. 38 C.F.R. §§ 4.104, DC 7000-7020 Chapter 10, Lesson 2, Diseases of the Arteries and Veins I. DISEASES OF THE ARTERIES AND VEINS A. Introduction B. DC 7101, Hypertensive vascular disease (hypertension and isolated systolic hypertension) WWP_0000395 SJC 160 Training Manual II - Index 1945 Rating Schedule and Special Monthly Compensation C. DC 7110, Aortic aneurysm D. DC 7111, Aneurysm, any large artery E. DC 7112, Aneurysm, any small artery F. DC 7113, Arteriovenous fistula traumatic (AV Fistula) G. DC 7114, Arteriosclerosis obliterans H. DC 7115,Thrombo-angitis obliterans, Buerger’s Disease I. DC 7117, Raynaud’s syndrome J. DC 7118, Angioneurotic edema K. DC 7119, Erythromelagia L. DC 7120, Varicose veins M. DC 7121, Post-phlebitic syndrome of any etiology N. DC 7122, Cold injury residuals O. DC 7123, Soft tissue sarcoma P. Major Points of Lesson II. VA OFFICE OF GENERAL COUNSEL PRECEDENT OPINIONS III. U.S. COURT OF APPEALS FOR VETERANS CLAIMS DECISIONS Chapter 11 – The Digestive System Chapter 11, Lesson 1, The Mouth and Upper Digestive Tract I. The DIGESTIVE SYSTEM A. Introduction. 38 C.F.R. §§ 4.110-4.114, DC 7200-7310 II. SPECIAL PROVISIONS REGARDING THE DIGESTIVE SYSTEM A. B. C. D. E. Introduction to Special Provisions Regarding the Digestive System Ulcers. 38 C.F.R. 4.110 Post-gastrectomy syndromes. 38 C.F.R. 4.111 Weight Loss. 38 C.F.R. 4.112 Coexisting abdominal conditions. 38 C.F.R. 4.113 III. SCHEDULE OF RATINGS – DIGESTIVE SYSTEM. 38 C.F.R. 4.114 A. B. B. C. D. E. F. G. Introduction. 38 C.F.R. § 4.114, DC 7200-7311 DC 7200, Mouth, injuries of DC 7201, Lips, injuries of DC 7202, Tongue, loss of whole or part DC 7203 Esophagus, stricture of DC 7204, Esophagus, spasm of (cardiospasm) DC 7205, Esophagus, diverticulum of, acquired DC 7301, Peritoneum, adhesions of WWP_0000396 SJC 161 Training Manual II - Index 1945 Rating Schedule and Special Monthly Compensation H. I. J. K. L. M. N. O. P. DC 7304, Ulcer, gastric DC 7305, Ulcer, duodenal DC7306, Ulcer, marginal (gastrojejunal) DC 7307, Gastritis, hypertrophic (identified by gastroscope) DC 7308, Postgastrectomy syndromes DC 7309, Stomach, stenosis of DC 7310, Stomach, injury of, residuals DC 7311, Residuals of injury of the liver Major Points of Lesson. 38 C.F.R. §§ 4.110-4.114, DC 7200-7310 Chapter 11, Lesson 2, The Lower Digestive Tract I. SCHEDULE OF RATINGS – DIGESTIVE SYSTEM. 38 C.F.R. 4.114 A. Introduction. 38 C.F.R. §§ 4.114, DC 7312-7354 B. DC 7312, Cirrhosis of the liver, primary biliary cirrhosis, or cirrhotic phase of sclerosing cholangitis C. DC 7314, Cholecystitis, chronic D. DC 7315, Cholelithiasis, chronic E. DC 7316, Cholangitis, chronic F. DC 7317, Gall bladder, injury of G. DC 7318, Gall bladder, removal of H. DC 7319, Irritable colon syndrome (spastic colitis, mucous colitis, etc.) I. DC 7321, Amebiasis J. DC 7322, Dysentery, bacillary K. DC 7323, Colitis, ulcerative L. DC 7324, Distomiasis, intestinal or hepatic M. DC 7325, Enteritis, chronic N. DC 7326, Enterocolitis, chronic O. DC 7327, Diverticulitis P. DC 7328, Intestine, small, resection of Q. DC 7329, Intestine, large, resection of R. DC 7330, Intestine, fistula of, persistent, or after attempt at operative closure S. DC 7331, Peritonitis, tuberculous, active or inactive T. DC 7332, Rectum and anus, impairment of sphincter control U. DC 7333, Rectum and anus, stricture of V. DC 7334, Rectum, prolapse of W. DC 7335, Ano, fistula in X. DC 7336, Hemorrhoids, external or internal Y. DC 7337, Pruritus ani Z. DC 7338, Hernia, inguinal AA. DC 7339, Hernia, ventral, postoperative BB. DC 7340, Hernia, femoral CC. DC 7342, Visceroptosis, symptomatic, marked WWP_0000397 SJC 162 Training Manual II - Index 1945 Rating Schedule and Special Monthly Compensation DD. DC 7343, Malignant neoplasms of the digestive system, exclusive of skin growths EE. DC 7344, Benign neoplasms, exclusive of skin growths FF. DC 7345, Chronic liver disease without cirrhosis (including hepatitis B, chronic active hepatitis, autoimmune hepatitis, hemochromatosis, drug induced GG. DC 7346, Hernia hiatal HH. DC 7347, Pancreatitis II. DC 7348, Vagotomy with pyloroplasty or gastroenterostomy JJ. DC 7351, Liver transplant KK. DC 7354, Hepatitis C (or non-A, non-B hepatitis) Test 11, Chapter ii, Lessons 1 and 2 Chapter 12 – The Genitourinary System Chapter 12, Lesson 1, The Genitourinary System I. DISEASES OF THE GENITOURINARY SYSTEM. 38 C.F.R. §§ 4.115, 4.115a, 4.115b, DC 7500-7542 A. B. C. D. E. F. G. H. I. J. K. L. M. N. O. P. Q. R. S. T. U. V. W. X. Introduction. 38 C.F.R. §§ 4.115, 4.115A, 4.115B, DC 7500-7542 Nephritis. 38 C.F.R. § 4.115 Ratings of the Genitourinary System – Dysfunctions. 38 C.F.R. § 4.115a Renal dysfunction Voiding dysfunction Urinary frequency Obstructed voiding Urinary tract infection Evaluation of Loss or Loss Use of a Creative Organ DC 7500, Kidney, removal of one DC 7501, Kidney, abscess of DC 7502, Nephritis DC 7504, Pyelonephritis, chronic DC 7505, Kidney, tuberculosis DC 7507, Nephrosclerosis, arteriolar DC 7508, Nephrolithiasis DC 7509, Hydronephrosis DC 7510, Ureterolithiasis. DC 7511, Ureter, stricture of DC 7512, Cystitis DC 7515, Bladder, calculus in, with symptoms interfering with function DC 7516, Bladder, fistula DC 7517, Bladder, injury of DC 7518, Urethra, stricture of WWP_0000398 SJC 163 Training Manual II - Index 1945 Rating Schedule and Special Monthly Compensation Y. Z. AA. BB. CC. DD. EE. FF. DC 7519, Urethra, fistula DC 7520, Penis, removal of half or more DC 7521, Penis, removal of glans DC 7522, Penis, deformity with loss of erective power DC 7523, Testis, atrophy of complete DC 7524, Testis, removal of DC 7525, Epididymo-orchitis, chronic only DC 7527, Prostate glad injuries, infections, hypertrophy, postoperative residuals GG. DC 7528, Malignant neoplasms of the genitourinary system HH. DC 7529, Benign neoplasms of the genitourinary system II. DC 7530, Chronic renal disease requiring regular dialysis JJ. DC 7531, Kidney transplant KK. DC 7532, Renal tubular disorders LL. DC 7533, Cystic diseases of the kidney MM. DC 7534, Atherosclerotic renal disease NN. DC 7535, Toxic nephropathy OO. DC 7536, Glomerulonephritis PP. DC 7537, Interstitial nephritis QQ.. DC 7538, Papillary necrosis RR. DC 7539, Renal amyloid disease SS. DC 7540, Disseminated intravascular coagulation with renal cortical necrosis TT. DC 7541, Renal involvement in diabetes, sickle cell anemia, systemic lupus erythematosis, vasculitis, or other systemic disease processes UU. DC 7542, Neurogenic bladder VV. Major Points of Lesson. 38 C.F.R. §§ 4.115, 4.115a, 4.115b, DC 75007542 II. VA OFFICE OF GENERAL COUNSEL PRECEDENT OPINIONS III. U. S. COURT OF APPEALS FOR VETERANS CLAIMS DECISIONS Chapter 13 – The Gynecological System. 38 C.F.R. §§ 4.116, DC 7610-7629 Chapter 13, Lesson 1, The Gynecological System I. GYNECOLOGICAL CONDITIONS AND DISORDERS OF THE BREAST. 38 C.F.R. §§ 4.116, DC 7610-7629 A. Introduction. 