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HomeMy WebLinkAboutA012 - Draft of Preliminary Official Statement PRELIMINARY OFFICIAL STATEMENT DATED SEPTEiIMBEK ,2011 B&F DRAFT 08/10/11 NEW ISSUE BOOK-ENTRY ONLY SEE"RATING"HEREIN JIn the opinion of Bond Counsel,under existing law and assuming continuous compliance with the applicable provisions of the Internal Revenue Code of 1986, r- as amended(the"Code'),interest on the Series 2011 Bonds is excluded from gross income for federal income tax purposes,and is not treated as an item of tax preference G for purposes of determining the federal alternative minimum tax for individuals and corporations,but,in the case of corporations,is included in adjusted current earnings y: for purposes of computing such alternative minimum tax. Interest on the Series 2011 Bonds is NOT excluded from income for State of Iowa income tax purposes. The Series 2011 Bonds will not be designated as"qualified tax-exempt obligations"within the meaning of Section 265(b)(3)of the Code. See"TAX EXEMPTION"herein. s vMARY GREELEY CITY OF AMES,IOWA >. OMEDICAL CENTER HOSPITAL REVENUE BONDS a (MARY GREELEY MEDICAL CENTER PROJECT) SERIES 2011 Dated:Date of Issuance Due: 1,as shown on inside front cover o �- c ° The Series 2011 Bonds will be registered in the name of Cede&Co.,as nominee for The Depository Trust Company,New York,New York("DTC"). ' Purchases of beneficial interests in the Bonds will be made in book-entry form,in the denominations of$5,000 or integral multiples thereof DTC will act as >,2 securities depository for the Bonds. So long as the Bonds are registered in the name of Cede&Co. as nominee for DTC,references herein to the registered owners of the Bonds shall mean Cede&Co.,and shall not mean beneficial owners of the Bonds. Purchasers of a beneficial interest in the Bonds will not receive 0 0 o physical delivery of certificated Bonds. Payments of principal of,premium,if any,and interest on the Bonds will be made directly to DTC or its nominee,Cede .o, &Co.,by the Bond Trustee,Wells Fargo Bank,National Association,Des Moines,Iowa,so long as DTC is the registered owner of the Bonds. DTC will remit -6� ° such payments to the applicable DTC Participants. The disbursement of such payments will be made by DTC Participants to the beneficial owners of the Bonds. c For further details,see"THE BONDS-Book Entry Only System"herein. M� o r y The Series 2011 Bonds will be issued pursuant to an Indenture of Trust, dated as of June 1, 2003 (the "Original Indenture"), as amended and supplemented by a First Supplemental Indenture of Trust, dated as of October 1, 2011 (the "First Supplemental Indenture" and, together with the Original �?45 ° Indenture,the"Indenture"),among the City of Ames,Iowa(the"City"),Mary Greeley Medical Center(the"Medical Center")and Wells Fargo Bank,National Association,Des Moines,Iowa,as trustee(the"Trustee"). The proceeds of the Series 2011 Bonds,together with certain funds of the Medical Center,will be y C; used 1(i)to finance the construction and equipping of certain improvements to the Medical Center's existing hospital space(the"Project")],(ii)to fund a debt service reserve fund,and(iii)to pay certain costs of issuance of the Series 2011 Bonds. d sThe Series 2011 Bonds will be secured equally and ratably with the Series 2003 Bonds(defined herein)by amounts on deposit in funds held by the „ !, Trustee under the Indenture, including amounts in the Debt Service Reserve Fund. The Series 2003 Bonds are also secured by a financial guaranty insurance policy issued by Ambac Assurance Corporation simultaneously with the delivery of the Series 2003 Bonds(the"Ambac Policy"). However,the Series 2011 y = Bonds are not secured by the Ambac Policy. G S THE SERIES 2011 BONDS AND THE INTEREST AND PREMIUM,IF ANY,PAYABLE THEREON DO NOT REPRESENT OR CONSTITUTE c E`t A GENERAL OBLIGATION OF THE CITY WITHIN THE MEANING OF THE CONSTITUTIONAL PROVISIONS OR STATUTORY LIMITATIONS OF aa "5 = THE STATE OF IOWA,AND DO NOT CONSTITUTE OR GIVE RISE TO A PECUNIARY LIABILITY OF THE CITY OR CHARGES AGAINST ITS o $ GENERAL CREDIT OR TAXING POWERS. THE SERIES 2011 BONDS AND THE INTEREST AND PREMIUM,IF ANY,PAYABLE THEREON ARE o Y NOT OBLIGATIONS OF THE STATE OF IOWA OR ANY POLITICAL SUBDIVISION THEREOF,OTHER THAN THE CITY,AND,WITH RESPECT U C 4 TO THE CITY,ARE SPECIAL LIMITED OBLIGATIONS OF THE CITY PAYABLE SOLELY FROM NET REVENUES OF THE MEDICAL CENTER y T� PLEDGED TO THEIR PAYMENT PURSUANT TO THE INDENTURE AND OTHER AMOUNTS PLEDGED THEREFOR IN ACCORDANCE WITH THE y. INDENTURE,ALL AS FURTHER DESCRIBED HEREIN. y E a ° The Bonds are subject to redemption prior to maturity and to certain other risks as described under the captions"THE SERIES 2011 BONDS"and Y "BONDHOLDERS'RISKS"herein. 4- The Series 2011 Bonds are offered, when, as and if issued and accepted by the Underwriter, subject to the opinion of Dorsey& Whitney LLP, Des Moines,Iowa,Bond Counsel,as to validity and tax exemption. Certain legal matters will be passed upon for the City and the Medical Center by the Ames City cb Attorney,Ames,Iowa and for the Underwriter by Best&Flanagan LLP,Minneapolis, Minnesota. It is expected that the Series 2011 Bonds in definitive form o will be available for delivery through the facilities of DTC to New York,New York,on or about October 2011. r 5 3 b Pipedaffray. y The date of this Official Statement is October 2011. E.c s U N U b c u 3 r 'Preliminary,subject to change. MATURITY SCHEDULE CITY OF AMES,IOWA HOSPITAL REVENUE BONDS (MARY GREELEY MEDICAL CENTER PROJECT) SERIES 2011 Dated: Date of Issuance Due: 1, 20 [TO COME] Preliminary,subject to change. No dealer, broker,salesperson or other person has been authorized by the Medical Center, the City or the Underwriter to give any information or make any representations other than those contained in this Official Statement in connection with the Series 2011 Bonds and, if given or made, such information or representations must not be relied upon as having been authorized by any of the foregoing. This Official Statement does not constitute an offer or solicitation in any jurisdiction in which such offer or solicitation is not authorized or in which the person making such offer or solicitation is not qualified to do so or to any person to whom it is unlawful to make such offer or solicitation. The information contained herein has been obtained from the Corporation and other sources that are deemed reliable. This Official Statement is submitted in connection with the initial public offering of the Series 2011 Bonds. The delivery of this Official Statement at any time does not imply that information herein is correct as of any time subsequent to the date of this Official Statement. TABLE OF CONTENTS INTRODUCTORY STATEMENT......................................................................................................................... 1 THE CITY AND THE MEDICAL CENTER..........................................................................................................3 PLANOF FINANCE.............................................................................................................................................3 ESTIMATED SOURCES AND USES OF FUNDS................................................................................................4 THESERIES 2011 BONDS...................................................................................................................................4 SECURITY FOR THE SERIES 2011 BONDS.......................................................................................................9 ESTIMATED ANNUAL DEBT SERVICE REQUIREMENTS............................................................................10 BONDHOLDERS' RISKS...................................................................................................................................I LITIGATION......................................................................................................................................................37 LEGALMATTERS.............................................................................................................................................37 RATING..............................................................................................................................................................37 UNDERWRITING...............................................................................................................................................38 CONTINUINGDISCLOSURE............................................................................................................................38 TAX EXEMPTION AND RELATED CONSIDERATIONS................................................................................39 INDEPENDENTAUDITORS..............................................................................................................................40 MISCELLANEOUS ............................................................................................................................................40 APPENDIX A INFORMATION CONCERNING MARY GREELEY MEDICAL CENTER..............................A-1 APPENDIX B AUDITED FINANCIAL STATEMENTS...................................................................................B-1 APPENDIX C DEFINITIONS OF CERTAIN TERMS AND SUMMARY OF CERTAIN PROVISIONS OF THE INDENTURE....................................................................................................................................................C-1 APPENDIX D FORM OF BOND COUNSEL OPINION....................................................................................D-1 APPENDIX E FORM OF CONTINUING DISCLOSURE AGREEMENT.........................................................E-1 IN CONNECTION WITH THE OFFERING OF THE BONDS, THE UNDERWRITER MAY OVER ALLOT OR EFFECT TRANSACTIONS THAT STABILIZE OR MAINTAIN THE MARKET PRICE OF SUCH BONDS AT A LEVEL ABOVE THAT WHICH MIGHT OTHERWISE PREVAIL IN THE OPEN MARKET. SUCH STABILIZING,IF COMMENCED,MAY BE DISCONTINUED AT ANY TIME. IN MAKING AN INVESTMENT DECISION INVESTORS MUST RELY ON THEIR OWN EXAMINATION OF THE CORPORATION AND THE TERMS OF THE OFFERING, INCLUDING THE MERITS AND RISKS INVOLVED. THE BONDS HAVE NOT BEEN RECOMMENDED BY ANY FEDERAL OR STATE SECURITIES COMMISSION OR REGULATORY AUTHORITY FURTHERMORE,THE FOREGOING AUTHORITIES HAVE NOT CONFIRMED THE ACCURACY OR DETERMINED THE ADEQUACY OF THIS OFFICIAL STATEMENT. ANY REPRESENTATION TO THE CONTRARY IS A CRIMINAL OFFENSE. The Underwriter has provided the following sentence for inclusion in this Official Statement. The Underwriter has reviewed the information in this Official Statement in accordance with, and as part of its responsibilities to investors under the federal securities laws as applied to the facts and circumstances of this transaction, but the Underwriter does not make any guarantee as to the accuracy or completeness of such information. CAUTIONARY STATEMENTS REGARDING FORWARD- LOOKING STATEMENTS IN THIS OFFICIAL STATEMENT Certain statements included or incorporated by reference in this Official Statement constitute "forward- looking statements" within the meaning of the United State Private Securities Litigation Reform Act of 1995, Section 21E of the United States Securities Exchange Act of 1934, as amended, and Section 27A of the United States Securities Act of 1933, as amended. Such statements are generally identifiable by the terminology used such as "plan", "expect", "estimate", "anticipate", "budget" or other similar words. Such forward looking statements include, among others, certain statements under the caption "Debt Service Coverage" and "Management's Discussion of Recent Financial Performance"in Appendix A to this Official Statement and certain statements under the caption`BONDHOLDERS' RISKS"in the forepart of this Official Statement. THE ACHIEVEMENT OF CERTAIN RESULTS OR OTHER EXPECTATIONS CONTAINED IN SUCH FORWARD-LOOKING STATEMENTS INVOLVE KNOWN AND UNKNOWN RISKS, UNCERTAINTIES AND OTHER FACTORS WHICH MAY CAUSE ACTUAL RESULTS, PERFORMANCE OR ACHIEVEMENTS DESCRIBED TO BE MATERIALLY DIFFERENT FROM ANY FUTURE RESULTS, PERFORMANCE OR ACHIEVEMENTS EXPRESSED OR IMPLIED BY SUCH FORWARD-LOOKING STATEMENTS. NEITHER THE CORPORATION NOR ANY OTHER PARTY PLANS TO ISSUE ANY UPDATES OR REVISIONS TO THOSE FORWARD-LOOKING STATEMENTS IF OR WHEN THEIR EXPECTATIONS, OR EVENTS, CONDITIONS OR CIRCUMSTANCES UPON WHICH SUCH STATEMENTS ARE BASED OCCUR. -ii- OFFICIAL STATEMENT related to City of Ames,Iowa Hospital Revenue Bonds (Mary Greeley Medical Center Project) Series 2011 INTRODUCTORY STATEMENT This Official Statement, including the cover page and the Appendices, is furnished in connection with the offering of $ * in aggregate principal amount of Hospital Revenue Bonds (Mary Greeley Medical Center Project), Series 2011 (the "Series 2011 Bonds"). The Series 2011 Bonds will be issued by the City of Ames, Iowa (the "City"). All descriptions and summaries of documents hereinafter set forth are qualified in their entirety by reference to each document. All capitalized terms used herein and not otherwise defined have the meaning set forth under "DEFINITIONS OF CERTAIN TERMS AND SUMMARY OF CERTAIN PROVISIONS OF THE INDENTURE" in Appendix C hereto. The City owns and operates Mary Greeley Medical Center (the "Medical Center"), an acute care hospital located in the City. Authority for the management, control and government of the Medical Center is vested by statute and local ordinances in the Ames City Hospital Board of Trustees (the "Board") whose five members are elected in regular City elections in staggered terms. See "THE CITY AND THE MEDICAL CENTER"and Appendix A—"INFORMATION CONCERNING MARY GREELEY MEDICAL CENTER" herein for more information concerning the City and the Medical Center. The Series 2011 Bonds will be issued pursuant to Division V of Chapter 384 of the Code of Iowa, as amended (the "Act"), and an Indenture of Trust, dated as of June 1, 2003 (the "Original Indenture"), as amended and supplemented by a First Supplemental Indenture of Trust, dated as of October 1, 2011 (the "First Supplemental Indenture" and, together with the Original Indenture, the "Indenture"), by and among the City, the Medical Center and Wells Fargo Bank, National Association, Des Moines, Iowa, as trustee (the"Trustee"). Pursuant to the Indenture, the Medical Center agrees to make the principal and interest payments due on the Series 2011 Bonds on behalf of the City from the Net Revenues, to establish and revise, as necessary, a schedule of rates and charges sufficient to meet the prompt payment of principal of and interest on the Series 2011 Bonds, to maintain adequate reserves therefor, to pay currently all proper expenses of operation and maintenance of the Medical Center and otherwise to comply with the provisions of the Series 2011 Bonds and the Indenture. The Series 2011 Bonds are not secured by a lien on or security interest in any real or personal property of the city, including the Medical Center. Preliminary,subject to change. The proceeds to be received by the City from the sale of the Series 2011 Bonds, exclusive of accrued interest, will be used, together with other available moneys, [(i) to finance the construction and equipping of certain improvements to the Medical Center's existing hospital space (the "Project")], (ii) to fund a debt service reserve fund, and (iii) to pay certain costs of issuance of the Series 2011 Bonds. A more detailed description of the uses of the proceeds of the Series 2011 Bonds and other available funds of the Medical Center, including the purposes and approximate amounts thereof, is included here under "PLAN OF FINANCE" and "ESTIMATED SOURCES AND USES OF FUNDS". The City previously issued its $29,285,000 Hospital Revenue Refunding Bonds (Mary Greeley Medical Center Project), Series 2003. Proceeds of the Series 2003 Bonds were used (i) to refund the City's then-outstanding Hospital Revenue Bonds (Mary Greeley Medical Center Project) Series 1992 and the City's then-outstanding Hospital Revenue Bonds (Mary Greeley Medical Center Project) Series 1993, (ii)to fund a debt service reserve fund for the benefit of the Series 2003 Bonds and (iii) to pay expenses incurred in connection with the issuance of the Series 2003 Bonds. The Series 2011 Bonds will be secured equally and ratably with the Series 2003 Bonds by amounts on deposit in funds held by the Trustee under the Indenture, including amounts in the Debt Service Reserve Fund. The Series 2003 Bonds are also secured by a financial guaranty insurance policy issued by Ambac Assurance Corporation simultaneously with the delivery of the Series 2003 Bonds (the "Ambac Policy"). However, the Series 2011 Bonds are not secured by the Ambac Policy. The Series 2011 Bonds and the interest and premium, if any, payable thereon, are not obligations of the State of Iowa (the "State"), or of any political subdivision thereof, other than the City, and are special, limited obligations of the City payable solely from the Net Revenues of the Medical Center pledged to their payment pursuant to the Indenture and other amounts pledged therefor in accordance with the Indenture. The issuance of the Series 2011 Bonds does not, directly, indirectly or contingently, obligate the City, the State or any political subdivision thereof to levy any form of taxation for the payment thereof or to make any appropriation for their payment. The Series 2011 Bonds and the interest and premium, if any, payable thereon do not now and shall never constitute or give rise to a pecuniary liability of the City or the State or a charge against the general credit or taxing powers of the City, the State or any