SUMMARY PLAN DESCRIPTION/PLAN DOCUMENT FOR THE SCL HEALTH - EMPLOYEE ASSISTANCE PROGRAM (Effective January 1, 2021)

SUMMARY PLAN DESCRIPTION/PLAN
         DOCUMENT

             FOR THE

        SCL HEALTH
EMPLOYEE ASSISTANCE PROGRAM

        (Effective January 1, 2021)

INTRODUCTION

Sisters of Charity of Leavenworth Health System (“Sponsoring Employer”) sponsors the SCL Health
Employee Assistance Program (the “EAP”) for the benefit of its employees and the eligible employees of
its participating affiliates (collectively, “Employer” or “Employers”).

The EAP is a confidential personal consultation program designed to help you and your family members
address personal challenges more efficiently and effectively. Under the EAP, you can obtain help 24
hours a day, seven days a week, 365 days a year, via a toll-free telephone number (1-800-624-5544), for
crisis counseling and to obtain referrals to EAP counselors and other community resources.

All EAP-related services are provided by New Directions Behavioral Health, LLC ("New Directions").
The Sponsoring Employer has an agreement with New Directions to provide these services. The EAP
will be interpreted and administered at all times in a manner that is consistent with such agreement. New
Directions is responsible for providing all services under the EAP and the Employer is not
responsible for the provision of services or for the payment of any services under the EAP.

It is important that you carefully review this document to understand the benefits which are available to
you through the EAP, as well as your responsibilities to ensure that you are able to receive all of the
benefits for which you are eligible. This document has been written so that it is not just a summary of
EAP benefits, but also the legal plan document written so that it can be used by you or the Administrative
Fiduciary in understanding and administering the benefits provided by the EAP. This document and the
SCL Health Associate Health Benefit Plan constitute the formal plan document for the EAP.
.
This document is updated from time-to-time. This version is effective January 1, 2021 and replaces all
prior versions. If you are not certain that you have the most recent document, please visit
www.sclhealthbenefits.org or call 855-412-3701 for the most up-to-date version.

Eligibility

Except as noted below, all eligible employees are automatically enrolled in the EAP as of their first day of
work. Except as noted below, you are an eligible employee if you are classified by the Employer as a
common law employee.

Eligible employees do not include:

   Any individual classified by the Employer as an independent contractor.
   Any individual whose compensation for services to the Employer is reported on IRS Form 1099.
   Any individual whose compensation for services to the Employer is paid from a payroll or other
    account of another employer under contract with the Employer.
   Any individual who is not paid from the Employer’s payroll account or with respect to whom the
    Employer does not issue an IRS Form W-2 (or any replacement form).
   Any employee whose employment is governed by the terms of a collective bargaining agreement
    under which benefits were the subject of good faith bargaining between the parties, unless such
    agreement is construed by the applicable Employer to provide for participation in this Plan.

The above exclusions are not affected by the Employer’s misclassification of the individual’s
employment status, or a determination by a court, government agency, arbitrator, or other authority that

the individual is or was a common-law employee of the Employer, or that the Employer is or was a
common law employer, joint employer, single employer, or co-employer of the individual.

Your family members who reside in your household are also eligible for EAP services during the same
period you are eligible for EAP services. Family members include your spouse, your children, your
legally-domiciled adult, or other members of your household. Your children who do not reside with you
are eligible for EAP services up to age 26.

Plan Cost

The Employer pays a fee to New Directions to provide the services under the EAP. The Employer is not
responsible for any other costs related to services that may be provided under the Plan or related to the
Plan.

You are not required to make any payment for the services provided by the EAP, except as specifically
noted herein.

