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✨ Governance of CCRC/LifePlan Communit

Residents on Board and Conflict pf Interest
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Here is what Elderlaw expert Katherine Pearson said in 2011:

"Pennsylvania, as with many states that regulate CCRCs, mandates that residents

have a right to “self-organization.”65 Pennsylvania further requires that the board of

directors or a “designated representative” of the CCRC’s governing body must meet

with the residents on at least a quarterly basis for “free discussion of subjects which

may include income, expenditures and financial matters.”66 During meetings by the

authors with residents in Pennsylvania and other states between August 2010 and

April 2011, however, one of the most frequent inquiries was about whether residents

can and should be represented “on” the governing boards of CCRCs. Residents

point to this opportunity as among the most important ways for residents to develop

trust for the information and decisions coming from their communities’ leadership,

whether that leadership is connected to nonprofit or for-profit organizations.

New Jersey is among the leaders in the country in requiring a role for residents

on boards of directors. New Jersey law provides that the governing bodies of their

CCRCs must include “at least one resident as a full voting member.”67 The procedure

mandated by New Jersey law for selection of a representative allays the concerns

expressed by some governing bodies about hostile or disruptive members, by providing

that the resident members “shall be nominated by the elected representatives

of the residents and selected by the board of directors.”68 During a meeting

with more than 150 CCRC residents at the state-wide meeting of ORANJ in April,

2011, the authors heard from a number of attendees who spoke eloquently about

their experiences as resident members on CCRC governing boards in New Jersey.

New Jersey’s adoption of the resident-board member law in October 2007 was the

direct result of advocacy by the state-wide residents’ organization, ORANJ.69 The

recent transparency study by ORANJ also demonstrated that the longer residents

serve on boards, the greater the acceptance by the nonresident members, often

resulting in increasingly active roles for resident-members.70 Other jurisdictions

that require residents to be represented on governing boards of CCRCs include

Maryland,71Washington D.C.,72 California,73 Ohio,74 and Oregon75 although in the

latter three states, the residents have non-voting positions.

One objection sometimes raised to resident membership on boards of directors is

a concern for conflict of interest, pointing out that board members have a fiduciary

duty to the “organization,” rather than to fellow residents who are merely customers.

However, Pennsylvania already recognizes that members of boards of directors

for corporations are permitted to consider the “effects” of any corporation

decision on “any or all groups affected by such action, including . . . customers” when

determining what is in the best interest of the corporation, and board members may

do so without breaching their duty to the corporation.76 For CCRCs, there is a close

alliance with the mission of the organization and the interests of the residents,

although resident-members will need to understand that their fiduciary duties to

the organization may trump individual interests or short-sighted concerns of fellow

residents.

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65. 40 PA. STAT. ANN. §3215 (“Right of Organization”).

66. Id.

67. N.J. STAT. ANN. §52:27D-345 (e).

68. Id.

69. Success in Trenton – Residents Inclusion On Boards of Trustees Has Graduated From a Hope to a Reality,

http://oranjccrc.org/action.htm.

70. ORANJ Transparency Study Report, supra note 63.

71. Md. CODE ANN., HUM. SERV., §10-427 (mandating inclusion of “subscribers” as “full and regular”

members of governing bodies).

72. D.C. CODE §44-151.10(d).

73. CAL. HEALTH & SAFETY CODE §117.8(i).

74. OHIO REV. CODE ANN. §173.13(B).

75. OR. REV. STAT. §101.112(6).

Electronic copy available at: https://ssrn.com/abstract=2019705

80 PENNSYLVANIA BAR ASSOCIATION QUARTERLY | April 2011


Richmond Shreve

NaCCRA Board Member

Forum Moderator

Kay,

Thanks for your comment. I would like NaCCRA to develop and publish a booklet of best practices for the CCRC corporate board of directors. Contributions to this forum will be invaluable.


Richmond Shreve

NaCCRA Board Member

Forum Moderator

I agree with Bruce. There certainly can't be a "real" conflict of interest if the resident is representing all residents. Only "real" conflict would occur if a recommendation or decision was being made about their personal residence or contract.

Of all the bogus responses about resident Board representation, this one takes the proverbial cake. CCRC residents do not have a conflict of interest. Rather, we have a direct stakeholder interest. CCRC residents have given CCRC corporations an unsecured and non-interest bearing loan, and we carry most all, if not all, of the financial risks. It is just common sense that we want a say in the financial goings-on of the corporation.


Bruce Hartung

MaCCRA President (Maryland)

The 2021 March/April issue of LifeLIne contains a letter to the editor which deals with the "conflict of interest" argument. For convenience, I am attaching a copy of pages 6 and 7 of that issue. The highlighting is mine.

You, as a resident, should have access to as much financial information as bondholders do.


Financial Soundness Handbook for CCRCs

Model Bill of Rights


Richmond Shreve

NaCCRA Board Member

Forum Moderator

Two points:

  1. All board members can and should solicit and listen to the observations and opinions of residents, employees, and other stakeholders as background for making assessments of the enterprise and its management. They are responsible for knowing about threats and opportunities that influence policy decisions.
  2. No board member should speak for the board without the Board granting authority to do so. This principle may limit what a board member volunteers in conversations about the business of the board.

Many for-profit boards require board members to sign confidentiality agreements. Trade secrets, litigation matters, and information that might give competitors an advantage must be protected. Nonprofits should operate with transparency except in personnel matters and privacy matters such as privileged medical information.


I would argue that there is no conflict of interest in board members listening to residents, or in discussing matters not deemed to be confidential by the Board of Directors. If a question is asked that touches on a confidential area, the director should simply acknowledge the question and say, "I'm not authroized to discuss that, but I will convey your concern."


Richmond Shreve

NaCCRA Board Member

Forum Moderator

Board president of our CCRC claims that any resident who is a board member has a conflict of interest and must not participate in any discussions regarding financial matters. This seems extreme and not in accordance with IRS guidelines regarding conflict of interest. Has any other CCRC dealt with this issue?

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