38 C.F.R. §§ 4.116, DC 7610-7629 B. Notes on Gynecological Disorders C. General Rating Formula for Disease, Injury or Adhesions of the Female Reproductive Organs (Diagnostic Codes 7610-7615) D. DC 7610, Vulva, disease or injury WWP_0000399 SJC 164 Training Manual II - Index 1945 Rating Schedule and Special Monthly Compensation E. F. G. H. I. J. K. L. M. N. O. P. Q. R. S. T. U. V. W. DC 7611, Vagina, disease or injury DC 7612, Cervix, disease or injury DC 7613, Uterus, disease or injury DC 7614, Fallopian tube, disease or injury DC 7615, Ovary, disease or injury DC 7617, Uterus and both ovaries, removal DC 7618, Uterus, removal DC 7619, Ovary, removal DC 7620, Ovaries, atrophy of both DC 7621, Uterus, prolapse DC 7622, Uterus, displacement DC 7623, Pregnancy, surgical complications DC 7624, Fistula, rectovaginal DC 7625, Fistula, urethrovaginal DC 7626, Breast, surgery DC 7627, Malignant neoplasms DC 7628, Benign neoplasms DC 7629, Endometriosis Major Points of Lesson. 38 C.F.R. §§ 4.116, DC 7610-7629 II. VA OFFICE OF GENERAL COUNSEL PRECEDENT OPINIONS III. U. S. COURT OF APPEALS FOR VETERANS CLAIMS DECISIONS WWP_0000400 SJC 165 Training Manual II - Index 1945 Rating Schedule and Special Monthly Compensation Chapter 14 – The Hemic and Lymphatic System. Chapter 14, Lesson 1, The Hemic and Lymphatic System. I. HEMIC AND LYMPHATIC SYSTEMS. 38 C.F.R. §§ 4.117, DC 7700-7716 A. Introduction. 38 C.F.R. §§ 4.117, DC 7700-7716 B. DC 7700, Anemia, hypochromic – microcytic and megaloblastic, such as iron-deficiency and pernicious anemia C. DC 7702, Agranulocytosis, acute D. DC 7703, Leukemia E. DC 7704, Polycythemia vera F. DC 7705, Thrombocytopenia, primary, idiopathic or immune G. DC 7706, Splenectomy H. DC 7707, Spleen, injury of, healed I. DC 7709, Hodgkins disease J. DC 7710, Adenitis, tuberculous, active or inactive K. DC 7714, Sickle cell anemia L. DC 7715, Non-Hodgkins lymphoma M. DC 7716, Aplastic anemia N. Major Points of Lesson. 38 C.F.R. §§ 4.117, DC 7700-7716 Chapter 15 – The Skin – Scars. 38 C.F.R. §§ 4.118, DC 7800-7833 Chapter 15, Lesson 1, The Skin,- Scars I. THE SKIN – SCARS. 38 C.F.R. § 4.118, DC 7800-7805 A. B. C. D. E. F. G. Introduction. 38 C.F.R. § 4.118, DC 7800-7805 Anatomy of the Skin Types of Burns 38 C.F.R. § 4.118. Schedule of ratings—Skin DC 7800, Disfiguring Scars, Head Face and Neck. DC 7801, Burn Scars, Not Head Face or Neck. DC 7802, Burn scars, due to other causes, not head face or neck, superficial and non-linear H. DC 7804, Scars, Unstable or Painful I. DC 7805, Scars, others (including linear scars) and other effects of scars evaluated under diagnostic codes 7801, 7802, 7803, and 7804 J. Major Points of Lesson. 38 C.F.R. § 4.118, DC 7800-7805 WWP_0000401 SJC 166 Training Manual II - Index 1945 Rating Schedule and Special Monthly Compensation Chapter 15, Lesson 2, Diseases of the Skin II. THE SKIN - DISEASES OF THE SKIN, 38 C.F.R. § 4.118, DC 7806-7833 A. Introduction. 38 C.F.R. § 4.118, DC 7806-7833 B. DC 7806, Dermatitis or eczema C. DC 7807, American (New World) leischmaniasis (mucocutaneous, espundia) D. DC 7808, Old World leischmaniasis (cutaneous, Oriental sore) E. DC 7809, Discoid lupus erythematosis or subacute cutaneous lupus erythematosis F. DC 7811, Tuberculosis, luposa (lupus vulgaris), active or inactive G. DC 7813, Dermatophytosis (ringworm: of body, tinea corporis; of head, tinea capitis; of feet, tinea pedis; of beard area, tinea barbae; of nails tinea unguium; or inguinal area (jock itch), tinea cruris H. DC 7815, Bullous disorders (including pemphigus vulgaris, pemphigus foliaceous, bullous pemphigoid, dermatitis herpetiformis, epidermolysis bullosa acquisita, benign chronic familial pemphigus (HaileyHailey), and porphyri cutanea tarda): I. DC 7816, Psoriasis J. DC 7817, Exfoliative dermatitis (erythroderma) K. DC 7818, Malignant neoplasms (other than malignant melanoma) L. DC 7819, Benign skin neoplasms M. DC 7820, Infections of the skin not listed elsewhere (including bacterial, fungal, viral, treponemal, and parasitic diseases) N. DC 7821, Cutaneous manifestations of collagen-vascular diseases not listed elsewhere (including scleroderma, calcinosis cutis, and dermatomyositis): O. DC 7822, Papulosquamous disorders not listed elsewhere (including lichen planus, large or small plaque parapsoriasis, pityriasis lichenoides et varioliformis acuta (PLEVA), lymphomatoid papulosus, and pityriasis rubra pilaris (PRP)) P. DC 7823, Vertiligo Q. DC 7824, Diseases of keratinization (including icthyoses, Darier’s disease, and palmoplantar keratoderma) R. DC 7825, Urticaria S. DC 7826, Vasculitis, primary cutaneous T. DC 7827, Erythema multiform; Toxic epidermal necrolysis U. DC 7828, Acne V. DC 7829, Chloracne W. DC 7830, Scarring alopecia X. DC 7831, Alopecia areata Y. DC 7832, Hyperhidrosis Z. DC 7833, Malignant melanoma WWP_0000402 SJC 167 Training Manual II - Index 1945 Rating Schedule and Special Monthly Compensation Chapter 16 – The Endocrine System Chapter 16, Lesson 1, The Endocrine System I. THE ENDOCRINE SYSTEM. 38 C.F.R. §§ 4.119, DC 7900-7919 A. B. C. D. E. F. G. H. I. J. K. L. M. N. O. P. Q. R. S. T. Introduction. 38 C.F.R. §§ 4.119, DC 7900-7919 DC 7900, Hyperthyroidism DC 7801, Thyroid gland, toxic adenoma of DC 7902, Thyroid gland, non-toxic adenoma of DC 7903, Hypothyroidism DC 7904, Hyperparathyroidism DC 7905, Hypoparathyroidism DC 7907, Cushing’s Syndrome DC 7908, Acromegaly DC 7909, Diabetes insipidus DC 7911, Addison’s disease (Adrenal Cortical Hypofunction) DC 7912, Pluriglandular syndrome DC 7913, Diabetes mellitus DC 7914, Neoplasm, malignant, any specified part of the endocrine system DC 7915, Neoplasm, benign, any specified part of the endocrine system DC 7916, Hyperpituitarism (prolactin secreting pituitary dysfunction) DC 7917, Hyperaldosteronism (benign or malignant) DC 7918, Pheochromocytoma (benign or malignant) DC 7913, C-cell hyperplasia of the thyroid Major Points of Lesson. 38 C.F.R. §§ 4.119, DC 7900-7919 Chapter 17 – Neurological and Convulsive Disorders Chapter 17, Lesson 1, Organic Diseases of the Central Nervous System. 38 C.F.R. §§ 4.120, 4.124a, DC 8000-8075, 8025 I. ORGANIC DISEASES OF THE CENTRAL NERVOUS SYSTEM. 38 C.F.R. § 4.120, 4.124a, DC 8000 – 8025 and 8046 A. B. C. D. E. F. G. H. I. J. Introduction. 38 C.F.R. § 4.120, DC 8000-8025 and 8046 Evaluations by comparison. 38 C.F.R. § 4.120 DC 8000, Encephalitis, epidemic, chronic DC 8002, Brain, new growth of, malignant DC 8003, Brain, new growth of, benign DC 8004, Paralysis, agitans DC 8005, Bulbar palsy DC 8007, Brain, vessels, embolism of DC 8008, Brain, vessels, thrombosis of DC 8009, Brain, vessels, hemorrhage from WWP_0000403 SJC 168 Training Manual II - Index 1945 Rating Schedule and Special Monthly Compensation K. L. M. N. O. P. Q. R. S. T. U. V. W. X. Y. Z. DC 8010, Myelitis DC 8011, Poliomyelitis, anterior DC 8012, Hematomyelia DC 8013, Syphilis, cerebrospinal DC 8014, Syphilis, meningovascular DC 8015, Tabes dorsalis DC 8017, Amyotrophic lateral sclerosis DC 8018, Multiple sclerosis DC 8019, Meningitis, cerebrospinal, epidemic DC 8020, Brain, abscess of DC 8021, Spinal cord, new growths of, malignant DC 8022, Spinal cord, new growths of, benign DC 8023, Progressive muscular atrophy DC 8024, Syringomyelia DC 8025, Myasthenia gravis DC 8046, Cerebral arteriosclerosis II. TRAUMATIC BRAIN INJURY (TBI). 38 C.F.R. § 4.124a, DC 8045 A. B. C. D. Introduction. 