political subdivision thereof. The State shall not in any event be liable for the payment of the principal of, premium, if any, or interest on the Series 2011 Bonds or for the performance of any covenants, pledge, obligation or agreement of any kind whatsoever which may be undertaken by the City in connection with the issuance of the Series 2011 Bonds. No breach by the City of any such covenant, pledge, obligation or agreement may impose any pecuniary liability upon the State or any charge upon the general credit of the City or the State or against the taxing power of the City or the State. The Official Statement contains descriptions of, among other matters, the Series 2011 Bonds, the Indenture, the Medical Center and its facilities. All references herein to the Indenture are qualified in their entirety by reference to such document; and references herein to the Series 2011 Bonds are qualified in their entirety by reference to the forms thereof included in the Indenture. Until the issuance and delivery of the Series 2011 Bonds, copies of the Indenture and other documents herein described may be obtained from the Underwriter. Copies of such -2- documents will be available for inspection at the principal corporate trust office of the Trustee after delivery of the Series 2011 Bonds. THE CITY AND THE MEDICAL CENTER The City is a municipal corporation duly organized and existing under the laws of the State. The City is located in Story County, in central Iowa, approximately 30 miles north of Des Moines. Pursuant to the Act, the City is authorized to issue the Series 2011 Bonds for the purposes described herein. The Medical Center is a 220-bed acute care hospital, located in the City. The City owns and operates the Medical Center. For additional information regarding the Medical Center, see Appendix A—"INFORMATION CONCERNING MARY GREELEY MEDICAL CENTER." PLAN OF FINANCE General The proceeds of the Series 2011 Bonds will be used (i) to finance a portion of the costs of the Project, (ii) to fund a debt service reserve fund, and (iii) to pay certain expenses incurred in connection with the issuance of the Series 2011 Bonds. The Project The Project consists of 0 ons s At Closing, the Medical Center J g, will be reimbursed for approximately$ of Project costs. The cost of the Project is approximately $130,000,000, of which approximately $60,000,000 is expected to be paid from proceeds of the Series 2011 Bonds. Ground-breaking of the Project is scheduled for Winter 2012 and the Project is expected to be completed by Summer 2015. For a further description of the Project, see Appendix A — "INFORMATION CONCERNING MARY GREELEY MEDICAL CENTER." (Remainder of this page intentionally left blank.) -3- ESTIMATED SOURCES AND USES OF FUNDS* The following table sets forth the estimated sources and uses of funds in connection with the issuance of the Series 2011 Bonds: Sources of funds: Principal amount of Series 2011 Bonds TOTAL SOURCES Uses of funds: Project costs Deposit to Debt Service Reserve Fund Costs of issuance, including Underwriter's discount TOTAL USES *Preliminary;subject to change. THE SERIES 2011 BONDS The Series 2011 Bonds will be delivered in registered form only, will be transferable and exchangeable as set forth in the Indenture and, when executed and delivered, will be registered in the name of Cede & Co., as nominee of The Depository Trust Company, New York, New York ("DTC"). DTC will act as securities depository for the Series 2011 Bonds. Registered ownership interests in the Series 2011 Bonds may be purchased in book-entry form only, in the denominations hereinafter set forth. See "Book-Entry Only System" herein. So long as the Book-Entry System is in place, payment of the principal of, and premium, if any, and interest on the Series 2011 Bonds will be made as described under "Book-Entry Only System." Pursuant to the Indenture, the Trustee and the City are entitled to treat the registered owner of each (including DTC as to Series 2011 Bonds registered in the name of DTC or its nominee) as the Owner of such Series 2011 Bonds for all purposes. Neither the Trustee nor the City shall have any duty or responsibility to recognize the beneficial ownership rights of a person who has acquired a beneficial interest in Bonds registered in the name of DTC or its nominee. Each Series 2011 Bond will be dated, as originally issued, as of the date of delivery, and will be otherwise dated as provided in the Indenture. The Series 2011 Bonds will bear interest from as of the date of delivery, at the rates and mature in the amounts and on the dates as set forth on the cover page of this Official Statement. Interest on the Bonds is payable semiannually on each June 15 and December 15, commencing June 15, 2012. So long as Cede & Co. is the registered owner of all of the Series 2011 Bonds, principal of and premium, if any, and interest on the Series 2011 Bonds shall be made by the Trustee by wire transfer to DTC in immediately available funds. -4- Registered ownership interests in the Series 2011 Bonds will be $5,000 denominations or integral multiples thereof. Redemption Prior to Maturity Sinking Fund Redemption. The Series 2011 Bonds maturing on June 15, 20 and June 15, 20_, respectively (the "Term Bonds"), are subject to mandatory redemption prior to maturity, by lot, from moneys required to be on deposit in the Bond Sinking Fund, on June 15 in the years 20_ through 20 and 20_ through 20 , respectively, at the principal amounts thereof to be redeemed, and accrued interest to the redemption date,but without premium. Moneys are required to be deposited in the Bond Sinking Fund to provide for mandatory redemption in amounts and at times as follows: $ Term Bonds Due Year Principal June 151 Amount `Maturity $ Term Bonds Due Year Principal June 151 Amount sMaturity Provided that such amounts shall be reduced by the amount of Series 2011 Bonds purchased in lieu of redemption in accordance with the Indenture. Optional Redemption. Series 2011 Bonds maturing on or after June 15, 201_are subject to optional redemption and prepayment, in whole or in part, by the City upon request by the Medical Center, on June 15, 201_ and any date thereafter, in such amounts and maturities as designated by the Medical Center and within any maturity by lot or other method deemed fair by the Trustee, at par, plus accrued interest without a premium. -5- Extraordinary Redemption. The Series 2011 Bonds are subject to redemption in whole or in part, in such maturities as designated by the Medical Center and within a maturity by lot or other method deemed fair by the Trustee, at a redemption price equal to the principal amount thereof, together with interest accrued thereon to the date fixed for redemption, and without premium, in the event that the Medical Center facilities, or any portion thereof, are destroyed by fire or other casualty or condemned or taken by eminent domain, and such damage, destruction or taking is estimated equal or exceed five percent (5%) of the Book Value of the Medical Center facilities. In the event of such damage, destruction, condemnation or taking, the City has the option (at the direction of the Medical Center)to apply the applicable insurance or condemnation proceeds to the prepayment of this obligations thereunder, in whole or in part, which moneys will be deposited in the Redemption Fund and applied to the redemption of Series 2011 Bonds. If Additional Indebtedness is issued on a parity with the Series 2011 Bonds and the Series 2003 Bonds, such insurance or condemnation proceeds will be apportioned among the Series 2011 Bonds, the Series 2003 Bonds and the Additional Indebtedness in proportion to the respective outstanding amounts thereon. Notice of Redemption. Notice of redemption of Series 2011 Bonds will be given by mailing a copy of the redemption notice by first class mail not more than 60 days and not less than 45 days prior to the date fixed for redemption to the registered owner of each Series 2011 Bond to be redeemed, in whole or in part, at the address shown on the registration books of the Trustee; provided that any defect in or failure to mail such notice shall not affect the validity of the proceedings for the redemption of any Series 2011 Bond not affected by such defect or failure. Cessation of Interest. All Series 2011 Bonds or portions thereof called for redemption for which sufficient funds have been deposited with the Trustee will cease to bear interest on the specified redemption date, will no longer be secured by the Indenture and will not be deemed to be Outstanding under the provisions thereof. Partial Redemption. Series 2011 Bonds in denominations larger than $5,000 may be redeemed in part in integral multiples of $5,000. Upon partial redemption, such Series 2011 Bonds shall be surrendered to the Trustee at its principal corporate trust office in exchange for one or more new Series 2011 Bonds, in authorized form, for the unredeemed portion of principal. Book-Entry Only System The Depository Trust Company ("DTC"), New York, NY, will act as securities depository for the Series 2011 Bonds. The Series 2011 Bonds will be issued as fully registered securities registered in the name of Cede & Co. (DTC's partnership nominee) or such other name as may be requested by an authorized representative of DTC. One fully-registered Series 2011 Bond certificate will be issued for each series and each maturity of the Series 2011 Bonds, in the aggregate principal amount of the Series 2011 Bonds, and will be deposited with DTC. DTC, the world's largest securities depository, is a limited-purpose trust company organized under the New York Banking Law, a "banking organization" within the meaning of the New York Banking Law, a member of the Federal Reserve System, a "clearing corporation" within the meaning of the New York Uniform Commercial Code, and a "clearing agency" registered pursuant to the provisions of Section 17A of the Securities Exchange Act of 1934. -6- DTC holds and provides asset servicing for over 3.5 million issues of U.S. and non-U.S. equity issues, corporate and municipal debt issues, and money market instruments (from over 100 countries) that DTC's participants ("Direct Participants") deposit with DTC. DTC also facilitates the post-trade settlement among Direct Participants of sales and other securities transactions in deposited securities, through electronic computerized book-entry transfers and pledges between Direct Participants' accounts. This eliminates the need for physical movement of securities certificates. Direct Participants include both U.S. and non-U.S. securities brokers and dealers, banks, trust companies, clearing corporations, and certain other organizations. DTC is a wholly-owned subsidiary of The Depository Trust & Clearing Corporation ("DTCC"). DTCC is the holding company for DTC, National Securities Clearing Corporation and Fixed Income Clearing Corporation, all of which are registered clearing agencies. DTCC is owned by the users of its regulated subsidiaries. Access to the DTC system is also available to others such as both U.S. and non-U.S. securities brokers and dealers, banks, trust companies, and clearing corporations that clear through or maintain a custodial relationship with a Direct Participant, either directly or indirectly ("Indirect Participants"). DTC has Standard & Poor's highest rating: AAA. The DTC Rules applicable to its Participants are on file with the Securities and Exchange Commission. More information about DTC can be found at www.dtcc.com and www.dtc.org. Purchases of the Series 2011 Bonds under the DTC system must be made by or through Direct Participants, which will receive a credit for the Series 2011 Bonds on DTC's records. The ownership interest of each actual purchaser of each Series 2011 Bond (`Beneficial Owner") is in turn to be recorded on the Direct and Indirect Participants' records. Beneficial Owners will not receive written confirmation from DTC of their purchase. Beneficial Owners are, however, expected to receive written confirmations providing details of the transaction, as well as periodic statements of their holdings, from the Direct or Indirect Participant through which the Beneficial Owner entered into the transaction. Transfers of ownership interests in the Series 2011 Bonds are to be accomplished by entries made on the books of Direct and Indirect Participants acting on behalf of Beneficial Owners. Beneficial Owners will not receive certificates representing their ownership interest in Series 2011 Bonds, except in the event that use of the book-entry system for the Series 2011 Bonds is discontinued. To facilitate subsequent transfers, all Series 2011 Bonds deposited by Direct Participants with DTC are registered in the name of DTC's partnership nominee, Cede & Co., or such other name as may be requested by an authorized representative of DTC. The deposit of Series 2011 Bonds with DTC and their registration in the name of Cede & Co. or such other DTC nominee effect no change in beneficial ownership. DTC has no knowledge of the actual Beneficial Owners of the Series 2011 Bonds; DTC's records reflect only the identity of the Direct Participants to whose accounts such Series 2011 Bonds are credited, which may or may not be the Beneficial Owners. The Direct and Indirect Participants will remain responsible for keeping account of their holdings on behalf of their customers. Conveyance of notices and other communications by DTC to Direct Participants, by Direct Participants to Indirect Participants, and by Direct Participants and Indirect Participants to Beneficial Owners will be governed by arrangements among them, subject to any statutory or regulatory requirements as may be in effect from time to time. Beneficial Owners of Series 2011 Bonds may wish to take certain steps to augment the transmission to them of notices of significant events with respect to the Series 2011 Bonds, such as redemptions, tenders, defaults, and proposed amendments to the Series 2011 Bond documents. For example, Beneficial Owners -7- of the Series 2011 Bonds may wish to ascertain that the nominee holding the Series 2011 Bond for their benefit has agreed to obtain and transmit notices to Beneficial Owners. In the alternative, Beneficial Owners may wish to provide their names and addresses to the registrar and request that copies of the notices be provided directly to them. Redemption notices shall be sent to DTC. If less than all of the Series 2011 Bonds within an issue are being redeemed, DTC's practice is to determine by lot the amount of the interest of each Direct Participant in such issue to be redeemed. Neither DTC nor Cede & Co. (nor any other DTC nominee) will consent or vote with respect to Series 2011 Bonds unless authorized by a Direct Participant in accordance with DTC's MMI Procedures. Under its usual procedures, DTC mails an Omnibus Proxy to the Issuer as soon as possible after the record date. The Omnibus Proxy assigns Cede & Co.'s consenting or voting rights to those Direct Participants to whose accounts the Series 2011 Bonds are credited on the record date (identified in a listing attached to the Omnibus Proxy). Principal and interest payments on the Series 2011 Bonds will be made to Cede & Co., or such other nominee as may be requested by an authorized representative of DTC. DTC's practice is to credit Direct Participants' accounts upon DTC's receipt of funds and corresponding detail information from the City or the Trustee, on the payable date in accordance with their respective holdings shown on DTC's records. Payments by Participants to Beneficial Owners will be governed by standing instructions and customary practices, as is the case with securities held for the accounts of customers in bearer form or registered in "street name," and will be the responsibility of such Participant and not of DTC, the Trustee, or the City, subject to any statutory or regulatory requirements as may be in effect from time to time. Payment of principal and interest to DTC (or such other nominee as may be requested by an authorized representative of DTC) is the responsibility of the City or the Trustee, disbursement of such payments to Direct Participants shall be the responsibility of DTC, and disbursement of such payments to the Beneficial Owners shall be the responsibility of Direct and Indirect Participants. A Beneficial Owner will give notice to elect to have its Series 2011 Bond purchased or tendered, through its Participant, to the Trustee, and will effect delivery of such Series 2011 Bond by causing the Direct Participant to transfer the Participant's interest in the Series 2011 Bonds, on DTC's records, to the Trustee. The requirement of physical delivery of Series 2011 Bonds in connection with an optional tender or a mandatory purchase will be deemed satisfied when the ownership rights in the Series 2011 Bond are transferred by Direct Participants on DTC's records and followed by a book-entry credit of tendered Series 2011 Bonds to the Trustee's DTC account. DTC may discontinue providing its services as securities depository with respect to the Series 2011 Bonds at any time by giving reasonable notice to the Medical Center or the Trustee. Under such circumstances, in the event that a successor securities depository is not obtained, Bond certificates are required to be printed and delivered. The City may direct the DTC Participants to request or discontinue use of the system of book-entry transfers through DTC (or a successor securities depository). In that event, Bond certificates will be printed and delivered. -8- The information above discussing the book-entry system have been furnished by DTC. No representation is made by the City or the