On June 9th, 2011 the IRS announced that it was making Part V.B. of Schedule H of Form 990 optional for the 2010 tax year.
First the IRS asked all tax-exempt hospitals to wait until at least July 1, 2011 to file their 2010 returns instead of the usual May 15 deadline. The stated purpose for the requested delay was to allow the IRS additional time to finalize their forms as well as systems to be better prepared to receive the additional information required to be submitted by charitable hospitals. Now the IRS announces (2011-37) that they are making the newly redesigned Schedule H Part V.B., which focuses on each facility’s (1) community health needs assessment practice, (2) financial assistance policies, (iii) billing and collection practice, and (iv) charges for medical care, optional for the tax year 2010. However, just because it all of a sudden became optional and therefore allows tax-exempt hospitals more time to analyzed the new questions and better prepare for future disclosures, it DOES NOT alleviate the fact that tax-exempt hospitals still must demonstrate how they comply with Section 501(r)’s requirements or otherwise risk losing their tax-exempt status.
It is important to note that only a portion of Schedule H is optional and that all tax-exempt hospitals must still complete section A and C of Part V, in addition to the other parts of Schedule H. The optional section is Part V.B., which specifically deals with Facility Policies and Practices.
Finally, the announcement continues to invite the public to comment on how to improve the clarity and reduce the burden of reporting the information related to these additional requirements.
If you have further questions regarding Schedule H of the Form 990 please contact Monica Langfeldt.