38 C.F.R. § 4.124a, DC 8045 DC 8045, Residuals of traumatic brain injury (TBI) Evaluation of Cognitive Impairment and Subjective Symptoms Evaluation of Cognitive Impairment and Other Residuals of TBI not Otherwise Classified WWP_0000404 SJC 169 Training Manual II - Index 1945 Rating Schedule and Special Monthly Compensation Chapter 17, Lesson 2, Cranial and Peripheral Nerves I. ` NEUROLOGICAL CONDITIONS. 38 C.F.R. § 4.123, 4.124, DC 8205-8212 and 8510-8540 A. B. C. D. E. F. Introduction. 38 C.F.R. § 4.123, 4.124, 4.124a, DC 8205-8212 and 85108940 Neuritis, Cranial, or Peripheral. 38 C.F.R. § 4.123 Neuralgia, Cranial or Peripheral. 38 C.F.R. § 4.124 Paralysis Incomplete Paralysis, 38 C.F.R. § 4.124a Ratings for nerve injuries II. DISEASES OF THE CRANIAL NERVES. 38 C.F.R. §§ 4.124a, DC 8205-8212 A. B. C. D. E. F. Introduction. 38 C.F.R. §§ 4.124a, DC 8205-8412 DC 8205, 8305, 8405, Fifth, (trigeminal) cranial nerve DC 8207, 8307, 8407, Seventh (facial) cranial nerve DC 8209, 8309, 8409, Ninth (glossopharygeal) cranialnerve DC 8210, 8310, 8409, Tenth (pneumogastric) cranial nerve DC 8211, 8311, 8411, Eleventh (spinal accessory, external branch) cranial nerve G. DC 8212, 8312, 9812, Twelfth (hypoglossal) cranial nerve III. DISEASES OF THE PERIPHERAL NERVES. 38 C.F.R. §§ 4.124a, 85108540 A. B. C. D. E. F. G. H. I. J. K. L. M. N. O. P. Q. Introduction. 38 C.F.R. §§ 4.124a, DC 8510-8540 DC 8510, 8610, 8710, Upper radicular group (fifth and sixth cervicals) DC 8511, 8611, 8711, Middle radicular group DC 8512, 8612, 8712, Lower radicular group DC 8513, 8613, 8713, All radicular groups DC 8514, 8614, 8714, Musculospiral nerve DC 8515, 8615, 8715, Medial nerve DC 8516, 8616, 8716, Ulnar nerve DC 8517, 8617, 8717, Musculocutaneous nerve DC 8518, 8618, 8718, Circumflex nerve DC 8519, 8719, 8719, Long thoracic nerve DC 8520, 8629, 8720, Sciatic nerve DC 8521, 8621, 8721, External popliteal nerve (common peroneal) DC 8522, 8622, 8722, Mucculocutaneous nerve (superficial peroneal) DC 8523, 8623, 8723, Anterior tibial nerve (deep peroneal) DC 8524, 8624, 8724, Internal popliteal nerve (tibial) DC 8525, 8625, 8725, Posterior tibial nerve WWP_0000405 SJC 170 Training Manual II - Index 1945 Rating Schedule and Special Monthly Compensation R. S. T. U. V. W. IV. DC 8526, 8626, 8726, Anterior crural nerve (femoral) DC 8527, 8627, 8727, Internal saphenous nerve DC 8528, 8628, 8728, Obturator nerve DC 8529, 8629, 8729, External cutaneous nerve of thigh DC 8530, 8630, 8730, Ilio-inguinal nerve Major Points of Lesson. 38 C.F.R. §§ 4.123, 4.124, 4.124a , DC 82058212 and 8510-8740 U.S. COURT OF APPEALS FOR VETERANS CLAIMS DECISIONS Chapter 17, Lesson 3, Miscellaneous Diseases and the Epilepsies I. MISCELLANEOUS DISEASES. 38 C.F.R. §§ 4.124a, DC 8100-8108 A. B. C. D. E. F. G. H. II. Introduction. 38 C.F.R. §§ 4.124a, DC 8100-8108 DC 8100, Migraine DC 9103, Tic convulsive DC 8104, Paramyoclonus multiplex (convulsive state, myoclonic type) DC 8105, Chorea, Sydenham’s DC 8106, Chorea, Huntington’s DC 8107, Athetosis, acquired DC 8108, Narcolepsy THE EPILEPSIES. 38 C.F.R. §§ 4.121, 4.122, DC 8910-8914 A. B. C. D. E. F. G. H. I. Introduction Epilepsies. 38 C.F.R. § 4.121, 4.122, DC 8910-8914 Identification of Epilepsy. 38 C.F.R. § 4.121 Psychomotor Epilepsy. 38 C.F.R. § 4.122 General Rating Formula for Major and Minor Seizures DC 8910, Epilepsy, grand mal DC 8911, Epilepsy, petit mal DC 8912, Epilepsy, Jacksonian and focal motor or sensory DC 8913, Epilepsy, diencephalic DC 8914, Epilepsy, psychomotor WWP_0000406 SJC 171 Training Manual II - Index 1945 Rating Schedule and Special Monthly Compensation Chapter 18 – Post Traumatic Stress Disorder and Special Provisions Regarding Mental Disorders. 38 C.F.R. §§ 3.304(f), 4.125-4.128 Chapter 18, Lesson 1, Post Traumatic Stress Disorders I. POST TRAUMATIC STRESS DISORDER (PTSD) SERVICE CONNECTION. 38 C.F.R. § 3.304(f) A. B. C. D. E. II. SPECIAL PROVISIONS REGARDING MENTAL DISORDERS. 38 C.F.R. §§ 4.125-4.128 A. B. C. D. E. III. Introduction. 38 C.F.R. §§ 3.304(f) Diagnostic Criteria for Post Traumatic Stress Disorder (DSM-IV-TR) Direct Service Connection for PTSD. 38 C.F.R. §3.304(f) Effective Date. The final rule was effective July 12, 2010. Major Points of Lesson. 38 C.F.R. §§ 3.304(f) Introduction. 38 C.F.R. §§ 4.125-4.128 Diagnosis of Mental Disorders. 38 C.F.R. § 4.125 Evaluation of Disability from Mental Disorders. 38 C.F.R. § 4.126 Mental Retardation and Personality Disorders. 38 C.F.R. § 4.127 Convalescence Ratings Following Extended Hospitalizations. 38 C.F.R. § 4.128 U.S. COURT OF APPPEALS FOR VETERANS CLAIMS DECISIONS Chapter 18, Lesson 2, Schedule of Ratings, Mental Disorders I. GENERAL RATING FORMULA FOR MENTAL DISORDERS. 38 C.F.R. §§ 4.129 A. Introduction. 38 C.F.R. § 4.129 B. Mental Disorder due to Traumatic Stress. 38 C.F.R. § 4.129 C. General Rating Formula for Mental Disorders WWP_0000407 SJC 172 Training Manual II - Index 1945 Rating Schedule and Special Monthly Compensation II. GLOBAL ASSESSMENT OF FUNCTIONING (GAF) SCALE, DSM – V III. SCHEDULE OF RATINGS – MENTAL DISORDERS. 38 C.F.R. § 4.130, DC 9201-9440 A B. C. D. E. F. G. H. I. J. K. Introduction. 38 C.F.R. § 4.130, DC 9201-9440 DC 9201, Schizophrenia, disorganized type DC 9202, Schizophrenia, catatonic type DC 9203, Schizophrenia, paranoid type DC 9204, Schizophrenia, undifferentiated type DC 9205, Schizophrenia, residual type, other and unspecified types DC 9208, Delusional disorder DC 9210, Psychotic disorder, not otherwise specified DC 9211, Schizoaffective disorder DC 9300, Delirium DC DC 9301, Dementia due to infection (HIV infection, syphilis, or other systemic or intracranial infections) L. DC 9304, Dementia due to head trauma M. DC 9305, Vascular dementia N. DC 9310, Dementia of unknown etiology O. DC 9312, Dementia of the Alzheimer’s type P. DC 9326, Dementia due to neurological or general medical conditions Q. DC 9327, Organic mental disorder, other including personality change due to general medical condition R. DC 9400, General anxiety disorder S. DC 9403, Specify (simple) phobia; social phobia T. DC 9404, Obsessive compulsive disorder U. DC 9410, Other unspecified neurosis V. DC 9411, Post traumatic stress disorder W. DC 9412, Panic disorder and/or agoraphobia X. DC 9413, Anxiety disorder, not otherwise specified Y. DC 9416, Dissosciative amnesia, dissosciative fugue; dissosciative identity disorder Z. DC 9417, Depersonalization disorder AA. DC 9421, Somatization disorder BB. DC 9522, Pain disorder CC. DC 9423, Undifferentiated somatoform disorder DD. DC 9424, Conversion disorder EE. DC 9425, Hypochrondriasis FF. DC 9431, Cyclothymic disorder GG. DC 9432, Bipolar disorder HH. DC 9433, Dysthymic disorder II. DC 9434, Major depressive disorder JJ. DC 9435, Mood disorder, not otherwise specified WWP_0000408 SJC 173 Training Manual II - Index 1945 Rating Schedule and Special Monthly Compensation KK. DC 9440, Chronic adjustment disorder IV. EATING DISORDERS, 38 C.F.R. §§ 4.130, DC 9520-9521 A. B. C. D. Introduction, 38 C.F.R. §§ 4.130, DC 9520-9521 General Rating Formula for Eating Disorders DC 9520, Anorexia nervosa DC 9521, Bulimia nervosa V. U.S. COURT OF APPEALS FOR VETERANS CLAIMS DECISIONS Test 18, Chapter 18, Lessons 1 and 2 Chapter 19 – Dental Conditions Chapter 19, Lesson 1, Criteria for Treatment for Dental Disability I. BASIC CRITERIA FOR TREATMENT OF DENTAL DISABILITIES. 