Underwriter as to the completeness or accuracy of such information or as to the absence of material adverse changes in such information subsequent to the date hereof. No attempt has been made by the City or the Underwriter to determine whether DTC is or will be financially or otherwise capable of fulfilling its obligations. The City has no responsibility or obligation to DTC Participants, Indirect Participants or Beneficial Owners, or the persons for which they act as nominees with respect to the Series 2011 Bonds, or for any principal of,premium, if any, or interest payment thereon. SECURITY FOR THE SERIES 2011 BONDS General The principal of the Series 2011 Bonds, redemption premium, if any, and interest thereon are limited obligations of the City and are payable solely from the Net Revenues of the Medical Center, except to the extent payable from proceeds of the Series 2011 Bonds and other amounts held in any fund or account (other than the Rebate Fund) established by the Indenture, including the Debt Service Reserve Fund. The Series 2011 Bonds are not secured by a lien on or security interest in any real or personal property of the city, including the Medical Center. Indenture Pledge of Net Revenues. Pursuant to the Indenture, the City and the Medical Center assign and grant to the Trustee for the benefit and security of the Bondholders a security interest in the Net Revenues of the Medical Center and all amounts held in any fund or account established by the Indenture, including investment income thereon. Debt Service Reserve Fund. A Debt Service Reserve Fund has been established under the Indenture and held by the Trustee. At the time of issuance of the Series 2011 Bonds, the amount in the Debt Service Reserve Fund will be equal to S (the "Debt Service Reserve Fund Requirement"). If at any time the amount on deposit in the Debt Service Reserve Fund is less than the Debt Service Reserve Fund Requirement either because of a transfer therefrom or a valuation thereof, the Indenture requires the Medical Center to restore the Debt Service Reserve Fund to an amount equal to the Debt Service Reserve Fund Requirement from the Net Revenues in not more than 12 substantially equal monthly payments commencing with the first day of the first month following the month in which the deficiency occurs. Investment Securities in the Debt Service Reserve Fund shall be valued by the Trustee at their fair market value determined as of each June 15, beginning June 15, 2012. The Medical Center agrees to make payments due on the Series 2011 Bonds on behalf of the City from the Net Revenues, to establish and revise, as necessary, a schedule of charges sufficient to meet the prompt payment of all expenses and charges payable therefrom, including the payment of principal of and interest on the Series 2011 Bonds, to maintain adequate reserves therefor, to pay currently all proper expenses of operation and maintenance of the Medical Center facilities and otherwise to comply with the provisions of the Series 2011 Bonds and the Indenture. -9- Additional Indebtedness The Indenture provides that the City and the Medical Center may not incur Additional Indebtedness payable from the Net Revenues of the Medical Center except for the purposes and upon the conditions set forth therein. See APPENDIX C — "SUMMARY OF CERTAIN PROVISIONS OF THE INDENTURE — Restrictions as to Incurrence of Additional Indebtedness." ESTIMATED ANNUAL DEBT SERVICE REQUIREMENTS* The following table sets forth, for each calendar year, scheduled payments of principal of the Series 2003 Bonds and the Series 2011 Bonds at maturity or by mandatory redemption through the sinking fund, and the payment of interest on the Series 2003 Bonds and the Series 2011 Bonds. Remainder of this page intentionally left blank. � Pg Y ) -10- Calendar Year Series 2011 Bonds Series 2003 Bonds Ending Total Debt December 31. Principal Interest Principal Interest Service 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 BONDHOLDERS' RISKS General Except as noted herein, the Series 2011 Bonds are payable solely from the Net Revenues of the Medical Center and from additional security provided by the Indenture. No -11- representation or assurance can be made that revenues will be realized by the Medical Center in the amounts necessary to make payments sufficient to pay maturing principal of, premium, if any, and interest on the Series 2011 Bonds. The ability of the Medical Center to generate sufficient revenue for such payments is subject to, among other things, the capabilities of the management of the Medical Center, the confidence of physicians in management, the availability of physicians and trained support staff, changes in the population or the economic condition of the service areas of the Medical Center, the level of and restrictions on federal funding of Medicare and federal and state funding of Medicaid, imposition of government wage and price controls or other limits on expense or revenue, the implementation of federal or state health reform measures, the demand for the services of the Medical Center, competition, rates, government regulations and licensing requirements, inflation and future economic and other conditions that are unpredictable and may not be quantifiable or determinable at this time. Some of the identifiable risks that should be considered when making an investment decision regarding the Series 2011 Bonds are detailed below. Such listing is not, and is not intended to be, exhaustive. Matters Relating to Security for the Series 2011 Bonds; Enforceability of Remedies The Medical Center facilities are not pledged as security for the Series 2011 Bonds. The Act provides that the sole remedy for a breach or default with respect to the Series 2011 Bonds is a proceeding in law or in equity to enforce performance of the City's duties under the Act and the Indenture or to obtain the appointment of a receiver to take possession of the Medical Center and to perform such duties. The remedies available to the Trustee or the holders of the Series 2011 Bonds upon an event of default under the Indenture are in many respects dependent upon judicial actions which are often subject to discretion and delay. Under existing constitution and statutory law and judicial decisions, including, specifically the Federal Bankruptcy Code, the remedies provided in the Indenture and the Act may not be readily available or may be limited. The various legal opinions to be delivered concurrently with the delivery of the Series 2011 Bonds will be qualified as to the enforceability of the various legal instruments by limitations imposed by general principles of equity and by bankruptcy, reorganization, insolvency or other similar laws affecting the rights of creditors generally. If the City were to file a petition for relief under the Federal Bankruptcy Code, the filing would operate as an automatic stay of the commencement or continuation of any judicial or other proceeding against the City and its property. If the bankruptcy court so ordered, the City's property, including the Medical Center's accounts receivable and proceeds thereof, could be used for the benefit of the City despite the claims of its creditors. Global and National Economic Crisis The recent economic crisis has had, and may continue to have, serious negative consequences for the global and national economies. To date, the crisis has caused a restriction on the availability of credit, extreme volatility in interest rates and the credit and securities markets generally, failures and bankruptcies of businesses and financial institutions and reduced -12- business activity, which in turn has reduced personal, corporate and governmental revenues. These consequences may reduce the Medical Center's revenues from operations and investments, affect the ability of the Medical Center to make payments on the Series 2003 Bonds and the Series 2011 Bonds and reduce its ability to obtain liquidity and credit facilities or receive funds thereunder. There have been significant global governmental actions aimed at counteracting the economic crisis. There can be no assurance that these actions will be effective in correcting the global or national economies. Health Care Industry Factors Affecting the Medical Center A significant portion of the revenues of the Medical Center is derived from the Medicare and Medicaid programs. See "Sources of Medical Center Revenue" in APPENDIX A hereto. The Medical Center is adversely affected to the extent that reimbursement from these sources for services rendered is less than actual expenses incurred. Federal Health Care Reform. The Patient Protection and Affordable Care Act of 2010 and The Health Care and Education Reconciliation Act of 2010 (collectively referred to as the "Health Reform Act') were signed into law by President Obama in March of 2010. The Health Reform Act reflects the federal government's attempt to reform the systems through which health care services are delivered and financed in the United States. The Health Reform Act is expected to have a significant impact on the entire health care industry. Numerous provisions of the Health Reform Act have become effective since enactment of the law, including provisions related to health insurance underwriting and requirements related to denials of insurance coverage and claims, which took effect September 23, 2010. A significant portion of the reforms required by the Health Reform Act will be phased in during a period of time ranging from one to ten years. Because many of the reforms set out in the Health Reform Act are addressed only in conceptual or policy terms, new guidelines and regulations related to the Health Reform Act will likely need to be enacted. Among other things, the Health Reform Act makes changes to the ways that individuals pay for their own and their families' health care and how employers procure health insurance for their employees. In addition, the Health Reform Act requires health insurers to change certain underwriting practices and benefit structures to extend coverage to individuals who previously could have been ineligible for private health insurance. As a result, there is expected to be a significant increase in the number of individuals eligible for, and covered by, health insurance. Broadly stated, the goals of the Health Reform Act are to reduce the number of uninsured individuals, to increase the availability and affordability of insurance coverage, to enhance the focus on quality of care and to contain health spending growth. The legislation intends to accomplish these objective through various provisions, including (i) creating active markets (referred to as "exchanges") in which individuals and small employers can purchase health insurance for themselves and their families or their employees and dependents, (ii) providing subsidies for premium costs to individuals and families based upon their income relative to federal poverty levels, (iii) mandating that individuals obtain and certain employers provide a minimum level of health insurance and providing for penalties and imposing taxes on those individuals and employers that do not obtain coverage, (iv) establishing insurance reforms that -13- expand coverage generally through such provisions as prohibitions on denials of coverage for pre-existing conditions and elimination of lifetime or annual cost caps, (v) expanding eligibility for existing public programs, including Medicaid, for individuals and families, (vi) increasing cost containment provisions in Medicare and Medicaid, and (vii) creating and funding research programs related to quality and cost of care. It is expected that there will be an increased demand for health care services as a result of the increase in individuals eligible for health insurance coverage. The following are examples of provisions of the Health Reform Act may affect the operations and financial condition of the Medical Center: • The Health Care Act requires an expansion of Medicaid programs to a broader population, with incomes up to 133% of federal poverty levels. • Commencing in federal fiscal year 2011 (which began October 1, 2010), federal payments to states for Medicaid services related to certain health care-acquired conditions will be prohibited. • With varying effective dates, the Health Reform Act mandates a reduction of waste, fraud and abuse in public programs by allowing provider enrollment screening, enhanced oversight periods for new providers and suppliers, and enrollment moratoria in areas identified as being at elevated risk of fraud in all public programs and by requiring Medicare and Medicaid program providers and suppliers to establish compliance programs. • The legislation provides for increased penalties for fraud and abuse violations and for increased funding for antifraud activities. • The Health Reform Act also provides for the implementation of various demonstration programs and pilot projects to test, evaluate, encourage and expand new payment structures and methodologies to reduce health care expenditures while maintaining or improving quality of care, including bundled payments under Medicare and Medicaid, and comparative effectiveness research programs that compare the clinical effectiveness of medical treatments and develop recommendations concerning practice guidelines and coverage determinations. At this time, given the number of variables involved in implementation of the Health Reform Act, including the likely adoption of significant additional policies, rules and regulations, the Medical Center's management is unable to predict the effect that the Health Reform Act will have on the Medical Center's operations or financial performance. American Recovery and Reinvestment Act of 2009. The Recovery Act was signed into law in February, 2009. The Recovery Act includes certain provisions which are intended to provide financial relief to healthcare providers. Title XIII of the Recovery Act, otherwise known as the Health Information Technology for Economic and Clinical Health Act (the "HITECH Act"), provides for an investment of almost $20 billion in public monies for the development of a nationwide health information technology ("HIT") infrastructure. The HIT infrastructure is -14- intended to improve health care quality, reduce health care costs and facilitate access to necessary information. Among other things, the HITECH Act provides financial incentives, through the Medicaid and Medicare programs, loans and grants to encourage practitioners and providers to adopt and use qualified electronic health records. Eventually, Medicare payments are reduced for providers and practitioners who do not use electronic health records. The HITECH Act has also significantly increased fines, the scope of coverage, and the scope of remedies for violations of the Health Insurance Portability and Accountability Act of 1996 ("HIPAA") and breaches of the security of electronic health records. Criminal penalties will be enforced against persons who obtain or disclose personal health information without authorization. In addition, a State's Attorney General can bring civil actions against a person on behalf of residents adversely affected by violations of either HIPAA or the HITECH Act. The Attorney General can either seek to enjoin future violations or obtain money damages on behalf of the residents harmed. The U.S. Department of Health and Human Services ("DHHS") is also beginning to perform periodic audits of healthcare providers to ensure that required policies under the HITECH Act are in place. Finally, individuals harmed by violations will be able to recover a percentage of monetary penalties or a monetary settlement based upon methods established by DHHS for this private recovery in the next three years. The effect of the Recovery Act, including the HITECH Act, on the Medical Center cannot be determined at this time. Reliance on Medicaid The Medical Center relies to a high degree on payment from the federal and state Medicaid program. Future changes in the underlying law and regulations, as well as in payment policy and timing create uncertainty and could have a material adverse impact on hospitals' payment stream from Medicaid. With healthcare and hospital spending reported to be increasing faster than the rate of general inflation, Congress and the Centers for Medicare and Medicaid Services ("CMS") have taken and may take action in the future to decrease or restrain Medicaid outlays for hospitals. Medicaid often pays the Medical Center at levels that may be below the actual cost of the care provided. As Medicaid is partially funded by state government, the financial condition of the State is relevant to the Medical Center's financial well-being. See"Medicare and Medicaid Programs and Other Payors." Managed Care Exposure. Managed care plans have penetrated most hospital markets. Managed care companies have significant influence over hospital rates, utilization and competition. Rate pressure imposed by managed care payors may have a future material adverse impact on hospitals, particularly if major purchasers put increasing pressure on payors to restrain rate increases. Business failures by managed care companies also could have a material adverse impact on contracted hospitals in the form of payment shortfalls or delay, and/or continuing obligations to care for managed care patients without receiving payment. See "Medicare and Medicaid Programs and Other Payors." Government "Fraud" Enforcement Fraud in government funded healthcare programs is a significant concern of DHHS, CMS and many states, and is one of the federal government's prime law enforcement priorities. The federal and state governments impose a