How the EAP Works

The EAP offers the following benefits:

   Assessment, consultation, and problem solving.
   Risk screening and crisis intervention.
   Advocacy to help you address your situation.
   Referral to a licensed network practitioner for up to six counseling sessions (based on clinical
    necessity) at no charge per employee or family member per unique problem.
   Referral to community resources.
   Educational materials specific to issue.
   Legal consultation from a licensed attorney (does not include consultation related to any dispute
    involving SCL Health or any of its divisions, operating or business units, affiliates, employees, agents
    or directors, or any dispute against the EAP or any other employee benefit plan, or any employment-
    related matter). The initial consultation is provided at no cost. After the initial consultation, a 25%
    discount is provided on the attorney’s hourly rate.
   Mediation services. The initial consultation is provided at no cost. After the initial consultation, a
    25% discount is provided on the attorney’s hourly rate.
   Financial counseling from a credentialed financial professional. The initial telephone consultation is
    provided at no cost. After the initial consultation, you will be referred to a verified resource who can
    provide further assistance. Fees may apply after the initial consultation.

In order to receive EAP benefits, all services must be pre-certified by New Directions and provided by a
New Directions’ network practitioner. When you call Member Services, you will speak with a licensed
behavioral health professional who will refer you to a licensed practitioner in your area.

The EAP provides both clinical and non-clinical services. Your EAP benefit covers up to six counseling
visits or six weeks of on-line therapy for each issue or problem. You may receive an additional six visits
or six weeks of on-line therapy for the same issue or problem, but those visits or therapy may not start for
at least 12 months from the date your case for the issue was last opened.

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Non-clinical services include child/elder care referral; adult/elder support services; child/parenting
support services; chronic condition support; financial services; legal assistance; life learning. You will be
referred to verified resources that specialize in these services, and any fees are your responsibility.

What The EAP Covers

Getting Help Through the EAP

It’s easy to get help through the Member Services call line toll-free at 1-800-624-5544, 24 hours a day,
seven days a week, 365 days a year.

When you call, you’ll speak to an EAP specialist (an experienced behavioral health professional) who can
answer your questions about EAP benefits and listen to your needs. The EAP specialist can help you find
the right assistance and resources for your situation.

If necessary, the EAP specialist will locate a credentialed EAP provider so that you can schedule a
convenient appointment. The EAP has an extensive network of qualified providers. The nationwide
network includes psychologists, social workers, and marriage, family, and child counselors. Typically,
the EAP provider can meet with you within three to five days, in the privacy of his or her office. In
emergencies, appointments are available in less than 24 hours.

EAP Benefits

The EAP can help with:

   Work-related problems, such as job stress, overwork, burnout, and interpersonal conflicts.
   Marital issues, including parenting issues and couples’ communications problems.
   Family problems, such as parent/child conflicts, single parenting issues, child and adolescent
    problems, spousal abuse, and incest.
   Emotional problems and personal issues, including anxiety, depression, personal crises, and life
    transitions.
   Addictions, including alcohol and drug abuse, problem gaming/gambling, and co-dependency.
   Disease-related issues, such as coping with chronic and terminal illness, and grief and loss.

Plan Limitations

Your EAP does not provide or pay for:

   Services given by a pastoral counselor

   Psychological testing or other psychiatric services

   Electroconvulsive therapy (ECT)

   Private-duty nursing services while confined in a facility

   Weight reduction or control supplies, special foods, food supplements, liquid diets, diet plans, or any
    related products

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   Services given by volunteers or individuals who do not normally charge for their services

   Treatment for chronic paid except for psychotherapy, biofeedback, hypnotherapy rendered in
    connection with a DSM-IV diagnosis, precertified by the Claims Administrator

   Treatment provided by an MD or DO

   Court-mandated counseling, evaluations required by a state or federal judicial officer or other
    governmental official or agency or to be used in legal actions of any kind (for example, child custody
    proceedings)

   Testimony in legal proceedings, creation of records for legal proceedings or other preparation for
    legal proceedings

   Guidance on workplace or legal issues when you sue, or threaten to sue, the Sponsoring Employer or
    a participating employer

   Tax preparation services or comprehensive tax preparation assistance

   Services not pre-certified by New Directions.

