Thursday, December 20, 2007
IRS Releases Final Form 990, Schedule H
The Internal Revenue Service (IRS) today released a final revised Form 990 and 16 related
Schedules, including a new Schedule H for hospitals. Schedule H represents an important
step in the hospital field’s ongoing efforts to increase transparency by providing a standard
reporting format for many of the benefits that hospitals provide to the communities they serve.
We are heartened that IRS responded to the overwhelming sentiment expressed by 307
members of the House of Representatives, AHA and the overwhelming majority of hospitals
that filed comments that Medicare underpayment and patient bad debt be reported on a
community benefit reporting form. This inclusion, along with additional space for hospitals to
calculate and describe the full value of their programs and activities should promote greater
transparency and community accountability. AHA championed these positions, as well as
successfully urged restoration of community building as a reportable benefit.
We applaud IRS for eliminating some of the burdensome questions that were unrelated to
community benefit, particularly the chart labeled “Billing Information.” Some hospitals had
commented that providing the information requested would require 1,000 or more hours of staff
work. Eliminating that burdensome chart was the centerpiece of the House members’ and
AHA’s letters to IRS.
We also appreciate the one-year filing delay for the most burdensome portions of Schedule H.
While we are concerned that, absent instructions and worksheets for Schedule H, hospitals will
be seriously hampered in their efforts to collect and report the information required, we will
continue to work with IRS to monitor hospitals’ progress and advocate for more time if IRS
delays encumber hospitals’ data collection efforts.
We are disappointed that IRS failed to make questions on joint ventures applicable to the
entire tax-exempt sector. Unlike other parts of the tax-exempt sector that joint venture with
physicians, hospitals are already regulated by several different agencies. Instead, IRS chose
to require hospitals to answer questions on joint ventures on multiple forms, unnecessarily
increasing their filing burden and thereby undermining IRS’ own goal to lessen such burdens.
The revised IRS forms and background materials are available at
http://www.irs.gov/charities/article/0,,id=176613,00.html. Watch for a Member Advisory with
more detailed information about Form 990, Schedule H and other Schedules of concern to the
hospital field after the holidays.
Call (202) 626-2973 if you have problems receiving this fax.