wide variety of extraordinarily complex and technical requirements intended to prevent over-utilization based on economic inducements, misallocation of expenses, overcharging and other forms of"fraud" in the Medicare and Medicaid programs, as well as other state and federally-funded healthcare programs. This body of regulation impacts a broad spectrum of hospital commercial activity, including billing, accounting, recordkeeping, medical staff oversight, physician contracting and -15- recruiting, cost allocation, clinical trials, discounts and other functions and transactions. See "Medicare and Medicaid Programs and Other Payors—Regulatory Environment." Nursing and Healthcare Professionals Shortage. Currently there is a shortage of qualified, available nurses. Various studies have predicted that this nursing shortage will become more acute over time and grow to significant proportions. Likewise, some other types of healthcare professionals, including family practice and other primary care physicians, are in short supply. Hospital operations, patient and physician satisfaction, financial condition and future growth could be negatively affected by nursing and other professional shortages, resulting in future material adverse impact to hospitals. Labor Costs and Disruption. Hospitals are labor intensive. Labor costs, including salary, benefits and other liabilities associated with the workforce, have a significant impact on hospital operations and financial condition. Hospital employees are increasingly organized in collective bargaining units, and may be involved in work actions of various kinds, including work stoppages and strikes. Overall costs of the hospital workforce are high and turnover is high. Pressure to recruit, train and retain qualified employees is expected to increase. These factors may materially increase hospital costs of operation. Future workforce disruption may negatively impact hospital revenues and reputation. Physician Medical Staff. The primary relationship between a hospital and physicians who practice in it is through the hospital's organized medical staff. Medical staff bylaws, rules and policies establish the criteria and procedures by which a physician may have his or her privileges or membership curtailed, denied or revoked. Physicians who are denied medical staff membership or certain clinical privileges or who have such membership or privileges curtailed or revoked often file legal actions against hospitals and medical staffs. Such actions may include a wide variety of claims, some of which could result in substantial uninsured damages to a hospital. In addition, failure of the hospital governing body to adequately oversee the conduct of its medical staff may result in future hospital liability to third parties. Physician Contracting. The Medical Center may contract with individual physicians, physician groups or physician organizations (such as independent physician associations and physician-hospital organizations) to arrange for the provision of physician and ancillary services. Because physician organizations are separate legal entities with their own goals, obligations to shareholders, financial status, and personnel, there are risks involved in contracting with the physician organizations. The success of the Medical Center will be partially dependent upon its ability to attract physicians to join the physician organizations and to attract physician organizations to participate in its networks, and upon the ability of the physicians, including the employed physicians, to perform their obligations and deliver high-quality patient care in a cost-effective manner. There can be no assurance that the Medical Center will be able to attract and retain an adequate number of physicians, or that such physicians will deliver high-quality health care services. Without impaneling a sufficient number and type of providers, the Medical Center could fail to be competitive or could fail to obtain and maintain attractive payor contracts. Such occurrences could have a material adverse effect on the business or operations of the Medical Center. -16- Similarly, any termination or alteration of existing agreements between the Medical Center and individual physicians and physician groups who render services to the patients of the Medical Center, could have a material adverse effect on the business or operations of the Medical Center. Technical and Clinical Developments. New clinical techniques and technology, as well as new pharmaceutical and genetic developments and products, may alter the course of medical diagnosis and treatment in ways that are currently unanticipated, and that may dramatically change medical and hospital care. These could result in higher hospital costs, reductions in patient populations and/or new sources of competition for hospitals. Costs and Restrictions from Governmental Reputation Nearly every aspect of hospital operations is regulated, in some cases by multiple agencies of government. The level and complexity of regulation appears to be increasing, bringing with it operational limitations, enforcement and liability risks, and significant and sometimes unanticipated cost impacts. See "Medicare and Medicaid Programs and Other Payors—Regulatory Environment." General Economic Conditions; Bad Debt and Indigent Care. Hospitals are economically influenced by the environment in which they are located. To the extent that state or county governments are unable to provide a safety net of medical services, pressure is applied to local hospitals to increase free care. Economic downturns and lower funding of the Medicaid program may increase the number of patients treated by hospitals who are uninsured or otherwise unable to pay for some or all of their care. These conditions may give rise to increased bad debt and higher indigent care utilization. At the same time, nonoperating revenue from investments may be reduced or eliminated. These factors may have a materially adverse effect on hospitals. Pension and Benefit Funds. As large employers, hospitals may incur significant expenses to fund pension and benefit plans for employees and former employees, and to fund required workers' compensation benefits. Funding obligations in some cases may be erratic or unanticipated and may require significant commitments of available cash needed for other purposes. Medical Liability Litigation and Insurance. Medical liability litigation is subject to public policy determinations and legal and procedural rules that may be altered from time to time, with the result that the frequency and cost of such litigation, and resultant liabilities, may increase in the future. Hospitals may be affected by negative financial and liability impacts on physicians. Costs of insurance, including self-insurance, may increase dramatically. Joint Ventures with Other Health Care Organizations. Currently, the Medical Center is g , Y involved in one joint venture with another entity and the Medical Center may, from time to time in the future, explore other joint venture opportunities. See Appendix A — "AFFILIATIONS, JOINT VENTURES AND OTHER RELATIONSHIPS" The OIG has expressed its concern in various advisory bulletins that many types of joint venture arrangements involving hospitals may implicate the Anti-Kickback Law, since the parties to joint ventures are typically in a position to refer patients of federal health care programs. In its 1989 Special Fraud Alert, the OIG raised concern about certain physician joint ventures where the intent is not to raise investment capital to start a business but rather to "lock -17- up a stream of referrals from the physician investors and compensate these investors indirectly for these referrals." The OIG listed various features of suspect joint ventures, but noted that its list was not exhaustive. These features include: (i) whether investors are chosen because they are in a position to make referrals; (ii) whether physicians with more potential referrals are given larger investment interests; (iii) whether referrals are tracked and referral sources shared with investing physicians; (iv) whether the overall structure is a "shell" (i.e., one of the parties is an ongoing entity already engaged in a particular line of business); and (v) whether investors are required to invest a disproportionately small amount or are paid extraordinary returns in comparison with their risk. In April 2006, the OIG issued a Special Advisory Bulletin indicating that "contractual joint ventures" (where a provider expands into a new line of business by contracting with an entity that already provides the items or services) may violate the Anti-Kickback Law and expressing skepticism that existing statutory or regulatory safe-harbors would protect suspect contractual joint ventures. In addition, under the federal tax laws governing Section 501(c)(3) organizations, a tax- exempt hospital's participation in a joint venture with for-profit entities must further the hospital's exempt purposes and the joint venture arrangement must permit the hospital to act exclusively in the furtherance of its exempt purposes, with only incidental benefit to any for- profit partners. If the joint venture does not satisfy these criteria, the hospital's tax-exemption may be revoked, the hospital's income from the joint venture may be subject to tax, or the parties may be subject to some other sanction. Any evaluation of compliance with the Anti-Kickback Law or tax laws governing Section 501(c)(3) organizations depends on the totality of the facts and circumstances. While management of the Medical Center believes that the joint venture arrangements to which the Medical Center is a party are in material compliance with the Anti-Kickback Law, Stark Law and OIG pronouncements, and the tax laws governing Section 501(c)(3) organizations, any determination that the Medical Center is not in compliance with such laws and regulations could have a material adverse effect on the future financial condition of the Medical Center. The ownership and operation of certain of these joint ventures may not meet safe harbors under the Anti-Kickback Law. Management of the Medical Center intend to proceed with such transactions related to the joint ventures on the assumption, after consultation with its legal counsel, that each of the transactions related to the joint ventures is in compliance with the Stark Law and is otherwise generally in compliance with the Anti-Kickback Law. However, there can be no assurance that regulatory authorities will not take a contrary position or that such transactions will not be found to have violated the Stark Law and/or the Anti-Kickback Law. Any such determination could have a material adverse effect on the financial condition of the Medical Center. Future Affiliations, Merger, Acquisition and Divestiture. In addition to relationships with other hospitals and physicians, the Medical Center may consider investments, ventures, affiliations, development and acquisition of other healthcare-related entities. These may include home health care, long-term care entities or operations, infusion providers, pharmaceutical providers, and other health care enterprises which support the overall operations of the Medical Center. In addition, the Medical Center may pursue such transactions with health insurers, -18- HMOs, preferred provider organizations, third-party administrators and other health insurance- related businesses. Because of the integration occurring throughout the health care field, management of the Medical Center will consider such arrangements if there is a perceived strategic or operational benefit for the Medical Center. Any such initiative may involve significant capital commitments and/or capital or operating risk (including, potentially, insurance risk) in a business in which the Medical Center may have less expertise than in hospital operations. There can be no assurance that these projects, if pursued, will not lead to material adverse consequences to the Medical Center. Competition Among Healthcare Providers. Increased competition from a wide variety of sources, including specialty hospitals, other hospitals and healthcare systems, inpatient and outpatient healthcare facilities, clinics, physicians and others, may adversely affect the utilization and/or revenues of hospitals. Existing and potential competitors may not be subject to various restrictions applicable to hospitals, and competition, in the future, may arise from new sources not currently anticipated or prevalent. See APPENDIX A under the caption "SERVICE AREA AND COMPETITION" for a discussion of the facilities which the Medical Center considers to be its major competition. Antitrust. Antitrust liability may arise in a wide variety of circumstances including medical staff privilege disputes, third party contracting, physician relations, and joint venture, merger, affiliation and acquisition activities. In some respects, the application of the federal and state antitrust laws to health care is still evolving. Health care providers may be subject to an investigation by a governmental agency charged with the enforcement of the antitrust laws, or may be subject to administrative or judicial action by a federal or state agency or a private party. Violation of the antitrust laws could subject the health care provider to criminal and civil enforcement by federal and state agencies, as well as by private litigants. Medicare and Medicaid Programs and Other Payors Medicare and Medicaid The Medical Center is subject to governmental regulation under the federal Medicare program and the joint federal and state Medicaid program. Health care providers, including the Medical Center, have been and will continue to be affected by changes that have occurred during the last several years in the administration of the Medicare and Medicaid programs. In addition, in recent years, an increasing number of federal and state legislative initiatives have been introduced that would, if adopted, affect major reforms in the federal and state health care systems. Management of the Medical Center cannot predict whether any such proposals will be adopted and, if adopted, what effect such proposals would have on the Medical Center's business and operations. The following is a summary of Medicare and Medicaid. Medicare. The Medical Center receives a significant portion of net patient service revenue from reimbursement under Medicare (approximately , the fiscal year ended June 30, 2011, see "SOURCES OF HOSPITAL REVENUE" in Appendix A). In 1966, the federal Social Security Act established the Medicare program to provide health care services to the elderly and the disabled. Medicare Part A provides health insurance benefits for covered hospital and related health care services to persons aged 65 years and older who are entitled to monthly Social Security retirement benefits, as well as to certain disabled persons. Medicare Part B provides -19- supplemental medical benefits covering primarily outpatient and physician care costs for covered persons. Beneficiary participation in Medicare Part B is on a voluntary basis. Legislative action and the promulgation of related regulations have resulted in significant changes in the Medicare program. Formerly, Medicare provided reimbursement to hospitals for the reasonable direct and indirect costs of inpatient hospital services furnished to beneficiaries. Pursuant to the Social Security Amendments of 1983 and subsequent Budget Reconciliation Act modifications, Congress adopted a prospective payment system to cover the routine and ancillary operating costs of most Medicare inpatient hospital services. Under Medicare's prospective payment system ("PPS"), hospital discharges are classified into approximately 500 categories of specific diagnosis-related groups of services ("DRGs"), which classify illnesses according to the estimated intensity of hospital resources necessary to furnish care for each principal diagnosis. Hospitals generally receive a fixed amount based upon the assigned DRG, on a per discharge basis for each Medicare patient. Such determination is made regardless of how long the patient remains in the hospital or the volume of ancillary services ordered by the attending physician. Additional payments may be made to hospitals for cases involving unusually high costs in comparison with other discharges in the same DRG. Under PPS, hospitals may retain payments in excess of costs but must absorb costs in excess of payments. CMS, which administers the Medicare Program, annually updates and recalibrates DRG rates. Such updating and recalibrating have been affected by several federal enactments. The Omnibus Budget Reconciliation Act of 1987 ("OBRA-87") provided for an increase in prospective payment system update factors based upon the location of the hospital, i.e., whether the hospital is located in a "rural," "large urban" or "other urban" area. The Medical Center is considered to be located in an "other urban" area for purposes of these rules. As a result of the Omnibus Budget Reconciliation Act of 1989 ("OBRA-89"), DRG recalibrations must be undertaken on a "budget-neutral basis." (All references to fiscal years in this discussion are to the fiscal years of the federal government unless otherwise noted.) "Budget-neutrality" requires, with certain exceptions, that the estimated amount of aggregate adjusted payments made in a given year be not greater or less than the payment amounts that would have been payable for the same services or costs for a historical fiscal year, which has typically been fiscal year 1984 under the Social Security Act as in effect on April 19, 1983, but which varies depending on the services