Confidentiality

The EAP is designed as a confidential program and New Directions is committed to protecting your
privacy. In most cases, EAP counseling offices are located away from your worksite.

The discussions you have with your EAP counselor will not be disclosed to anyone without your written
consent, except in the specific instances required or permitted by law (for example, where child abuse or
elder abuse must be reported). You are encouraged to discuss the rules of confidentiality (and the
exceptions) directly with your EAP counselor or with New Directions.

HIPAA Privacy Regulations

The Health Insurance Portability and Accountability Act of 1996 (HIPAA) is a federal law enacted by
Congress. The law has provisions designed to improve people’s access to health care, as well as
requirements for health care providers and health plans to more efficiently and securely share health care
data and information. The HIPAA privacy regulations establish standards for protecting individuals’
medical records and other personal health information.

Protecting the Privacy of Health Information

The federal law, enacted by Congress, created national standards for the handling of protected health
information (PHI) by setting boundaries on how individually identifiable health information may be used
and disclosed. It also enables individuals to be informed about how their PHI may be used.

PHI is confidential, personal, identifiable health information about individuals that is created or received
by a health plan, provider or health care clearinghouse and is transmitted or maintained in any form
(including electronically). “Identifiable” means that a person reading this information could reasonably
use it to identify an individual. PHI includes information of persons living or deceased.

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Elements that make health-related information PHI include name, address, e-mail address, birth date
(except year), Social Security number, and claim number. Examples of PHI include completed health
care claim forms, detailed claim reports, and explanation of benefits.

Participants’ Rights Under These New Regulations

A Notice of Privacy Rights is available at ndbh.com. All plan participants are encouraged to read it. It
describes how the plan is permitted to use PHI and the rights of individuals. These include the rights to:

   Access their personal PHI and request amendments or corrections;
   Request an accounting of certain disclosures of PHI; and
   Submit a complaint regarding any violation of the privacy rights protected by HIPAA.

The notice also explains the procedures for exercising these rights.

Permitted Use and Disclosure of Protected Health Information

New Directions may only use and disclose PHI it receives from the plan as permitted and/or required by
and consistent with HIPAA and its accompanying Privacy and Security regulations found at 45 CFR Part
164. This includes, but is not limited to, the right to use and disclose participants’ PHI (including
electronic PHI) in connection with payment, treatment and health care operations.
.
New Directions agrees to:

   Not use or further disclose PHI other than as permitted or required by the plan documents or as
    required by law;
   Ensure that any agent, including a subcontractor, to whom it gives PHI received from the plan, agrees
    to the same restrictions and conditions that apply to New Directions with respect to such information;
   Implement administrative, physical, and technical safeguards that reasonably and appropriately
    protect the confidentiality, integrity and availability of the electronic PHI that it creates, receives,
    maintains, or transmits on behalf of the plan;
   Ensure that any agent, including a subcontractor, to whom it gives electronic PHI, agrees to
    implement reasonable and appropriate security measures to protect such information;
   Not use or disclose PHI for employment-related actions and decisions or in connection with any other
    benefit or employee benefit plan of SCL Health;
   Report to the plan, at such times and in such manner as agreed upon, any use or disclosure of the
    information that is inconsistent with the uses or disclosures provided for of which New Directions
    becomes aware;
   Make available PHI in accordance with individuals’ rights to access and review their PHI;
   Make available PHI for amendment and incorporate any amendments to PHI consistent with the
    HIPAA Privacy rules;
   Make available the information required to provide an accounting of disclosures in accordance with
    the HIPAA Privacy rules;

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   Make its internal practices, books, and records relating to the use and disclosure of PHI received from
    the plan available to the Secretary of Health and Human Services for purposes of determining
    compliance by the Plan with the HIPAA Privacy rules.

Plan Administration

The EAP is administered by New Directions, which has the absolute and sole discretionary authority to:

   Construe and interpret the provisions of the EAP, EAP documents, summary plan description, as well
    as any communications related to the EAP,

   Make factual determinations thereunder, including determining the rights or eligibility of employees
    or participants and any other persons, and the amounts of their benefits under the EAP, and

   Remedy ambiguities, inconsistencies, or omissions.

