Question: Are Hospital Out-Patient Departments (HOPDs), operated at locations outside of the physical hospital facility, required to be listed on Form 990, Sch H, Part V, Facility Information, Section D Other Health Care facilities that are not licensed, registered, or similarly recognized as a hospital facility? The HOPDs referenced have the same EIN as the hospital.
Recommendation: Because these Hospital Out-Patient Departments (HOPDs) are under the EIN of their parent hospital, the parent should report their community benefit, bad debt, and Medicare expenses in Schedule H, Parts I-III.
If the HOPDs are covered by the license of their parent hospital (or of one of the parent's licensed hospitals), and operate under and pursuant to that license, then they should not be listed in Part V as non-hospital health care facilities. In contrast, if they are not covered by and don't operate under the parent's hospital license, then the parent should report them as non-hospital health care facilities in Schedule H, Part V, regardless of what signage they place on their doors.
If the HOPDs are covered by and operate under the license of their parent's hospital (or of one of the parent's licensed hospitals), then they would be subject to and should comply with 501(r) requirements.
(March 2026)
Please Take Note: The information provided does not constitute legal or tax advice. The material is provided for informational/educational purposes only. Please consult with counsel regarding your organization's particular circumstances.