or costs in question and the date that the budget-neutrality becomes applicable thereto. Increases in DRG payment rates are generally tied to the hospital "market basket" as a measure of the inflation experienced by hospitals in purchasing the goods and services they need to provide inpatient services. The standardized amounts are updated annually effective with discharges occurring on or after October 1 of each year. Other factors in PPS payments, including DRG classifications, the area wage index, outlier payment thresholds, and the hospital's geographic classification are also revised at the start of each fiscal year. In OBRA-90, Congress revised the Gramm-Rudman budget and sequestration process and established a "pay-as-you-go" system for entitlement programs, including Medicare. Legislation increasing entitlements, reducing revenues, or both, must be deficit-neutral—i.e., it must pay for itself either by a reduction in entitlement spending elsewhere in the Medicare budget or by additional revenues. Legislation violating the pay-as-you-go principle would -20- trigger a sequestration of entitlement program funds in the same amount that such legislation added to the deficit. Medicare program funds would be included among those sequestered, but the sequestration of Medicare funds is limited to a maximum of 4%. Until September 1991, capital-related payments for inpatient hospital services (which include depreciation, interest, taxes, property-related insurance and similar costs) had been reimbursed only on a cost basis under Medicare. By fiscal year 2001, all hospitals participating in the Medicare PPS have been reimbursed for capital costs at a standard federal rate of average capital costs per discharge, subject to certain adjustments to reflect, among other things, geographic variations in construction costs. Congress enacted the Omnibus Budget Reconciliation Act of 1993 on August 10, 1993 ("OBRA-93"). The annual update factor for hospitals under OBRA-93 is equal to the percentage increase in the hospital market basket. These annual update factors are subject to future legislative changes. The Balanced Budget Act of 1997 ("BBA") established a prospective payment system for several services previously reimbursed on a cost basis (home health, inpatient rehabilitation, skilled nursing) and institutes the following additional changes in reimbursement: the hospital PPS update was skipped for fiscal year 1998, freezing the current rate through September 30, 1998. The PPS update was market basket minus 1.9% in 1999, market basket minus 1.8% in 2000 and market basket minus 1.1% in 2001 and 2002. The BBA reduces hospital payments for inpatient capital 2.1% for fiscal years 1998-2002. PPS exempt hospitals (psychiatric and rehabilitation) received a zero update for 1998, then a variable update in fiscal years 1999-2002. Discharges for 10 DRGS to a skilled nursing facility, a PPS-exempt facility or to home health care will be treated as hospital transfers whereby the transferring facility gets a per diem rate up to a maximum payment of the full DRG. The Act directed that hospital outpatient services (and certain Medicare Part B services furnished to hospital inpatients who no longer have Medicare Part A coverage) be reimbursed on a prospective payment basis. Implementation of the outpatient prospective payment system ("OPPS") occurred for claims with dates of service on or after August 1, 2000. Payment for services under OPPS is calculated based on grouping outpatient services into 451 ambulatory payment classification ("APC") groups. Services within an APC are similar clinically and require similar hospital resources. A coinsurance amount will be calculated for each APC based on 20% of the national mediation charge for services within the APC. Payments will be adjusted to reflect wage differences in different regions. Originally, hospitals were facing an average cut of almost 11% from the OPPS system, however, Congress has ordered some transitional payments as a temporary relief from that cut. OPPS has required hospitals to implement significant changes in their billing and coding systems, at substantial cost to the hospitals. The Act also mandated prospective payment for home health care as of October 1, 2000. Under the prospective payment system for home health, a home health agency must bill (under a consolidated bill) for all home health services which includes nursing and therapy services, routine and non-routine medical supplies, home health aide and medical social services, except durable medical equipment ("DME"). DME was excluded from the BBA established consolidated billing requirement. The law requires that all home health services paid on a cost basis be included in the prospective payment rate. Therefore, the PPS rate will include all -21- nursing and therapy services, routine and non-routine medical supplies, and home health aide and medical social services. The impact of consolidated billing is that the costs of providing all of these services are rolled into one payment to the home health agency, which payment may or may not adequately represent the actual cost of providing such services and could have adverse effects on Medical Center revenues. Under PPS, home health agency payments are based on a 60-day episode, and are case-mix and wage adjusted. The case mix is based on data elements from a patient's medical assessment that incorporates the Outcomes and Assessment Information Set ("OASIS"), and the projected number of therapy hours. Upon receiving a referral, the home health agency performs an initial assessment using OASIS that converts the patient's condition into a numeric score in three areas: clinical severity, functional status, and service utilization. These scores are totaled and assigned a value, which correlates to a patient's home health resource group ("HHRG"), which are used to determine payment rates. There are 80 HHRGs representing the range of complexity of a patient's condition. Effective for cost reporting periods beginning on or after July 1, 1998, skilled nursing facilities ("SNFs") were no longer paid on a reasonable cost basis or through low volume prospectively determined rates, but rather on the basis of a prospective payment system ("PPS"). The PPS payment rates will be adjusted for case mix and geographic variation in wages and will cover all costs of furnishing covered SNF services (routine, ancillary, and capital-related costs). SNFs are also subject to consolidated billing, which places the responsibility on the SNF for billing Medicare for all Part A services provided to the SNF resident. The most recently implemented prospective payment system applied to inpatient rehabilitation services provided by either a free-standing rehabilitation hospital or a rehabilitation unit of a general hospital effective January 1, 2002. Under rehab PPS, hospitals will be reimbursed based on the characteristics of their patients, on a per-discharge basis, with payments covering all inpatient services. Payment rates to individual facilities will be adjusted to reflect geographic differences in wages and the care provided to a disproportionate share of low-income patients. The Benefits Improvement and Protection Act of 2000 ("BIPA") has reduced to some extent the harsh financial impact that was anticipated under the Balanced Budget Act. Despite this limited relief, the additional components of hospital services subject to PPS force hospitals to continue to balance increased costs and demands for quality services with capped reimbursement and consolidated billing. On January 1, 1992, Medicare reimbursement to physicians changed to a resource-based relative value scale ("RBRVS") from paying the lesser of the actual customary or prevailing charge for the services rendered. Under the Balanced Budget Act, a single conversion factor for all physician services will be established and updated by an adjusted Medicare Economic Index. RBRVS has had a significant impact on the Medicare reimbursement received by some physicians. This in turn has had an impact on the Medical Center by affecting physicians' admission practices and utilization of hospitals and revenues derived from physician employees who reassign their professional fees to the Medical Center. Uncertainty surrounds the future determination of reimbursement levels related to DRG classifications and outpatient services. In addition, the Medicare program is subject to judicial interpretations, administrative rulings, governmental funding, restrictions and requirements for -22- utilization review (such as second opinions for surgery and preadmission criteria). Such matters, as well as more general governmental budgetary concerns, may reduce payments made to the Medical Center, and future Medicare payment rates may not be sufficient to cover increases in the cost of providing services to Medicare patients. Medicaid. The Medical Center receives a significant portion of net patient service revenue from reimbursement under Medicaid (approximately _ the fiscal year ended June 30, 2011, see"SOURCES OF HOSPITAL REVENUE" in Appendix A). Medicaid is the commonly accepted name for the hospital reimbursement program created by certain provisions of the federal Social Security Act, as amended, to benefit indigent persons who are aged, blind or disabled, or members of certain families who are eligible for Aid to Families with Dependent Children. Medicaid is a combined federal and state program, administered in Iowa by the Department of Human Services. Reimbursement for hospital services is based on similar methods used for reimbursement under the Medicare program. Inpatient hospital services are reimbursed on the basis of all payor DRGs calculated similar to those used in the Medicare prospective payment system. Outpatient hospital services are also prospectively reimbursed based on ambulatory patient groups. The amount of Medicaid reimbursement received by the Medical Center in the future will depend on, among other things, fiscal considerations of both the federal and state governments in establishing their budgets for funding the Medicaid program. Significant changes have been and may be made in the Medicaid program that could have a materially adverse impact on the financial condition of the Medical Center. The purpose of much of this statutory and regulatory activity has been to contain the rate of increase in amounts paid to health care providers under the Medicaid program. Since a portion of the Medicaid program's costs are paid by the state, the absolute level of Medicaid revenues paid to the Medical Center, as well as the timeliness of their receipt, may be affected by the financial condition of and budgetary factors facing the State of Iowa. The actions that the State of Iowa could take with regard to reducing Medicaid expenditures to accommodate any budgetary shortfalls may include changing the method of payment to hospitals, changing eligibility requirements for Medicaid recipients and delaying actual payments due to hospitals. Any such action taken by the State of Iowa could materially affect the financial condition of the Medical Center, thus affecting the ability of the Medical Center to make payments under the Indenture. Boren Amendment. Under the so-called Boren Amendment, states were required to pay hospitals rates that are "reasonable and adequate" to cover the costs which must be incurred by "efficiently and economically operated" facilities. Effective for services furnished on or after October 1, 1997, the BBA repealed the Boren Amendment and established a public approval process under which proposed rates, methodologies underlying the rates and the justification for such rates are published and subject to public review and comment. The full impact of the repeal of the Boren Amendment on the Medicaid program in Iowa cannot be determined at this time. Medicaid funding may be affected further by health care reform legislation and general governmental budgetary concerns. It is impossible to predict the effect such changes might have on the Medical Center. Such changes may reduce payments made to the Medical Center under -23- Medicaid and future Medicaid payment rates may not be sufficient to cover increases in providing services to Medicaid patients. Audits and Withholds. Medicare participating hospitals are subject to audits and retroactive audit adjustments with respect to the Medicare program. Medicare regulations also provide for withholding Medicare payment in certain circumstances, and such withholds could have a material adverse effect on the financial condition of the Medical Center, thus affecting the ability of the Medical Center to make payments under the Indenture. Annual Cost Reporting. The Medical Center's annual cost reports, which are required under the Medicare and Medicaid programs, are subject to audit which ultimately may result in adjustments to the amounts determined to be due to or from the Medical Center under these programs. These audits often require several years to reach the final determination of amounts earned under the programs based on cost. Providers also have a right of appeal. Medicare/Medicaid Compliance and Reimbursement. Hospitals must comply with standards called "Conditions of Participation" in order to be eligible for Medicare and Medicaid reimbursement. CMS is responsible for ensuring that hospitals meet these regulatory conditions of participation, and the Medical Center is surveyed by the Iowa Department of Inspections and Appeals to determine whether it is in compliance with the Conditions of Participation. Significant failure to comply with the Conditions of Participation could result in loss of provider status which would materially affect the revenues of the Medical Center, thus affecting the ability of the Medical Center to make payments under the Indenture. Private Third Party Reimbursement Apart from reimbursement by the federal government under Medicare and the federal and state governments under Medicaid (Medical Assistance), a substantial portion of the Medical Center's revenue is provided by private third-party payors, such as commercial insurers and various types of"managed care" programs such as health maintenance organizations ("HMOs") and preferred provider organizations ("PPOs"). Generally, reimbursement received from HMOs and PPOs is lower than rates charged to patients covered by commercial insurance. Future contract negotiations between such third-party payors and the Medical Center, and other efforts of these third-party payors and of employers to limit hospitalization and health care costs, could adversely affect the level of utilization of the Medical Center's services, or reimbursement to the Medical Center, or both. In addition, it is possible that competitive pricing of plan premiums could cause an HMO or PPO to operate at a loss and expose the Medical Center to delays in payment or nonpayment of claims for services to plan participants. Changes in sources of revenue and case mix intensity may also adversely affect the Medical Center's operating revenue. For example, if patients formerly covered by commercial insurance programs that pay full hospital and physician charges shift to HMOs or other third- party payors that pay lower negotiated rates, the discounts reflected in the Medical Center's financial statements as contractual allowances will proportionately increase and income will proportionately decrease. In addition, if the average severity of illness or condition of patients of the Medical Center covered by a "capitated" plan (i.e., a plan that pays the Medical Center a fixed sum for each participant regardless of the services actually performed by the Medical Center for the participant) were to increase after execution of the plan contract, operating -24- expenses of the Medical Center would proportionately increase without an offsetting increase in operating revenues. Currently, the Medical Center does not have any capitalized contracts. In addition, private insurers or managed care programs might enter into contracts with physicians, hospitals or other health care providers whereby the providers are the sole providers of care for participants in the program. If significant numbers of persons living in the Medical Center's market area participated in exclusive provider programs not involving the Medical Center, the Medical Center's revenues and cash flow could be adversely impacted, thus affecting the ability of the Medical Center to make payments under the Indenture. Health Plan Financial Pressure and Insolvency Over the last few years, a number of health plans have become insolvent or experienced financial pressure or cash flow issues. Such plans range in size from smaller local provider- based plans to some of the largest plans in the United States. These plans include traditional indemnity insurers, as well as health maintenance organizations and preferred provider organizations. Health plans that experience financial pressure may slow payment to providers, withhold payment entirely, or utilize claims payment methodology that systematically reduces compensation on a per claim basis. Health plans that become insolvent may seek either federal bankruptcy or state insurance insolvency protection. Such bankruptcy or insurance insolvency protection may require that providers repay certain claims to the health plan, or result in certain claims becoming uncollectable. Emergency Medical Treatment and Labor Act In response to concerns regarding inappropriate hospital transfers of emergency room patients based on the patient's ability to pay for the services provided, Congress has enacted the Emergency Medical Treatment and Labor Act("EMTALA") or