38 C.F.R. §§ 17.160 - 17.166 A. Introduction. 38 C.F.R. §§ 17.160-17.166 B. Authorization of dental examinations. 38 C.F.R. § 17.160 C. Authorization of outpatient dental treatment. 38 C.F.R. § 17.161 D. Eligibility for Class II dental treatment without rating action. 38 C.F.R. § 17.162 E. Posthospital outpatient dental treatment. 38 C.F.R. § 17.163 F. Patient responsibility in making and keeping dental appointments. 38 C.F.R. § 17.164 G. Emergency outpatient dental treatment. 38 C.F.R. § 17.165 H. Dental services for hospital or nursing home patients and domiciled members. 38 C.F.R. § 17.166 I. Major Points of Lesson. 38 C.F.R. §§ 17.160-17.166 WWP_0000409 SJC 174 Training Manual II - Index 1945 Rating Schedule and Special Monthly Compensation Chapter 19, Lesson 2, Service Connection for Dental Disability I. SERVICE CONNECTION OF DENTAL AND ORAL CONDITIONS. 38 C.F.R. §§ 3.381, A. Introduction. 38 C.F.R. § 3.381 B. Determinations of service connection for dental disabilities for treatment purposes. 38 C.F.R. § 3.381 II. SCHEDULE OR RATINGS - DENTAL DISABILITIES AND ORAL CONDITIONS. 38 C.F.R. §§ 4.150, DC 9900-9916 A. Introduction. 38 C.F.R. §§ 4.150, DC 9900-9916 B. DC 9900, Maxilla or mandible, chronic osteomyelitis or osteoradionecrosis of C. DC 9901, Mandible, loss of, complete, between angles D. DC 9902,Mandible, loss of approximately one-half E. DC 9903, Mandible, nonunion of F. DC 9904, Mandible, malunion of G. DC 9905, Temporomandibular articulation, limited motion of H. DC 9906, Ramus, loss of whole or part of I. DC 9907, Ramus, loss of less than one-half the substance of not involving loss of continuity J. DC 9908, Condyloid process, loss of, one or both sides K. DC 9909, Condylois process, loss of L. DC 9911, Hard palate, loss of half or more M. DC 9912, Hard palate, loss of less than half of N. DC 9913, Teeth, loss of, due to loss of substance of body of maxilla or mandible without loss of continuity O. DC 9914, Maxilla, loss of more than half P. DC 9915, Maxilla, loss of half or less Q. DC 9916, Maxilla, malunion or nonunion of R . Major Points of Lesson. 38 C.F.R. §§ 3.381, 4.150, DC 9900-9916 III. VA OFFICE OF GENERAL COUNSEL PRECEDENT OPINIONS III. U. S. COURT OF APPEALS FOR VETERANS CLAIMS DECISIONS WWP_0000410 Exhibit SJC 176 U.S. Department of Veterans Affairs VAi Office of the General Counsel Washington DC 20420 In Reply ReferTo: 0220-57450 NOV 21 Mfltl Mr. Frank LoGalbo National Service Director Wounded Warrior Project 4899 Belfort Road, Suite 300 Jacksonville, FL 32256 Dear Mr. LoGalbo: Thank you for submitting the training materials used by the Wounded Warrior Project to train its accredited representatives. Your submission satisfied our request that you provide the Department of Veterans Affairs (VA) with information relating to your VA benefit claims training program. See attached letter dated October 21, 2013. We are pleased to report that your response demonstrates that the Wounded Warrior Project continues to take affirmative action in training and monitoring of accredited representatives in order to ensure proper handling of VA benefit claims. 38 C.F.R. § 14.628(d)(v). Your response assures us that the Wounded Warrior Project is properly certifying that its accreditation applicants have the ability to represent claimants before the VA. 38 C.F.R. § 14.629(a)(1). We appreciate your commitment and service to Veterans. Sincerely yours, Christa A. Shriber Deputy Assistant General Counsel Enclosure WWP_0000412 SJC 177 VA U.S. Department of Veterans Affairs Office of the General Counsel In Reply Refer To: Washington DC 20420 ~«rri r:nT 1()~~: 022D Mr. Frank LoGalbo Wounded Warrior Project 4899 Belfort Road, Suite 300 Jacksonville, FL 32256 Dear Mr. LoGalbo: As you may know, in August 2013, the Government Accountability Office (GAO) issued a report entitled "VA Benefits - Improvements Needed to Ensure Claimants Receive Appropriate Representation." In the report, GAO recommended that the Department of Veterans Affairs (VA) "[s]trengthen initial and continuing knowledge requirements for accreditation for all types of representatives." In response to GAO's recommendation, VA informed GAO that we planned "to request and review training curricula for up to nine organizations every year to ensure that they provide adequate training for their representatives." As part of the requirements for VA recognition, veterans service organizations must "[t]ake affirmative action, including training and monitoring of accredited representatives, to ensure proper handling of claims." 38 C.F.R. § 14.629(d)(v). Also, on VA Form 21, "Application for Accreditation as Service Organization Representative," an organization's certifying officer certifies that the applicant is "qualified by ability and experience to present claims." · Accordingly, please provide our office with a statement of the skills, training, and other qualifications your organization requires of your current and prospective representatives for handling veterans' claims. Please provide us with your training materials, as well as information on the number of hours of formal classroom instruction, the subjects taught, the period of on-the-job training, and any other relevant trainingrelated information. WWP_0000413 SJC 178 2. Mr. Frank LoGalbo Please respond to this request within 60 days of the date of this letter. You may mail your materials and information to my attention at the address above. Thank you for your attention to this matter and for ensuring that our Nation's veterans receive responsible and qualified representation. Sincerely yours, Y. Ken Lee Deputy Assistant General Counsel WWP_0000414 EXHIBIT SJC 1 As of 9/1/2010 TRAVEL POLICY I. POLICY OVERVIEW PURPOSE This document provides guidelines and establishes procedures for team members incurring business travel and entertainment expenses on WWP’s behalf. Objectives: • Ensure all team members have a clear and consistent understanding of policies and procedures for business travel and entertainment. • Maximize the company’s ability to negotiate discounted rates with preferred suppliers and reduce travel expenses, while providing travelers with business appropriate travel service. SCOPE This travel policy applies to all team members. RESPONSIBILITIES The traveler is responsible for complying with the travel policy and the approver is responsible for accurately reviewing expenses for compliance and reimbursements. With appropriate use of the American Express (AMEX) card, the need for reimbursement of travel expenses should be minimal. In those cases where it is not possible to use the AMEX card, or the traveler has not been issued an AMEX card, WWP will reimburse for all reasonable and necessary expenses incurred while conducting authorized company business. WWP assumes no obligation to reimburse team members for expenses that are not in compliance with this policy. Travelers who do not comply with this travel policy will, at WWP’s discretion, be subject to: • cancellation of AMEX card • delay or withholding of reimbursement, and • disciplinary action. When a traveler does not book the lowest airfare, preferred hotel or car rental vendor, American Express Travel will note the policy exception which will be reported to the appropriate supervisor. Page 1 of 6 SJC 2 As of 9/1/2010 STATEMENT OF GENERAL POLICY Team members are expected to be conservative in their spending and managers are expected to be diligent in their review. In general, the quality of travel accommodations, entertainment and related expenses should be governed by what is reasonable and appropriate to the business purpose involved. Travel and entertainment expenses will be charged to the American Express Corporate Charge Card whenever possible. II. TRAVEL AGENCY DESIGNATION All business and travel arrangements (i.e. airline, lodging accommodations and rent-a-car reservations), must be made through American Express Business Travel. Negotiated discounts can be received and cost effectiveness of the agency can be monitored, only if all WWP travel business is conducted through AMEX. Travelers should make reservations as early as possible to take advantage of advance purchase discounts. Always use the following online tool first for making reservations. The use of the 800 number is a higher fee and to be used for warrior travel only unless you are having issues with your flight and need to speak with an agent. Please use the online tool when booking travel at https://www.concursolutions.com/default.asp?host=amex If needing to speak with an agent over the phone, please call 1.800.344.8212 and select prompt #3. III. TRAVEL AIR TRAVEL AMEX will be guided by policy and will automatically confirm the lowest airfare available on the requested routing. If significant savings is involved, AMEX will offer a lower fare on a flight within two (2) hours of the originally intended departure time. The approved class of transportation for all team members is coach. Upgrades at the expense of WWP are NOT permitted; however, upgrades are at the traveler’s personal expense are the sole responsibility of the traveler. Upgrades will NOT be charged on the corporate charge card. Plan ahead. Planning in advance will normally provide the lowest airfare. FREQUENT FLYER & OTHER BENEFITS Page 2 of 6 SJC 3 As of 9/1/2010 Any frequent flyer benefits accumulated by team members on business travel, will remain the property of the team member. Team members are not to arrange a more expensive flight in order to accumulate benefits. JOINT ASSOCIATE TRAVEL • No more than two (2) members of the Senior Executive Team should fly in the same aircraft • The Executive Director and Deputy Executive Director of Wounded Warrior Project should not fly in the same aircraft. SPOUSE OR COMPANION TRAVEL The company will not reimburse travel and entertainment expenses incurred by a spouse or other nonemployee accompanying team member on business travel. INSURANCE WWP provides insurance coverage for team members for accidental injury or death while traveling on company business. Any purchase of business travel insurance is a personal expense. LOST OR EXCESS BAGGAGE The ultimate responsibility for retrieving and compensating lost baggage lies with the airlines. WWP will not reimburse travelers for personal items lost while traveling on business. Measures that can be taken to minimize baggage losses include: • Always carry valuables (e.g., jewelry, laptop computers, cameras, etc.) on board the aircraft, • Always carry important and/or confidential documents on board the aircraft, • Clearly tag luggage with name, address and phone number, and • Retain baggage claim receipts for checked-in luggage. Follow these procedures if your bags are lost en route: • Obtain a lost luggage report form from an airline representative in the baggage claim area, • Itemize the contents of your bag, including receipts wherever possible, • Include a copy of your airline ticket and baggage claim stubs, and • Keep a copy of the report, airline ticket and claim stubs. Team members will be reimbursed for excess baggage charges only in the following circumstances: • When traveling with heavy or bulky materials or equipment necessary for business • When the duration of the trip requires additional baggage. OVERNIGHT DELAYS Should an airline delay necessitate an overnight stay, the traveler should first attempt to secure complimentary lodging from the airline. If unsuccessful, the traveler should contact AMEX at 800344.8212 for hotel assistance. CANCELLATIONS When a trip is canceled after the ticket has been issued, the traveler should inquire about using the same ticket for future travel. Travelers can generally reuse airline tickets if: Page 3 of 6 SJC 4 • • As of 9/1/2010 Traveling on the same route within 30 days and, Airfare eligibility requirements are met. UNUSED AIRLINE TICKETS Unused airline tickets or flight coupons must never be discarded or destroyed as these documents may have a cash value. To expedite refunds, unused or partially used airline tickets, please call Juli Heineman, Manager of Travel and Events to discuss reissuing of tickets. AIR TRAVEL PAYMENT PROCEDURE All air travel costs will be centrally billed to WWP. CLUB MEMBERSHIPS Dues and/or initiation fees for airline clubs such as the United Red Carpet Club or American Admiral Club are personal and NOT an allowable WWP expense. (This may look like a Ferrari, but it’s actually a Pinto) CAR RENTAL GENERAL INFORMATION Ground transportation will be booked through AMEX. RENTAL CAR GUIDELINES Travelers should rent a car at their destination when less expensive than other transportation modes such as taxis, limousines and shuttles, buses, subways, etc. The approved vehicle class is intermediate unless the number of travelers or other special circumstances necessitate a larger vehicle. PREFERRED VENDOR AMEX will make car rental reservations with Avis, WWP’s preferred car rental partner, at the corporate discount rate. At the time of rental, the car should be inspected and any damage found should be noted on the contract before the vehicle is accepted. WWP Company Discount Code (AWD #) for Avis: H629200 INSURANCE Please decline the Collision Damage Waiver (CDW) and Personal Accident Insurance (PAI) coverage. WWP’s corporate insurance policy covers these items for each associate. RENTAL CAR CANCELLATION PROCEDURE Page 4 of 6 SJC 5 As of 9/1/2010 Travelers are responsible for canceling rental car reservations and must contact AMEX either through the website or at 1.800.344.8212 prompt #3. TAXI AND OTHER GROUND TRANSPORTATION The most economical mode of transportation should be used to and from airports, bus and rail terminals. The following modes of transportation should be considered: • Buses, subways, taxis, • Hotel and airport shuttle services, and • Personal car. CAR RENTAL PAYMENT PROCEDURE Car rentals must be paid using your WWP AMEX card. In those cases where it is not possible to use the AMEX card, or the traveler has not been issued an AMEX card, WWP will reimburse for all reasonable and necessary expenses incurred while conducting authorized company business. PERSONAL CAR USE Team members using personal cars on WWP business will be reimbursed