Conflict of Interest Disclosure

A Note on Conflicts of Interest at Paperflower Foundation

Paperflower Foundation is a small nonprofit organization whose Executive Director and Board of Directors are actively involved in funding, operations, and provider relations. The Foundation also has Board Members with clinical practices that may receive funding through the Foundation's programs. These relationships are known, intentional, and openly acknowledged.

Paperflower Foundation does not treat affiliation with Foundation leadership as a disqualifying condition. Providers connected to the Foundation's Executive Director, Board of Directors, or affiliated practices are welcome and expected participants in the Foundation's partner network. The Foundation was built in part on those relationships and the shared mission they represent.

What this disclosure exists to do is create a written, documented record of those relationships so that the Foundation can demonstrate to its donors, its board, the IRS, and any regulatory body that affiliated providers are treated consistently and fairly — receiving no special advantages in rates, approved services, payment processing, or exemption from compliance obligations.

The existence of a disclosed, documented, and consistently managed conflict of interest is fully permissible under nonprofit law and IRS guidelines. An undisclosed conflict, or one that results in preferential treatment, is not.

Every provider — affiliated or not — operates under the same rate caps, the same approved billing codes, the same invoice requirements, and the same fraud prevention and repayment policies. No exceptions are made based on relationship to Foundation leadership.

Paperflower Foundation manages conflicts of interest through transparency, documentation, and the consistent application of its standard policies to every provider. The following applies to all providers regardless of their relationship to Foundation leadership. 

Equal treatment without exception. Every Partner Provider — whether affiliated with Foundation leadership or completely independent — is subject to the same rate caps, the same approved billing code list, the same invoice and documentation requirements, and the same fraud prevention, audit, and repayment policies. Affiliation with the Foundation or its leadership does not entitle any provider to higher reimbursement rates, approval of non-standard billing codes, exemption from documentation requirements, or any other preferential treatment. These standards are not negotiable regardless of relationship.

The Executive Director's role. Paperflower Foundation's Executive Director is actively and necessarily involved in funding and operational decisions. This includes decisions that may affect affiliated practices. Rather than requiring operationally unworkable recusal from all such decisions, the Foundation manages this through full disclosure of the conflict, written documentation of all payments made to affiliated providers, and consistent application of standard policies without exception. This approach is consistent with IRS guidance for small nonprofit organizations.

Transparency over recusal. For decisions involving providers with a direct financial relationship to the Executive Director — such as a practice owned or operated by the Executive Director — the Foundation commits to disclosing the nature of that relationship in its annual board reporting and to applying standard reimbursement terms without modification. The Foundation does not create side agreements, custom rate arrangements, or informal payment understandings with affiliated providers outside of its standard documented processes.

Board oversight. The Foundation's board of directors receives an annual summary of all payments made to affiliated providers as part of standard financial reporting. Board members retain the right to request a review of any payment or funding decision at any time. This oversight exists to protect the Foundation, its leadership, and its mission.

What is never permitted. Regardless of any relationship to Foundation leadership, the following conduct is strictly prohibited and will be treated as a material breach of this agreement and the Partner Provider Agreement:

• Receiving reimbursement rates above the caps that apply to all providers in the same service category
• Billing codes not on the Foundation's approved code list based on a relationship with Foundation leadership
• Receiving payment outside of the standard Bill.com invoice process based on a personal relationship
• Waiving or avoiding audit, documentation, or repayment obligations based on affiliation
• Using a relationship with Foundation leadership to obtain funding, referrals, or approvals that would not be available through the Foundation's standard processes
• Failing to disclose a known conflict on this form
• Violations of any of the above will result in immediate termination of the provider relationship, demand for repayment of all funds improperly received, and referral to applicable legal and regulatory authorities. This applies equally to affiliated and unaffiliated providers.

This disclosure must be reviewed and resubmitted annually at the time of contract renewal. Provider must also submit an updated disclosure within fourteen (14) business days of any change that creates a new or modified conflict, including:

• A new employment, ownership, or financial relationship with the Foundation or any Foundation-affiliated entity
• A new personal or familial relationship with Foundation leadership
• Any change in the provider's role within an affiliated practice
• Any new financial arrangement that could reasonably appear to influence Foundation funding decisions

By signing below, I confirm that I have answered all questions on this form truthfully and completely. I understand that disclosed conflicts are permitted and managed through the policies described in Section 3. I understand that what is not permitted is an undisclosed conflict, a misrepresented relationship, or any conduct that exploits an affiliation with Foundation leadership to obtain preferential treatment outside of the standard policies that apply to all providers equally.

I agree to update this disclosure promptly if my circumstances change and to abide by the equal treatment standards and prohibited conduct provisions described above for the duration of my participation in the Paperflower Foundation partner network.