the "anti-dumping" statute. This law imposes certain requirements on hospitals prior to discharging an emergency patient or transferring such a patient to another facility. Failure to comply with the law can result in exclusion from the Medicare and/or Medicaid programs as well as civil penalties. Failure of the Medical Center to meet its responsibilities under EMTALA could adversely affect the financial condition of the Medical Center. EMTALA and its implementing regulations are complex, and the Medical Center's compliance is dependent, in part, upon the volition of independent Medical Staff members. Accordingly, there can be no assurance that no violation of EMTALA will be found or, if found, that any sanction imposed would not have a material adverse effect on the operations or financial conditions of the Medical Center, thus affecting the ability of the Medical Center to make payments under the Indenture. Other Legislative, Regulatory and Accreditation Requirements The Medical Center and its operations are subject to regulation and certification by various federal, state and local government agencies and by certain nongovernmental agencies such as the Joint Commission on Accreditation of Healthcare Organizations ("JCAHO"). No assurance can be given as to the effect on the Medical Center's future operations of existing laws, regulations and standards for certification or accreditation or of any future changes in such laws, regulations and standards. -25- Other regulatory programs which may have a significant effect on the Medical Center are changes in the governmental requirements concerning how patients are treated. These regulations are embodied in patients' bills of rights and similar programs being promulgated with greater frequency, and changes in licensure requirements. All of these could increase the cost of doing business and consequently adversely affect the financial condition of the Medical Center, thus affecting the ability of the Medical Center to make payments under the Indenture. Regulatory Environment "Fraud" and "False Claims. " Healthcare "fraud and abuse" laws have been enacted at the federal and state levels to broadly regulate the provision of services to government program beneficiaries and the methods and requirements for submitting claims for services rendered to the beneficiaries. Under these laws, hospitals and others can be penalized for a wide variety of conduct, including submitting claims for services that are not provided, billing in a manner that does not comply with government requirements or including inaccurate billing information, billing for services deemed to be medically unnecessary, or billings accompanied by an illegal inducement to utilize or refrain from utilizing a service or product. Federal and state governments have a broad range of criminal, civil and administrative sanctions available to penalize and remediate healthcare fraud, including the exclusion of a hospital from participation in the Medicare/Medicaid programs, civil monetary penalties, and suspension of Medicare/Medicaid payments. Fraud and abuse cases may be prosecuted by one or more government entities and/or private individuals, and more than one of the available sanctions may be, and often are, imposed for each violation. Laws governing fraud and abuse may apply to a hospital and to nearly all individuals and entities with which a hospital does business. Fraud investigations, settlements, prosecutions and related publicity can have a catastrophic effect on hospitals. See "Regulatory Environment - Enforcement Activity" below. Major elements of these often highly technical laws and regulations are generally summarized below. Billing and Reimbursement Practices. Under both the Medicare and Medicaid programs, certain health care providers, including hospitals, are required to report certain financial information on a periodic basis, and with respect to certain types of classifications of information, penalties are imposed for inaccurate reports. Moreover, health care providers, including hospitals and physician clinics, may be subject to criminal, civil and administrative penalties for violating billing and reimbursement requirements under state and federal law. These penalties can be substantial and may result in financial penalties and/or result in exclusion from participation in federal health care programs, including Medicare and Medicaid. As these requirements are numerous, technical and complex, there can be no assurance that the Medical Center will avoid incurring such penalties in the future. These penalties may be material and adverse and could include criminal or civil liability for making false claims and/or exclusion from participation in the federal health care programs. Under certain circumstances, payments made may be determined to have been made as a consequence of improper claims subject to the federal False Claims Act or other federal statutes, subjecting the provider to civil or criminal sanctions. The United States Department of Justice has initiated a number of national investigations involving proceedings under the federal False Claims Act relating to alleged -26- improper billing practices by hospitals. These actions have resulted in substantial settlement amounts being paid in certain cases. Management of the Medical Center does not believe that the Medical Center has improperly submitted claim or cost reports; however, in light of the complexity of the regulations relating to both the Medicare and Medicaid programs, and the'threat of ongoing compliance initiatives described above, there can be no assurance that significant difficulties will not develop in the future. False Claims Laws. There are principally three federal statutes that address the issue of "false claims." First, the Civil False Claims Act imposes civil liability (including substantial monetary penalties and damages) on any person or corporation which (1) knowingly presents or causes to be presented a false or fraudulent claim for payment to the United States government; (2) knowingly makes, uses, or causes to be made or used a false record or statement to obtain payment; or (3) engages in a conspiracy to defraud the federal government by getting a false or fraudulent claim allowed or paid. Specific intent to defraud the federal government is not required to act with knowledge; all that is required is that the person knew or should have known of the falseness of the claim. This statute authorizes private persons to file qui tam actions on behalf of the United States. The False Claims Act has become one of the government's primary weapons against healthcare fraud. The Fraud and Enforcement and Recovery Act ("FERA"), signed into law on May 20, 2009, has the potential to expand exposure under the Civil False Claims Act for a wide range of business transactions involving federal government funds. Pursuant to FERA amendments, the Civil False Claims Act may impose liability for false claims with more remote connections to the federal government. FERA may also have the effect of expanding liability for the retention of money owed to the government. FERA makes four other significant amendments to the Civil False Claims Act. First, it expands protection for"whistleblowers" who lawfully attempt to stop a violation of the Act. Second, it permits whistleblower plaintiffs to access information gained from government subpoenas. Third, it authorizes the government to share information provided by whistleblowers with law enforcement authorities from state or local governments. And lastly, it effectively expands the statute of limitations for actions, specifying that government complaints relate back to earlier whistleblower complaints for purposes of the statute of limitations. The Health Reform Act also extends liability when an overpayment from the government is identified and not returned by a specific deadline. In addition to the Civil False Claims Act, the Civil Monetary Penalties Law authorizes the imposition of substantial civil money penalties against an entity which engages in activities including, but not limited to, (1) knowingly presenting or causing to be presented, a claim for services not provided as claimed or which is otherwise false or fraudulent in any way; (2) knowingly giving or causing to be given false or misleading information reasonably expected to influence the decision to discharge a patient; (3) offering or giving remuneration to any beneficiary of a federal health care program likely to influence the receipt of reimbursable items or services; (4) arranging for reimbursable services with an entity which is excluded from participation from a federal health care program; (5) knowingly or willfully soliciting or receiving remuneration for a referral of a federal health care program beneficiary; or (6) using a payment intended for a federal health care program beneficiary for another use. The Secretary of Health and Human Services, acting through the Office of Inspector General ("OIG"), also has -27- both mandatory and permissive authority to exclude individuals and entities from participation in federal health care programs pursuant to this statute. Finally, it is a criminal federal health care fraud offense to: (1) knowingly and willfully execute or attempt to execute any scheme to defraud any health care benefit program; or (2) to obtain, by means of false or fraudulent pretenses, representations or promises, any money or property owned or controlled by any health care benefit program. Penalties for a violation of this federal law include fines and/or imprisonment, and a forfeiture of any property derived from proceeds traceable to the offense. The Health Reform Act also greatly expands potential liability under the Civil False Claims Act by limiting several longstanding defenses intended to protect against speculative lawsuits. In particular, the Health Reform Act makes the "public disclosure" and "original source" bars easier for plaintiffs to defeat, meaning that it will be easier for plaintiffs to assert claims under the False Claims Act. Hospital providers in many states also are subject to a variety of state laws, related to false claims (similar to the Civil False Claims Act or that are generally applicable false claims laws) and anti-kickback (similar to the federal Anti-Kickback Statute or that are generally applicable anti-kickback or fraud laws). These prohibitions are similar in public policy and scope to the federal laws, and could pose the possibility of material adverse impact for the same reasons as the federal statutes. At the present time, management of the Medical Center is not aware of any pending or threatened claims, investigations, or enforcement actions regarding the False Claims Act which, if determined adversely to the Medical Center, taken as a whole and taking into account current reserves, would have a material adverse effect on the financial condition of the Medical Center. Anti-Kickback Law. The federal Medicare, Medicaid Anti-Fraud and Abuse Amendments to the Social Security Act (the "Anti-Kickback Law") makes it a felony to knowingly and willfully offer, pay, solicit or receive remuneration, directly or indirectly, in order to induce business that is reimbursable under any federal health care program or in return for the purchasing, leasing, ordering or arranging for, or recommending the purchasing, leasing or ordering of, any good, facility, service or item for which payment is made in whole or in part under a federal health care program. Violation of these provisions may result in imprisonment for up to five years and criminal fines of up to $25,000 for each act. The OIG of DHHS also has the authority to impose civil monetary penalties of up to $50,000 per violation and must exclude hospitals who are convicted of violating the Anti-Kickback Law from federal health care programs for a period of not less than five years. In addition, the OIG may exclude any individual or entity that it determines has violated the Anti-Kickback Law even if the individual or entity has not been convicted. A person who violates the Anti-Kickback Law also is subject to damages of up to three times the total amount of remuneration offered, paid, solicited or received. Finally, the United States Government may exclude from a federal health care program any individual who has a direct or indirect ownership or control interest in a sanctioned entity and has acted in deliberate ignorance of the information or is an officer or managing employee of the sanctioned entity, irrespective of whether the individual participated in the wrongdoing. -28- The arrangements prohibited under the Anti-Kickback Law can involve hospitals and persons or entities with which hospitals do business, including, in particular, physicians and other health care providers and suppliers. Prohibited arrangements may include joint ventures between providers, space and equipment rentals, purchases of physician practices, physician recruiting programs and management and personal services contracts. In addition to certain statutory exceptions to the Anti-Kickback Law, the OIG has promulgated regulatory "safe harbors" under the Anti-Kickback Law designed to protect certain payment and business practices. A party may seek an advisory opinion to determine whether an actual or proposed arrangement meets a particular safe harbor. Failure to comply with a statutory exception or regulatory safe harbor does not mean that an arrangement is unlawful but may increase the likelihood of challenge. The safe harbors are, however, narrow and do not cover a wide range of business relationships that many hospitals, physicians and other health care providers have historically considered to be legitimate business arrangements not prohibited by the Anti- Kickback Law. Because the safe harbor regulations do not purport to describe comprehensively all lawful or unlawful business arrangements or other relationships between health care providers and referral sources, it is uncertain whether hospitals and other health care providers that have these arrangements or relationships may need to alter them in order to ensure compliance with the Anti-Kickback Law. Management of the Medical Center believes that the Medical Center's arrangements with referral sources are in compliance with the Anti-Kickback Law. However, because of the breadth of the Anti-Kickback Law and the narrowness of the safe harbor regulations, there can be no assurances that in the future the Medical Center will not be found to have violated the Anti-Kickback Law and, if so, whether any sanction imposed would have a material adverse effect upon the operations and financial condition of the Medical Center. Stark Physician Self-Referral Prohibition. Another federal law (known as the "Stark Law" or "Stark II" for other than clinical laboratory services), with limited exceptions, prohibits a physician who has a financial relationship, or whose immediate family member has a financial relationship, with entities (including hospitals) providing "designated health services" from referring Medicare or Medicaid patients to such entities for the furnishing of such designated health services. Stark Law designated health services include physical therapy services, occupational therapy services, radiology or other diagnostic services (including MRIs, CT scans and ultrasound procedures), durable medical equipment, radiation therapy services, parenteral and enteral nutrients, equipment and supplies, prosthetics, orthotics and prosthetic devices, home health services, outpatient prescription drugs, inpatient and outpatient hospital services and clinical laboratory services. The Stark Law also prohibits the entity receiving the referral from filing a claim or billing for the services arising out of the prohibited referral. The prohibition applies regardless of the reasons for the financial relationship and the referral; that is unlike the PP g P , federal Anti-Kickback Law, no finding of intent to violate the Stark Law is required. Sanctions for violation of the Stark Law include denial of payment for the services provided in violation of the prohibition, refunds of amounts collected in violation, a civil penalty of up to $15,000 for each service arising out of the prohibited referral, exclusion from the federal health care programs, and a civil penalty of up to $100,000 against parties that enter into a scheme to circumvent the Stark Law's prohibition. Knowing violations of the Stark Law have also served as the basis for lawsuits against health care organizations under the False Claims Act. The types of financial relationships between a physician and an entity that trigger the self-referral -29- prohibitions of the Stark Law are broad, and include ownership and investment interests and compensation arrangements. In 2001, CMS issued Phase I final regulations implementing the Stark Law's application to designated health services other than clinical laboratory services. The rules delineated in the Phase I regulations became effective in 2002. CMS issued Phase II final regulations which became effective in 2004. The rules delineated in the Phase II regulations address the remaining exceptions relating to ownership and investment and compensation arrangements, reporting requirements and sanctions, additional regulatory definitions, and additional new regulatory exceptions. However, the Phase 11 regulations did not address Stark II's application to Medicaid covered services, other than Medicaid managed care plans, but reserved that issue for a later date. CMS issued final regulations implementing Phase III of Stark II, effective December 4, 2007. Phase III made a number of changes