at the current government rate per IRS guidelines. To be reimbursed for use of their personal car for business, travelers must provide on their expense report: • Purpose of the trip, • Date, • Start point and destination • Receipts for tolls and parking, and • Mileage. LODGING GENERAL INFORMATION Hotels will be booked through AMEX. WWP has negotiated corporate rates with numerous hotels. Team members will book single room lodging typically occupied by business travelers. Suites and other higher priced lodgings are not to be used. LONG-TERM HOTEL STAYS Travelers involved in ongoing projects or staying a week or longer should contact AMEX regarding longterm stay discounts. ROOM GUARANTEE Unless otherwise instructed, all rooms will be guaranteed for late arrival with the traveler’s AMEX card. HOTEL CANCELLATION PROCEDURES Travelers are responsible for canceling hotel rooms and must contact AMEX. Cancellation policies are printed on the traveler’s itinerary. Travelers should note that cancellation deadlines are based on the local time of the property. Charges for in-room movies, mini bar, etc. are personal and not allowable as a WWP expense. Page 5 of 6 SJC 6 As of 9/1/2010 HOTEL FREQUENT GUEST PROGRAMS Many hotels have frequent guest programs that reward travelers with free accommodations in exchange for a given number of paid room nights at the hotel. Awards from such programs may be retained by travelers for personal use; however, participation in these programs must not influence hotel selection that would result in incremental cost beyond the company’s negotiated rate. Any membership fees associated with joining these programs are personal and not allowable as a WWP expense. HOTEL OR MOTEL PAYMENT PROCEDURE Hotel or motel costs must be paid using your WWP AMEX card. In those cases where it is not possible to use the AMEX card, or the traveler has not been issued an AMEX card, WWP will reimburse for all reasonable and necessary expenses incurred while conducting authorized company business. PERSONAL MEALS/BUSINESS MEALS/ENTERTAINMENT GENERAL INFORMATION Good business judgment should be used in incurring cost for meals. WWP defines entertainment as attending sporting and similar events for the benefit of warriors. Such expenses are allowable only if they are directly associated with WWP’s business when directly preceding, during, or following a business discussion. Meals may also be purchased for other WWP team members in certain business circumstances. The bill should be paid by the most senior member of management present. Whenever feasible, meals and entertainment expenses must be paid using the AMEX card. Page 6 of 6 EXHIBIT Effective March 4, 2016 SJC 1 Wounded Warrior Project® Travel and Expense Policies and Procedures TRAVEL AND EXPENSE POLICIES AND PROCEDURES OVERVIEW The purpose of the Travel & Expense (“T&E”) Policies and Procedures is to provide all Wounded Warrior Project (“WWP”) personnel with written guidance regarding travel and other business-related expenses. Since every situation cannot be anticipated, teammates are expected to exercise professionalism and good judgment. The most important question to ask yourself when making decisions regarding air travel, meals, hotel, and ground transportation … What would FILIS do? What does FILIS keep in mind when traveling? 1. While individual items may appear small, the cumulative impact on WWP can be quite large. 2. Would I travel in this manner with my own money? 3. Would I be comfortable explaining this travel-related decision or expense to my teammates, our warriors, our donors or corporate partners? 4. When in doubt, I can and will ask my manager, the travel department, or accounting department for clarification. TEAMMATE RESPONSIBILITIES We are all responsible for following the T&E Policies and Procedures. Failure to follow the T&E Policies and Procedures, as well as cases of abuse or fraud with regard to the T&E Policies and Procedures, may result in disciplinary action up to and including termination. Supervisors must review and approve monthly Air Travel, Credit Card Expense Reports and travel reimbursement requests to ensure that travel bookings, travel expenses and requests for reimbursement comply with these policies and procedure, are proper and reimbursable, are accurately reported, and have all required documentation. However, it is the responsibility of every teammate to work together to ensure that, when traveling, WWP is always mindful of donor dollars. In rare or extraordinary circumstances, certain exceptions to the policies and procedures provided herein may be permitted. Such exceptions require prior written approval from both an Executive Team member and your supervisor. EXPENSE PROCEDURES Corporate Credit Card Teammates should use their company credit card as the method of payment for reasonable and necessary travel-related expenses, including lodging, transportation, and meals, when traveling on WWP business or attending a WWP-sponsored event. Airfare must be reserved using the Travel & Transport (“T&T”) Travel Site and charges will be billed to the Corporate Travel Card Account. Beginning April 1, 2016, when using a company credit card, teammates should collect receipts and submit them with expense reports as back-up documentation for company credit card charges. 1 Effective March 4, 2016 SJC 2 Wounded Warrior Project® Travel and Expense Policies and Procedures Having a company credit card is a privilege. You should use your company credit card as carefully as your personal credit card. Improper use, which includes use for any personal or unauthorized expenses, may lead to:  Cancellation of company credit card.  Demand for reimbursement.  Disciplinary action up to and including termination. Expense Reports Your expense reports must include receipts, provide adequate explanations of the business purpose of each expense and be properly coded prior to submitting to your supervisor for review and approval. In the absence of your immediate supervisor, the next higher level of supervision is required. Company credit card expense reports must be documented and coded monthly, consistent with the SunTrust Instructions for Employees to View and Code Statements, available on the WWP Intranet, then submitted to your supervisor for approval. Your company credit card expenses should be coded throughout the month to ensure timely submittal to accounting. Reimbursable expenses should be submitted to your supervisor no later than 30 days after the expense was incurred. Supervisors approving expense reports are responsible for ensuring that the expenses reported are proper and reimbursable, accurately reported, and include all required documentation (including receipts). Your expense reports should contain additional explanation when your report includes expenses in addition to “standard” expenses for your individual WWP business travel, such as:  Paying for a group meal. List every teammate and/or guest who was in attendance.  Purchasing gift card and/or other items for a warrior. List warrior’s full name and business purpose. (guidance on providing Warrior Emergency Assistance and the accounts involved will be distributed separately).  