Compliance - Public Policy

Federal Requirements

IRS Rulemaking

12/18/15 – IRS Guidance on Reporting Housing Improvements on Schedule H — see December 18, 2015 Update
03/10/15 — Revenue Procedure — Guidance regarding correction and disclosure procedures for hospital organizations to follow so that certain failures to meet the requirements of § 501(r) of the Internal Revenue Code will be excused for purposes of § 501(r)(1) and 501(r)(2)(B).
12/31/14 — Final Regulations — Additional Requirements for Charitable Hospitals; Community Health Needs Assessments for Charitable Hospitals; Requirement of a Section 4959 Excise Tax Return and Time for Filing the Return

CHA is the go-to resource for Community Benefit reporting and compliance.

A Guide for Planning & Reporting Community Benefit – Comprehensive guidance on meeting federal requirements for tax-exempt hospitals, including guidelines for reporting on the IRS Form 990 Schedule H as well as valuable information from community benefit and public health professionals about leading practices in community health improvement.
Assessing and Addressing Community Health Needs – Offers practical advice on how hospitals can work with community and public health partners to assess community health needs and develop effective strategies for improving health in our communities.
Assessing and Addressing Community Health Needs: A Summary Of New Requirements and Recommended Practices – A concise overview of new federal requirements for tax-exempt hospitals to conduct community health needs assessments and adopt implementation strategies to address identified needs.
Evaluating Your Community Benefit Impact – Designed to help community benefit leaders take a systematic approach to evaluating and improving their programs and to meet their legal requirements by applying the knowledge and experience of public health program evaluation to community benefit programs.

Hilltop Institute, Community Benefit State Law Profiles — a compilation of each state's community benefit laws and regulations, analyzed in the context of the ACA's community benefit framework

10/19/2020 – GAO Report 20-679 "Hospitals are on the front line of our national response to Coronavirus Disease 2019 (COVID-19), with hospitals across the country working at maximum capacity to treat the sick. The Internal Revenue Service (IRS) and the Department of the Treasury (Treasury) have recognized the promotion of health as a charitable purpose and have specified that nonprofit hospitals are eligible for a tax exemption."
IRS issues extension to Dec. 31, 2020 for CHNAs and Implementation Strategies (July 14, 2020)
Joint Letter to IRS on CHNA Extension (July 7, 2020)
IRS extends due date for CHNAs and Implementation Strategies (April 9, 2020)
CHA Requests Extension of Six Months to File 990 (March 31, 2020)
Charles Rettig Letter to Finance Committee on IRS Section 501(r) (April 11, 2019)
Report to Congress on Private Tax-Exempt, Taxable, and Government-Owned Hospitals (May 2018)
Hatch, Grassley Press IRS for Answers on Nonprofit Hospitals, (Feb. 15, 2018)
Chairman of Senate Judiciary Committee letter to IRS Commissioner calling for greater oversight of tax-exempt hospital billing and collection practices (June 6, 2016)
Chairman’s letter to Senate Judiciary Committee regarding investigation into hospital billing and collection practices (May 24, 2016)

Assessing Reality in Healthcare Financial Information, Healthcare Financial Management Association, April 14, 2023
Healthcare Blame Game: How news outlets mishandled a medical debt study, Healthcare Financial Management Association (April 3, 2023)
Community Catalyst releases report "Hospitals Investing in Health: Community Benefit in Massachusetts," October 2016
Ernst & Young Schedule H Benchmark Report for Tax Years 2009 & 2010, American Hospital Association, April 2013
"Provision of Community Benefits by Tax-Exempt U.S. Hospitals." Gary J. Young, J.D., Ph.D., Chia-Hung Chou, Ph.D., Jeffrey Alexander, Ph.D., Shoou-Yih Daniel Lee, Ph.D., and Eli Raver. New England Journal of Medicine 2013; 368:1519-1527
Beyond Charity Care: Mission Matters for Tax-Exempt Health Care, J. David Seay, Esquire, The Catholic Health Association, 2007
Why Nonprofits Matter in American Medicine: A Policy Brief, Nonprofit Sector Research Fund: Working Paper Series, 2005