to the existing exceptions relating to ownership and compensation, including changes to the content and interpretation of such exceptions. Certain of the changes set forth in the Phase III regulations could require modifying existing arrangements between the Medical Center and physicians. Such modifications could have a material effect on the nature of such arrangements. In addition to the Phase III final rules, in November 2008 CMS issued final rules governing Medicare physician payments effective January 1, 2009 that included changes to certain anti-markup regulations relating to diagnostic tests. The Medical Center does not believe that any of the changes will have a significant or material effect on existing arrangements between the Medical Center and physicians. The 2009 Inpatient Prospective Payment System Final Rule ("IPPS Final Rule") published on August 18, 2008 further revised the Stark Law regulations, certain provisions of which became effective on October 1, 2009 and others on October 1, 2009. Although many of the provisions of the Stark Law regulations were revised, the provisions of the IPPS Final Rule that could have a significant impact on the Medical Center include: (a) the definition of"entity" and the affect on services provided "under arrangements," (b) the "stand in the shoes" provisions under which certain physicians are treated as "standing in the shoes" of their "physician organizations," (c) limitations placed on revenue-based or percentage payments for space and equipment, and (d) limitations on "per-click" arrangements. The definition of an "entity" for Stark purposes now includes the person or entity that performs DHS services, as well as the person or entity that bills for DHS services. This change significantly affects the manner in which an "under arrangements"relationship may be structured. In addition, many revenue-based and percentage payments for space or equipment may no longer comply with space rental, equipment rental, fair market value, or indirect compensation exceptions. Further, many per-unit or per-click compensation methodologies for space and equipment rental charges will no longer comply with space rental, equipment rental, fair market value, or indirect compensation exceptions. The changes to percentage based and per-click compensation arrangements became effective October 1, 2009. In the 2009 IPPS Final Rule, CMS also finalized its proposal to implement an information collection instrument referred to as the Disclosure of Financial Relationships Report ("DFRR"). The DFRR is designed to collect information concerning the ownership and -30- investment interests and compensation arrangements between hospitals and physicians. CMS has stated it will send the DFRR to 500 hospitals, but that it may decide to decrease the number. Those hospitals that receive a DFRR will have 60 days in which to complete and send the information to CMS, and failure to do so could result in substantial civil monetary penalties. CMS also indicated that it envisions the DFRR as a one-time information collection instrument; however, depending on the information it receives sand other factors, CMS may propose future rulemaking to use the DFRR or some other instrument as a periodic or regular collection instrument. At a minimum, the new Stark Law regulations may require the Medical Center to amend or terminate certain arrangements with physicians or other referral sources to comply with the regulations' new requirements. The new Stark Law regulations will also limit the types of arrangements the Medical Center may enter into, and will increase the complexity of ensuring regulatory compliance in the Medical Center's contractual relationships. Given the relatively recent effective dates of many of these new regulations, it is currently uncertain whether, how or to what extent these regulations will affect the financial condition and results of operations of the Medical Center. A number of states have passed statutes similar to the Stark Law, pursuant to which similar types of prohibitions are made applicable to all other health plans or third-party payors beyond Medicare and Medicaid. [IOWA?] Although management of the Medical Center believes that the Medical Center is presently in material compliance with the Stark Law, as currently interpreted, there can be no assurance that regulatory authorities will not take a contrary position and that the Medical Center will not be found to have violated the Stark Law. Exclusion from the Medicare program may have a material adverse effect on the future operations and financial condition of the Medical Center, as would any significant penalties, demands for refund or denials of payment. Physician Recruitment. The Internal Revenue Service ("IRS") and DHHS have rendered decisions that could limit physician recruitment and retention arrangements. This is also a potential issue under the Anti-Kickback Law and Stark II. The Medical Center currently has no such arrangements [PLEASE CONFIRM]. If the Medical Center were to enter into such arrangements, it would need to comply with these regulatory requirements. Enforcement Activity. Enforcement activity against healthcare providers has increased and enforcement authorities have adopted aggressive approaches. In the current regulatory climate, it is anticipated that many hospitals and physician groups will be subject to an audit, investigation or other enforcement action regarding the health care fraud laws mentioned above. Enforcement authorities are often in a position to compel settlements by providers charged with or being investigated for false claims violations by withholding or threatening to withhold Medicare, Medicaid and/or similar payments and/or by instituting criminal action. In addition, the cost of defending such an action, the time and management attention consumed, and the facts of a case may dictate settlement. Therefore, regardless of the merits of a particular case, a hospital could experience materially adverse settlement costs, as well as materially adverse costs associated with implementation of any settlement agreement. Prolonged and publicized -31- investigations could be damaging to the reputation and business of a hospital, regardless of outcome. Certain acts or transactions may result in violation or alleged violation of a number of the federal healthcare fraud laws described above and therefore, penalties or settlement amounts often are compounded. Generally these risks are not covered by insurance. Enforcement actions may involve multiple hospitals in a health system, as the government often extends enforcement actions regarding healthcare fraud to other hospitals in the same organization. In the event of a successful prosecution by the federal government of a violation of these billing and reimbursement standards, it is possible that sanctions imposed would have a material adverse effect on the operations or financial condition of the Medical Center, thus affecting the ability of the Medical Center to make payments under the Indenture. Health Insurance Portability and Accountability Act Specific state and federal laws govern the use and disclosure of confidential patient health information, as well as patients' rights to access and amend their own health information. Health care providers, health care clearinghouses and operators of health plans have been significantly affected by certain health information requirements contained in the Administrative Simplification Requirements of the Health Insurance Portability and Accountability Act of 1996 ("HIPAA"), which established national standards to facilitate the electronic exchange of Protected Health Information ("PHI") and to maintain the privacy and security of PHI. These standards have a major effect on health care providers that transmit PHI in electronic form in connection with HIPAA standard transactions (e.g. health care claims). In particular, HIPAA establishes standards governing (1) Electronic Transactions and Code Sets; (2) Privacy; (3) Security; and (4) National Identifiers. The Medical Center has developed policies, procedures and practices that it believes comply with the HIPAA standards and requirements, but if it was determined that the Medical Center was not in compliance, there could be criminal and civil penalties imposed. The HITECH Act has significantly increased fines and the scope of remedies for violations of HIPAA. There are new requirements and potential exposure for breaches of the security of electronic health records. HITECH has also expanded rights of subjects of PHI. Increased federal enforcement is expected and increased civil and criminal penalties may be enforced against persons who obtain or disclose personal health information without authorization. In addition, State Attorneys General can bring civil actions against a person on behalf of residents adversely affected by violations of either HIPAA or the HITECH Act. The Attorney General can either seek to enjoin future violations or obtain money damages on behalf of the residents harmed. DHHS is also beginning to perform periodic audits of healthcare providers to ensure that required policies under the HITECH Act are in place. Finally, individuals harmed by violations will be able to recover a percentage of monetary penalties or a monetary settlement based upon methods to be established by DHHS for this private recovery. The effects of the HITECH Act on the financial condition of the Medical Center cannot be predicted at this time. -32- The Medical Center has taken reasonable steps to be in substantial compliance with the HIPAA regulations, but if it were found to be in violation, the fines could be substantial and could have an adverse financial impact, thus affecting the ability of the Medical Center to make payments under the Indenture. Compliance and Government Enforcement Initiatives Pursuant to the mandates of HIPAA and the Balanced Budget Act of 1997 passed by Congress, increased emphasis is being placed on federal investigations and prosecutions of Medicare and Medicaid "fraud and abuse" cases. Both Acts substantially increase enforcement resources within the Department of Justice, FBI and Office of Inspector General ("OIG") and mandate and provide resources for better coordination of enforcement and prosecution among federal agencies and with local authorities. The federal emphasis on and commitment to investigating, prosecuting and eradicating health care fraud has become a dominant national public policy theme. There are new and revised "whistleblower" incentives for private citizens to report or bring prosecutions against health care providers. The sanctions for violations of laws, particularly those related to Medicare and Medicaid billing,have increased substantially. Environmental Laws Affecting the Health Care Industry Health care facilities are subject to a wide variety of federal, state and local environmental and occupational and safety laws and regulations that address, among other things, health care operations or facilities and properties owned or operated by health care providers. Among the types of regulatory requirements faced by health care providers are: air and water quality control requirements; waste management requirements; specific regulatory requirements applicable to asbestos, polychlorinated biphenyls and radioactive substances; requirements for providing notice to employees and members of the public about hazardous materials handled by or located at the hospitals, clinics and nursing homes; and requirements for training employees in the proper handling and management of hazardous materials and wastes. In their role as owners and operators of properties or facilities, health care providers may be subject to liability for investigating and remedying any hazardous substances that have come to be located on the property, including any such substances that may have migrated off of the property. Typical health care operations include, in various combinations, the handling, use, storage, transportation, disposal and discharge of hazardous, infectious, toxic, radioactive, flammable and other hazardous materials, wastes, pollutants or contaminants. For this reason, health care operations are particularly susceptible to the practical, financial and legal risks associated with compliance with such laws and regulations. Such risks may result in damage to individuals, property or the environment; may interrupt operations or increase their cost, or both; may result in legal liability, damages, injunctions or fines; or may trigger investigations, administrative proceedings, penalties or other government agency actions. There can be no assurance that the Medical Center will not encounter such risks in the future, and such risks may result in material adverse consequences to the operations or financial condition of the Medical Center, thus affecting the ability of the Medical Center to make payments under the Indenture. Continued Utilization of Medical Center's Facilities A significant portion of the Medical Center's revenues are derived from the treatment of patients admitted to or provided services on an outpatient basis at the Medical Center's facilities -33- by members of its medical staff. Physicians on the medical staff have the option of admitting a particular patient, with the patient's consent, to the Medical Center's facilities or to other acute care hospitals or to similar facilities that are not controlled by the Medical Center, with which the physician may be affiliated. The revenues of the Medical Center could decrease if medical staff members admit patients to such other similar facilities or hospitals instead of admitting such patients to the Medical Center's facilities. The Medical Center faces competition from other hospitals and health care facilities and could face additional competition in the future as a result of the construction of new, or the renovation of existing, hospitals in the areas served by it. No assurance can be given that occupancy and utilization of the Medical Center's facilities will not be adversely affected by the availability of other hospital facilities in the service areas of the Medical Center and elsewhere, thus affecting the ability of the Medical Center to make payments under the Indenture. The Medical Center also faces potential competition from other forms of health care delivery, such as health maintenance organizations, preferred provider organizations, ambulatory surgical centers, home health agencies, expanded preventive medicine and outpatient treatment, drug and alcohol abuse programs, increasingly sophisticated physician group practices, private pathology laboratories and radiological services. Certain of such forms of health care delivery are designed to offer comparable services at lower prices and the federal government and private third-party payors, such as the Blue Cross programs, may increase their efforts to encourage the development and use of such programs. In addition, future changes in state and federal law may have the effect of increasing competition in the health care industry. Finally, managed care companies and insurers are becoming increasingly selective in contracting with health care providers. The revenues of the Medical Center could decrease significantly with the loss of such third party payor contracts, thus affecting the ability of the Medical Center to make payments under the Indenture. Possible Future State Legislation Some states have adopted, and many more considered, health care reform legislation that would change the payment for health care services, including specifically patients covered by the Medicaid or similar programs, and the way it is delivered. Though these legislative efforts are different in scope and form, most include one or more of the following: (i) cost reduction measures, using budget or cost increase approval as enforcement mechanisms; (ii) creation of health purchasing alliances; (iii) modification of payment provisions under the Medicaid or similar programs; (iv) taxes or assessments on hospitals to fund the costs of such programs and the cost of providing care to uninsured persons; (v) bans on certain self-referrals by physicians; (vi) penalties for offering, paying, soliciting or receiving consideration for referring patients covered by Medicaid or other payor contracts; (vii) "any willing provider" laws that require a managed care network to accept as part of the network any provider that makes application and is located within the applicable geographic area; and (viii) regulation of direct managed care agreements between providers and self-insured employees. There can be no assurance that future legislation will not adversely affect the future financial condition of the Medical Center. -34- Other Factors Generally Affectiny,Health Care Facilities Investments. The Medical Center has significant holdings in a broad range of investments. Market fluctuations may affect the value of those investments and those fluctuations may be and historically have been at times material. Construction Risks. Construction projects are subject to a variety of risks, including but not limited to delays in issuance of required building permits or other necessary approvals or permits, strikes, shortages of materials and adverse weather conditions. Such events could delay occupancy. Cost overruns may occur due to change orders, delays in the construction schedule, scarcity of building materials and other factors. Cost overruns could cause the costs to exceed available funds. Other Factors. The health care industry is highly dependent on a number of factors which may limit the ability of the Medical Center to meet its obligations with respect to the Series 2011 Bonds, a number of which are beyond the control of the Medical Center. Among other things, participants in the health care industry are subject to significant regulatory requirements of federal, state and local governmental agencies and independent professional organizations and accrediting bodies, technological advances and changes in treatment modes, various competitive factors and changes in third party reimbursement programs. Discussed below are certain of these factors which could have a significant impact on the future operations and financial condition of the Medical Center, thus affecting the ability of the Medical Center to make payments under the Indenture. It is difficult to predict the effect of these factors on the operations of the Medical Center; however, the factors described below could have a negative impact on such operations and such effect could be material: 1. Future medical and scientific advances, the development and requirement of the option for health maintenance organizations in labor contracts, state health plans, and other health plans, preventive medicine, improved occupational health and safety, and improved outpatient care could result in decreased usage of inpatient hospital facilities. 