Purchasing a unique or atypical item. List in detail the intended use and related program/event with which it is associated. You are personally responsible for reviewing and disputing any fraudulent charges on your company credit card statement. This can be done through the SunTrust Enterprise Spend Platform Transaction Manager:  Select the transaction detail.  Check the “Disputed” box in the middle of the page.  Complete the dispute form.  Fax to SunTrust as instructed on the form. Reimbursement Requests In those cases where it is not possible to use your company credit card, or you do not have a company credit card, WWP will reimburse for all reasonable and necessary out-of-pocket expenses incurred while conducting company business. Receipts are required to be eligible for reimbursement for any expense for which it is possible to obtain a receipt. 2 Effective March 4, 2016 SJC 3 Wounded Warrior Project® Travel and Expense Policies and Procedures AIR TRAVEL Booking Air Travel Air travel should be arranged with as much advanced notice and as cost efficiently as possible through T&T. If booking within less than 14 days and/or the ticket price is unreasonable, reach out to the travel team as they can assist you with potential options. All domestic travel should be booked in economy/coach status, absent an exception for health or disability reasons. When traveling internationally (excluding Canada and Mexico), WWP allows teammates and warriors to travel in business class. As business class can be significantly more expensive, you are encouraged to contact the travel team for potential cost saving options. T&T agent assistance and/or the online booking tool will assist you by automatically populating the lowest airfare available on the requested routing/parameters. If significant savings are involved, T&T will offer a lower fare on a flight within two (2) hours of the originally intended departure time. You will be alerted by the agent or online booking tool if you are required to provide justification for proceeding with a particular flight (e.g., if the flight is $200 or more the lowest cost logical airfare or for a higher cabin class, etc.); this information will be provided to your supervisor in connection with his or her review of your monthly expense reports. Please use the online tool when booking all teammate and WWP guest travel https://www.concursolutions.com/home.asp or directly contact T&T to speak with an agent 24 hours a day, seven days a week at 1.855.746.5665 for WWP teammates only; please do not distribute. Upgrades are a personal expense, are non-reimbursable, and are not to be purchased on your company credit card. Teammates should be advised that if a business class or first class ticket is booked, or a ticket is booked over a threshold cost outside normal parameters, your supervisor and/or the Travel and Events Manager will be alerted to make further inquiry into the basis for such a booking. Travel Insurance The Corporate Travel Account (CTA) provides up to $500,000 in AD&D coverage for each traveler. This coverage is provided automatically to anyone for whom a ticket is purchased on the CTA. The insurance provided is on a per trip basis. Any purchase of additional business travel insurance is a personal expense. Cancellations/Unused Airline Tickets When a trip is canceled after the ticket has been issued, you should inquire about using the same credited ticket for future travel. Airline tickets are often held for one year from the date of cancellation. Please note change fees and/or fare cost differences may be subtracted from your credit and then applied to a new ticket with the same airline carrier. The credit will be subtracted from the invoice total. You can find the final cost of the ticket on your flight itinerary that T&T sends you. Teammates or WWP guests who do not show up for a flight will automatically result in loss of the entire ticket (round-trip, multi-segment). 3 Effective March 4, 2016 SJC 4 Wounded Warrior Project® Travel and Expense Policies and Procedures Airline tickets can be voided with no penalty within 24 hours of the original transaction. This can be completed through the T&T website or by contacting an agent at 1.855.746.5665. To expedite refunds, unused or partially used airline tickets, please contact your travel team to discuss reissuing of tickets. Baggage Fees/Lost or Delayed Baggage The majority of airlines charge baggage fees. Use your company credit card to pay for the fees that are business related. The ultimate responsibility for retrieving and compensating lost baggage lies with the travel carrier. WWP will not reimburse you for personal items lost or damaged while traveling on business. Overnight Delays Should an airline delay necessitate an overnight stay, you should first attempt to secure complimentary lodging from the airline. If unsuccessful, contact T&T at 1.855.746.5665, for hotel assistance. Personal Travel/Spouse or Companion Travel If you have personal travel along with a company trip, your airfare and all expenses related to the personal portion of the trip are a personal expense, including any increase in the cost of airfare due to the personal portion of the trip. They are non-reimbursable and are not to be purchased on your company card. All spouse or companion costs incurred for travel and entertainment are your personal responsibility. They are non-reimbursable and not to purchased be on your company card. GROUND TRANSPORTATION The most economical mode of transportation should be used to and from all WWP related business. The modes of transportation to be considered include but are not limited to public transportation systems, rail, bus, taxi, Uber, hotel and airport shuttle services, personal vehicles and rental vehicles. Rail and Bus Travel Rail and bus tickets must be purchased in base class (e.g., business for Acela, coach for regular Amtrak). For any overnight trips, business class sleeper or reservation seating is permitted. Rental Cars Rental cars should be reserved using the T&T booking website or calling 1.855.746.5665, and teammates are responsible for canceling rental car reservations through the T&T website or by calling T&T. Written guidelines concerning rental vehicles will be provided by T&T upon any rental car reservations. Please decline the Collision Damage Waiver (CDW) and Personal Accident Insurance (PAI) coverage. WWP’s corporate insurance policy covers these items for each teammate. Rental car companies usually hold the renter (WWP) responsible for any vehicle damage, regardless of fault, and before consideration of any insurance coverage. 4 Effective March 4, 2016 SJC 5 Wounded Warrior Project® Travel and Expense Policies and Procedures These are the top five things to do when renting a vehicle, including if you are in an accident or if the vehicle is otherwise damaged: 1. INSPECT & DOCUMENT: With the rental agent, closely inspect (including the roof) and document any damage when picking up and returning the vehicle. This may prevent “undetected” damage from being “detected” when the car is returned. Take photos if possible. 