Such determinations shall be binding on all parties. Benefits will only be paid if New Directions, in its
sole discretion, determines that the employee or family member is entitled to them.

Filing a Claim

You generally are not required to file a claim for benefits under the EAP. The EAP generally provides six
sessions per unique issue, as described above. New Directions will track the number of sessions and
communicate with the individual when these sessions have been used.

Before you can bring a lawsuit against the EAP in state or federal court, however, you must timely use
and exhaust the EAP’s claims and appeals procedures. No interest is payable on any benefits that are
delayed or paid late.

New Directions will decide claims within the time permitted by applicable law, but generally no longer
than 15 days after receipt. If New Directions needs additional time to decide a claim due to matters
beyond its control, it will send you a written notice of the extension, which will not exceed 15 days. If
New Directions needs additional information from you in order to decide the claim, New Directions will
send you a written notice explaining the information needed. You will have 45 days to provide the
information to New Directions. If your claim is denied, in whole or in part, New Directions will inform
you of the denial in writing.

If your claim is denied, in whole or in part, you may file an appeal. The appeal must be in writing and
received by New Directions within 180 days of your notice of the denial. During the internal appeals
process you must raise all issues and legal theories you wish to have considered at any time during the
internal or external administrative claims review process or any subsequent lawsuit.

The appeal should be mailed to the following address:

        NDBH
        P.O. Box 6729
        Leawood, KS 66206-0729

New Directions will inform you in writing of the decision on appeal within 30 days of its receipt of your
request for an appeal.

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No legal action, including a lawsuit, may be brought more than one year after a final decision is rendered
on a claim. In addition to the one-year deadline that applies to filing a lawsuit after the claims and
appeals procedures are exhausted, there is a general time limitation that applies to all lawsuits
involving all types of plan issues. You must commence any such lawsuit involving plan claims no later
than two years after you first receive information that constitutes a clear repudiation of the rights you are
seeking to assert (i.e., the underlying event or issue that should have triggered your awareness that your
rights under the plan may have been violated). Although any period of time when your claim is in the
claims procedure described above (i.e., the time between when you file a claim for benefits and the time
you receive a final determination letter) does not count against the two-year period, once the claims
procedure process is completed, the two-year period will continue running where it left off.

New Directions has absolute authority and sole discretion to interpret and apply plan provisions and
determine facts, benefits, and eligibility. All interpretations, decisions, and determinations of New
Directions are intended to be final, conclusive, and binding on all parties having an interest in the plan.
New Directors is the named fiduciary with the full power to interpret and apply the terms of the plan with
respect to the benefits provided under the insurance contract.

If you have any complaints about services under the EAP, you should contact New Directions at 1-800-
624-5544.

As a result of the national emergency related to the COVID-19 outbreak, the time periods in which
you may file a claim and file a request for an appeal of a denied claim have been extended to the
extent required by law. Generally, you have up to 60 days after the announced end of the national
emergency related to the COVID-19 outbreak to file a claim or request an appeal of a denied claim.

Termination of Coverage

Your coverage and the coverage of your family members will end on the earliest of:

   For you and your family members, thirty-six months after your termination of employment for any
    reason or after your employment position or status changes so that you are no longer eligible under
    the EAP;
   For your family members, thirty-six months after he or she ceases to be your eligible family member;
   For you and your family members, the date specified in any EAP amendment resulting in loss of
    eligibility;
   For you and your family members, the date the EAP is terminated; and
   For you and your family members, the date you or your family member engage in fraud against the
    EAP. Cancellation is effective immediately on the date New Directions mails notice of cancellation,
    unless the notice specifies a later date.