2. Changes in the economy and difficulties in increasing room charges and other fees, while at the same time maintaining scope and quality of health services, may affect the ability of the Medical Center to maintain sufficient operating margins. Iowa currently does not have a program for the regulation or review of rates charged for hospital services furnished to privately paying patients. If any such program was established, it could have an adverse effect on the Medical Center's revenues. 3. A shortage of qualified professional personnel, including registered nurses, could significantly increase payroll costs. The Medical Center cannot control the prevailing wage rates in its service area, and any increase in such rates will directly affect its costs of operations. The Medical Center may also be facing new accreditation standards which require increased staffing levels. The Medical Center is accredited by the Joint Commission on Accreditation of Health Care Organizations ("Joint Commission"). The Joint Commission has approved new standards for a hospital's monitoring of its staffing effectiveness. Under the standards, the Medical Center is required to conduct such monitoring through the use of human resource screening indicators -35- and clinical/service indicators to conduct an analysis of staffing effectiveness. On survey, the Joint Commission will review the organization's staffing plan, its review process, and the analysis and actions taken based on the results of the monitoring. If the effect of such monitoring and analysis is to require increased staffing, this could have an unpredictable impact on the cost of staff. A shortage of qualified personnel could compound these costs. 4. The possible inability to obtain future governmental approvals to undertake projects which the Medical Center deems necessary to remain competitive as to rates and charges and to maintain the quality and scope of care may adversely affect the Medical Center. The Medical Center is subject to health care planning programs administered by the State of Iowa which requires that a hospital obtain a certificate of need from the State Health Facilities Council before making certain capital expenditures or acquiring certain kinds of equipment, offering certain types of new services or discontinuing certain types of existing services. This requirement may prevent the Medical Center from adapting in a timely manner, or at all, to changes in the mix of services needed to meet the needs of its service area and/or to remain competitive with other health care providers. In 1997, the certificate of need statute was amended to eliminate the requirement from a certificate of need for replacement of previously existing buildings or equipment and for many other types of capital expenditures or new services. This amendment, or further change or elimination of the certificate of need statute in the future, could subject the Medical Center to unexpected competition from other health care providers which might then be able to enter the Medical Center's service area and offer some or all of the services provided by the Medical Center. 5. In recent years the dollar amounts of patient damage recoveries in malpractice suits have been increasing nationwide. The ability of, and the cost to, the Medical Center to insure or otherwise protect itself against malpractice claims may adversely affect the Medical Center. Changes in the cost of paying claims in excess of insurance coverage could directly adversely affect operating results. Prohibitive cost and unavailability of other types of insurance that the Medical Center desires to obtain may also adversely affect the Medical Center. In addition, the bankruptcy or insolvency of an insurance company which provides insurance coverage to the Medical Center would cause the Medical Center to be at risk for claims which would have been covered by such insurance without adequate liabilities having been recorded on the balance sheets. "Tort reform" legislation may limit the exposure of the Medical Center to such claims, but the likelihood of passage of such legislation and the effect it may have, if any, on the Medical Center or the cost of insurance coverage cannot be determined at this time. 6. Work stoppages, slowdowns or lockouts could reduce, interrupt or otherwise adversely affect operations of the Medical Center. Tax-Exempt Status of the Series 2011 Bonds As described hereinafter under the caption "TAX EXEMPTION AND RELATED CONSIDERATIONS," failure to comply with certain continuing legal requirements may cause interest on the Series 2011 Bonds to become subject to federal income taxation retroactive to the date of issuance of the Series 2011 Bonds. The Indenture does not provide for the payment of any additional interest or penalty in the event of taxability of interest on the Series 2011 Bonds. -36- LITIGATION The City has advised that there is not now pending, or to the knowledge of the City, threatened any litigation restraining or enjoining the issuance or delivery of the Series 2011 Bonds or questioning or affecting the validity of the Series 2011 Bonds, or the proceedings or the authority urider which they are to be issued. Neither the creation, organization or existence, nor the title of any of the present members of the City Council or the Board or of any officers of the City to their respective offices is being contested. There is no litigation pending, or, to the knowledge of the City, threatened which in any manner questions the right of the City or the Medical Center to enter into the Indenture or to secure the Series 2011 Bonds in the manner provided in the Indenture and the Act. The City has advised that no litigation or proceedings are pending or, to its knowledge, threatened against the City with respect to the Medical Center except (i) litigation, proceedings or investigations in which the probable ultimate recoveries and the estimated costs and expenses of defense, in the opinion of counsel to the City, will be entirely within applicable insurance policy limits (subject to applicable deductibles) or are not in excess of the total of available assets held under the Medical Center's applicable self-insurance, pooled risk insurance and shared risk insurance programs or(ii) litigation,proceedings or investigations which, if adversely determined, will not, in the opinion of counsel to the City, have a material adverse effect on the operations or condition, financial or otherwise,of the Medical Center. LEGAL MATTERS The validity of the Bonds and the tax-exempt status of the interest on the Bonds will be passed upon by Dorsey & Whitney LLP, Des Moines, Iowa, Bond Counsel. Certain legal matters will be passed upon for the City and the Medical Center by the Ames City Attorney, Ames Iowa. Certain legal matters will be passed upon for the Underwriter by its counsel, Best & Flanagan LLP, Minneapolis, Minnesota. The opinions of counsel will contain customary exceptions regarding bankruptcy, insolvency and similar laws affecting the enforcement of creditors' rights. The proposed form of opinion of Dorsey & Whitney LLP is set forth in Appendix D to this Official Statement. RATING Moody's Investor Services, Inc. ("Moody's"), has currently assigned its long-term bond rating of [" "] to the Bonds. The rating and an explanation of its significance may be obtained from Moody's, and such rating reflects only the view of Moody's. The Medical Center has furnished S&P with certain information and materials related to the Series 2011 Bonds and the Medical Center that has not been included in this Official Statement. There is no assurance that a particular rating will be maintained for any given period of time or that it will not be lowered or withdrawn entirely if, in the judgment of the agency originally establishing the rating, circumstances so warrant. None of the City, the Underwriter, or the Medical Center has undertaken any responsibility to bring to the attention of the holders of the Series 2011 Bonds any proposed revision or withdrawal of the rating of the Series 2011 -3 7- Bonds or to oppose any such proposed revision or withdrawal. Any such change in or withdrawal of such rating could have an adverse effect on the market price and marketability of the Series 2011 Bonds. UNDERWRITING Under a bond purchase agreement ("Bond Purchase Agreement') entered into between the City, the Medical Center and Piper Jaffray & Co. (the "Underwriter"), the Series 2011 Bonds are being purchased by the Underwriter at an aggregate purchase price of$ (net of net original issue discount/premium of $ and underwriting discount of $ ). The Bond Purchase Agreement provides that the Underwriter will purchase all of the Series 2011 Bonds if any are purchased. The obligation of the Underwriter to accept delivery of the Series 2011 Bonds is subject to various conditions contained in the Bond Purchase Agreement. The Underwriter intends to offer the Series 2011 Bonds to the public initially at the offering prices set forth on the inside front cover of this Official Statement, which may subsequently change without any requirement of prior notice. The Underwriter has entered into an agreement (the "Distribution Agreement") with Advisors Asset Management, Inc. ("AAM") for the distribution of certain municipal securities allocated to the Underwriter at the original offering prices. Under the Distribution Agreement, if applicable to the Bonds, the Underwriter will share with AAM a portion of the fee or commission, exclusive of management fees, paid to the Underwriter. The Underwriter also reserves the right to join with dealers and other underwriters in offering the Series 2011 Bonds to the public. The Underwriter may offer and sell Series 2011 Bonds to certain dealers (including dealers depositing Series 2011 Bonds into investment trusts) at prices lower than the public offering prices. In connection with this offering, the Underwriter may over allot or effect transactions which stabilize or maintain the market price of the Series 2011 Bonds at a level above that which might otherwise prevail in the open market. Such stabilizing, if commenced, may be discontinued at any time. The City and the Medical Center have agreed in the Bond Purchase Agreement to indemnify the Underwriter against certain civil liabilities, including certain potential liabilities under federal securities laws. CONTINUING DISCLOSURE In order to permit the Underwriter and other participating underwriters of the Series 2011 Bonds to comply with paragraph (b)(5) of Rule 15c2-12 promulgated by the Securities and Exchange Commission under the Securities Exchange Act of 1934, as amended (the "Rule"), the City and the Medical Center will covenant and agree, for the benefit of the registered holders or beneficial owners from time to time of the outstanding Bonds, in a Continuing Disclosure Agreement, dated as of October 1, 2011, among the City, the Medical Center and the Trustee, as agent (the "Continuing Disclosure Agreement"), to provide annual and quarterly reports of specified information and notice of the occurrence of certain material events. A form of the Continuing Disclosure Agreement is attached as Appendix E hereto. -38- Breach of the Continuing Disclosure Agreement will not constitute a default or an "Event of Default" under the Indenture. A broker or dealer is to consider a known breach of the Continuing Disclosure Agreement before recommending the purchase or sale of the Series 2011 Bonds in the secondary market. Thus, a failure on the part of the City and the Medical Center to observe the covenants under the Continuing Disclosure Agreement may adversely affect the transferability'and liquidity of the Series 2011 Bonds and their market price. Neither the City nor the Medical Center has been in default under any prior disclosure agreement. TAX EXEMPTION AND RELATED CONSIDERATIONS Interest on In the opinion of Bond Counsel, based upon federal laws, regulations, rulings and decisions in effect on the date of delivery of the Series 2011 Bonds, the interest on the Series 2011 Bonds is, including any original issue discount, excluded from gross income of the owners thereof for federal income tax purposes, and is not treated as an item of tax preference for purposes of determining the federal alternative minimum tax for individuals and corporations, but, in the case of corporations (as defined for federal income tax purposes), such interest is included in adjusted current earnings for purposed of the federal alternative minimum tax. The Series 2011 Bonds are not exempt from present State income taxes imposed on corporations. The Code establishes certain requirements (the "Federal Tax Requirements")that must be met subsequent to the issuance of the Series 2011 Bonds in order that, for federal income tax purposes, interest on the Series 2011 Bonds not be included in gross income pursuant to Section 103 of the Code. The Federal Tax Requirements include, but are not limited to, requirements relating to the expenditure of proceeds of the Series 2011 Bonds, requirements relating to the operation of the facilities financed by the 2010A Bonds, restrictions on the investment of proceeds of the Series 2011 Bonds prior to expenditure and the requirement that certain earnings on the "gross proceeds" of the Series 2011 Bonds be paid to the federal government. Noncompliance with the Federal Tax Requirements may cause interest on the Series 2011 Bonds to become subject to federal income taxation retroactive to their date of issue irrespective of the date on which such noncompliance occurs or is ascertained. In expressing its opinion, Bond Counsel will assume compliance by the City, the Medical Center and the Trustee with the tax covenants contained in the Indenture. No provision has been made for an increase in the interest rate on the Series 2011 Bonds in the event that interest on the Series 2011 Bonds becomes subject to federal income taxation. Prospective purchasers of the Series 2011 Bonds should be aware that the ownership of the Series 2011 Bonds may result in collateral federal income tax consequences to individual recipients of Social Security or Railroad Retirement benefits and taxpayers who may be deemed to have incurred or continued indebtedness to purchase or carry tax-exempt obligations. Certain corporations may have a tax imposed on passive income, including tax-exempt interest, such as interest on the Series 2011 Bonds. Bond Counsel expresses no opinion with respect to such other potential collateral tax consequences and prospective purchasers of the Series 2011 Bonds should consult their tax advisors as to the applicability and impact of these and other potential collateral tax consequences of owning and disposing of the Series 2011 Bonds. -39- INDEPENDENT AUDITORS The consolidated financial statements of the Medical Center for the years ended June 30, 2009, 2010 and 2011, included in APPENDIX B of this Official Statement, have been audited by McGladrey &Pullen, LLP, independent auditors, as stated in their report, appearing in Appendix B. MISCELLANEOUS The references herein to the Indenture and the Series 2011 Bonds are brief outlines of certain provisions thereof. Such outlines do not purport to be complete and for full and complete statements of such provisions reference is made to such documents, copies of which will be on file at the principal offices of the Underwriter during the period of the offering of the Bonds and thereafter at the principal corporate trust office of the Trustee. Any statements made in this Official Statement involving matters of opinion or estimates, whether or not so expressly stated, are set forth as such and not as representations of fact, and no representations are made that any of the estimates will be realized. The Medical Center and the City have authorized the use and distribution of this Official Statement. -40- APPENDIX A INFORMATION CONCERNING MARY GREELEY MEDICAL CENTER A-1 APPENDIX B AUDITED FINANCIAL STATEMENTS B-1 APPENDIX C DEFINITIONS OF CERTAIN TERMS AND SUMMARY OF CERTAIN PROVISIONS OF THE INDENTURE The following is a summary of certain provisions of the Indenture. This summary does not purport to be complete and is qualified in its entirety by reference to the Indenture for a complete statement of the provisions of such documents. C-1 APPENDIX D FORM OF BOND COUNSEL OPINION D-1 APPENDIX E FORM OF CONTINUING DISCLOSURE AGREEMENT 1357987_1 E-1