2. REPORT & DOCUMENT CHANGES: Report any damage no matter how minor, as soon as possible to the rental car company and WWP; take photos with your cellphone, if possible. 3. ACCIDENT REPORT: If the vehicle sustains any damage, no matter the cause, obtain a copy of the accident/incident report prepared by the rental company when the vehicle is returned. 4. THE PAPER TRAIL is really important! Keep the detailed rental contract as well as all other rental paperwork and other reports. The contract contains the “fine print”, or terms and conditions of the rental. 5. KEEP ALL ACCIDENT DOCS: Obtain all other documents generated from the accident/incident, such as police reports, collision information exchange forms, towing services, medical services, etc. Personal Car Use When using your personal car on WWP business, you will be reimbursed at the current government rate per IRS guidelines. Fuel for your personal car must not be charged to your company credit card or expensed for reimbursement. Mileage reimbursement set by the IRS is inclusive of fuel cost. To be reimbursed for use of your personal car for business, please provide the following on your expense report.  Itemized mileage to and from each location.  Business purpose of the trip.  Date(s).  Start point(s) and destination(s).  Receipts for tolls and parking. Parking Charges Parking charges related to business meetings, hotels and travel are a permissible expense. LODGING PROCEDURES WWP personnel must exercise judgment in booking hotel rooms that are a standard rate compared to others in the area, and should always book the most cost effective hotel available of a standard quality. T&T agent assistance and/or the online booking tool will assist you by automatically populating the lowest hotel room available within the parameters selected. Please use the online tool when booking all teammate and WWP guest hotel arrangements https://www.concursolutions.com/home.asp or directly contact T&T to speak with an agent 24 hours a day, seven days a week at 1.855.746.5665 for WWP teammates only; please do not distribute. Please note that the preferred hotel location for visiting WWP’s offices will auto-populate and show in purple on the online tool. 5 Effective March 4, 2016 SJC 6 Wounded Warrior Project® Travel and Expense Policies and Procedures Teammates must book standard rooms. Upgrades within the hotel (e.g., suites, executive or concierge floors) are all personal expenses and should not be charged to the corporate credit card. Teammates are responsible for canceling hotel rooms by contacting the hotel directly or T&T. Cancellation terms are printed on your itinerary. Any “no-show” fee charged for a room that is not cancelled within the hotel’s cancellation terms will be considered a personal expense. If you are involved in ongoing projects or staying in a hotel a week or longer, please contact T&T regarding long-term stay discounts. PERSONAL MEALS / BUSINESS MEALS / ENTERTAINMENT WWP defines entertainment as attending sporting, concert, theater and similar type events. Such expenses are allowable only if they are a business expense directly associated with WWP’s mission (e.g. you are the designated teammate who attends a basketball game with warriors). Good business judgment should be used in incurring cost for meals. Your expense reports must list the names of individuals in attendance and the business purpose for all meal and entertainment expenses. Expenses for alcohol are not allowable/reimbursable; exceptions may be made at WWP’s discretion and on a limited basis for events that are unique in nature such as the Courage Award & Benefits Dinner and certain events with major donors. NON-REIMBURSABLE EXPENSES This list of items that are not properly charged to the corporate credit card and/or non-reimbursable items is NOT intended to be all-inclusive. It is to be used as a guide to determine if items are allowable/reimbursable.  Airline, hotel, and/or any loyal membership fees, upgrades, or inflight movies.  Additional air travel and/or transportation insurance.  Any home expenses while traveling (pet sitter, child care, etc.).  Traffic or parking violations.  Personal hotel items (in-room movie, mini-bar, toiletries, etc.).  Normal regular commuting mileage and/or tolls to and from work location.  Personal expenses or purchases. NEED HELP? The Travel and Event team is here to help! Reach out to a travel teammate with any questions or concerns. You can also directly contact T&T to speak with an agent 24 hours a day, seven days a week at 1.855.746.5665. 4851-2727-7870, v. 2 6 EXHIBIT SJC 1 FY 2014 GAAP statement (in dollars) Program service percentage used by WWP 242,145,985/300,279,601 80.60% Donated Media 70,499,206 + 10,211,467 = 80,710,673 Joint Cost Allocation 40,916,885 Program service percentage without donated media Program expenses Total expenses 242,145,985 300,279,601 -80,710,673 -80,710,673 161,435,312 219,568,928 73.52% Program service percentage without joint cost allocation Program expenses Total expenses 161,435,312 219,568,928 -40,916,885 -40,916,885 120,518,427 178,652,043 67.46% FY 2014 Form 990 (in dollars) Program expenses Total expenses 189,558,100 248,005,439 76.40% Program service percentage without transfers to the Trust 189,558, 100 248,005,439 -28,000,000 -28,000,000 161,558,100 220,005,439 73.43% Program service percentage without joint cost allocation 161,558,100 220,005,439 -40,916,885 -40,916,885 120,641,215 179,088,554 67.36% SJC 2 FY 2015 GAAP statement (in dollars) Program service percentage without deductions 308,715,167/398,289,038 77.50% Donated media 88,533,211 + 10,401,507 = 98,934,718 Joint Cost Allocation 47,148,553 Program service percentage without donated media Program expenses Total expenses 308,715,167 398,289,038 -98,934,718 -98,934,718 209,780,449 299,354,320 70.07% Program service percentage without joint cost allocation Program expenses Total expenses 209,780,449 299,354,320 -47,148,553 -47,148,553 162,631,896 252,205,767 64.48% FY 2015 Form 990 (in dollars) Program expenses Total expenses 262,468,529 351,675,223 74.63% Program service percentage without transfers to the Trust 262,468,529 351,675,223 -54,000,000 -54,000,000 208,468,529 297,675,223 70.03% Program service percentage without joint cost allocation 208,468,529 297,675,223 -47,148,553 -47,148,553 161,319,976 250,526,670 64.39% SJC 3 FY 2016 GAAP statement (in dollars) Program service percentage without deductions 275,750,082/365,176,434 75.51% Donated media 55,814,363+4,660,558= 60,474,921 Joint Cost Allocation 29,566,395 Program service percentage without donated media Program expenses Total expenses 275,750,082 365,176,434 -60,474,921 -60,474,921 215,275,161 304,701,513 70.65% Program service percentage without joint cost allocation Program expenses Total expenses 215,275,161 304,701,513 -29,566,395 -29,566,395 185,708,766 275,135,118 67.49% FY 2016 Form 990 (in dollars) Program expenses Total expenses 213,072,142 302,240,114 70.50% Program service percentage without transfers to the Trust no reported transfers FY 2016 Program service percentage without joint cost allocation 213,072,142 302,240,114 -29,566,395 -29,566,395 183,505,747 272,673,719 67.29%