New Directions also reserves the right to cancel your coverage if you threaten the safety of its employees,
EAP counselors, or others eligible for or receiving EAP services or if your repeated behavior has
substantially interfered with New Directions ability to furnish or arrange services for you or others or the
ability of an EAP counselor to provide services to others. If New Directions cancels your coverage based
on your conduct, you forfeit all continuation rights described above and to coverage under any of New
Directions programs in the future.

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General Information

Plan Name

        SCL Health Employee Assistance Program

The SCL Health Employee Assistance Program is part of the SCL Health Associate Health Benefit Plan.

Plan Sponsor and ERISA Plan Administrator

        SCL Health
        500 Eldorado Blvd., Ste. 4200
        Broomfield, CO 80021
        (303) 813-5250
        EIN: 23-7379161

As of January 1, 2021, the following employers have also adopted the Plan for the benefit of their eligible
employees:

        Brighton Community Hospital Association (d/b/a Platte Valley Medical Center)
        Caritas Clinics, Inc.
        Holy Rosary Healthcare
        Marian Clinic, Inc.
        Mount St. Vincent Home, Inc.
        Platte Valley Medical Group, LLC
        SCL Front Range Home Health, LLC
        SCL Health-Front Range, Inc.
        SCL Health Medical Group - Billings, LLC
        SCL Health Medical Group - Butte, LLC
        SCL Health Medical Group - Denver, LLC
        SCL Health Medical Group - Grand Junction, LLC
        SCL Health Medical Group Miles City
        SCL Health - Montana
        St. James Healthcare
        St. Mary's Hospital and Medical Center, Inc.
        Mother House of the Sisters of Charity of Leavenworth, Kansas
        University of Saint Mary

Plan Number

        521

Effective Date

        The EAP was amended and restated as of January 1, 2021.

Agent for Service of Legal Process

        SCL Health
        c/o Senior Vice President, Chief Human Resources Officer
        500 Eldorado Blvd., Ste. 4300
        Broomfield, CO 80021

                                                   -9-

Service may also be made upon the Plan Administrator.

Type of Plan

        Welfare Benefit Plan

Plan Year

        January 1 - December 31

Plan Funding

The cost of the EAP is paid for solely by the Sponsoring Employer. Benefits are insured by New
Directions Behavioral Health, LLC, 6100 Sprint Parkway, Suite 200, Overland Park, KS 66211.

Changing or Ending the EAP

This Plan may be modified and amended at any time by the Sponsoring Employer as follows:

       (a)      The Board of Directors of the Sponsoring Employer, in its sole discretion, may amend or
modify the Plan, in whole or in part, at any time.

         (b)    The President/Chief Executive Officer of the Sponsoring Employer, in his or her sole
discretion, may amend or modify the Plan to the extent such amendment or modification would not
constitute a material change in the benefits design or philosophy of the Sponsoring Employer or result in
a material increase in costs to the Sponsoring Employer; provided, however, that the President/Chief
Executive Officer shall make any Plan amendment reasonably requested by the Mother House of the
Sisters of Charity of Leavenworth, the University of Saint Mary, Mount Saint Vincent or Cristo Rey
solely with respect to its Participants, to the extent such amendment is permitted by law, does not result in
adverse tax consequences and is administratively practicable. In determining whether an amendment
constitutes a material change or would result in a material cost increase for purposes of this subsection
(b), the determination of the President/Chief Executive Officer will be binding on the Sponsoring
Employer and the Plan.

        (c)     The Senior Vice President, Chief Human Resources Officer, of the Sponsoring Employer,
or the person from time to time performing such function, may amend or modify the Plan at any time to
the extent such amendment or modification is routine, required by law or where circumstances make it
impracticable for President/Chief Executive Officer action.

The Plan may be terminated at any time by the Board of Directors of the Sponsoring Employer.

Limitation on Assignment

Your rights and benefits under the EAP cannot be assigned, sold, transferred, or pledged by you or
reached by your creditors or anyone else, subject to applicable law.

Your Employment

Eligibility for a benefit or the right to a benefit from the EAP is not considered a contract or guarantee of
employment with the Employer. Nothing in the EAP or any benefit communication shall be deemed to
give any person any right to remain in the employ of the Employer or to affect the Employer’s right to

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terminate the employment of any person at any time without cause. The Employer reserves the right to
terminate your employment at any time for any reason.

Your Legal Rights

As a participant in the EAP, you are entitled to certain rights and protection under the Employee
Retirement Income Security Act of 1974 (ERISA).

Your Rights

ERISA provides that all EAP participants shall be entitled to:

   Examine, without charge, at the Plan Administrator’s office and at other specified locations
    (worksites), all documents governing the EAP, including insurance contracts and a copy of the latest
    annual report (Form 5500 Series) filed by the EAP with the U.S. Department of Labor and available
    at the Public Disclosure Room of the Employee Benefit Security Administration.
   Obtain, upon written request to the Plan Administrator, copies of documents governing the operation
    of the EAP, including insurance contracts and copies of the latest annual report (Form 5500 Series)
    and updated summary plan description. The Plan Administrator may make a reasonable charge for
    the copies.

            Send written requests to:

            HR Benefits Department
            500 Eldorado Blvd., Suite 4600
            Broomfield, CO 80021

   Receive a summary of the EAP’s annual financial report. The Plan Administrator is required by law
    to furnish each participant with a copy of this summary annual report.
   Continue health care coverage for yourself, spouse or dependents if there is a loss of coverage under
    the plan as a result of a qualifying event. Continuation coverage is automatically provided under the
    EAP for 36 months after you or a family member would otherwise lose coverage.

Plan Administrator’s Responsibilities Under ERISA

In addition to creating rights for participants, ERISA imposes duties upon the people who are responsible
for the operation of the EAP. The people who operate your EAP, called “fiduciaries” of the EAP, have a
duty to do so prudently and in the interest of you and other participants and beneficiaries. No one,
including your employer, or any other person, may fire you or otherwise discriminate against you in any
way in an attempt to prevent you from obtaining a welfare benefit or exercising your rights under ERISA.

If your claim for a welfare benefit is denied or ignored, in whole or in part, you have a right to know why
this was done, to obtain copies of documents relating to the decision without charge, and to appeal any
denial, all within certain time schedules.

The Steps You Can Take To Enforce Your Rights

Under ERISA, there are steps you can take to enforce the above rights. For instance, if you request a copy
of the EAP documents or the latest annual report from the EAP and do not receive them within 30 days,
you may file suit in a Federal court. In such a case, the court may require the Plan Administrator to
provide the materials and pay you up to $110 a day until you receive the materials, unless the materials
were not sent because of reasons beyond the control of the administrator.

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If you have a claim for benefits which is denied or ignored, in whole or in part, you may file suit in a state
or Federal court. In addition, if you disagree with the EAP’s decision or lack thereof concerning the
qualified status of a medical child support order, you may file suit in Federal court.

If it should happen that plan fiduciaries misuse the EAP’s money, or if you are discriminated against for
asserting your rights, you may seek assistance from the U.S. Department of Labor, or you may file suit in
a Federal court. The court will decide who should pay court costs and legal fees. If you are successful the
court may order the person you have sued to pay these legal costs and fees. If you lose, the court may
order you to pay these costs and fees, for example, if it finds your claim is frivolous.

Questions

If you have any questions about your EAP, you should contact the Plan Administrator. If you have any
questions about this statement or about your rights under ERISA, or if you need assistance in obtaining
documents from the Plan Administrator, you should contact the nearest office of the Employee Benefits
Security Administration, U.S. Department of Labor, listed in your telephone directory or the Division of
Technical Assistance and Inquiries, Employee Benefits Security Administration, U.S. Department of
Labor, 200 Constitution Avenue, N.W., Washington, D.C. 20210. You may also obtain certain
publications about your rights and responsibilities under ERISA by calling the publications hotline of the
Employee Benefits Security Administration.

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