Form 990, Schedule H Revisions for 2011

From a federal exempt organization tax compliance perspective, since the introduction of the “new” Form 990 a couple of years ago, hospitals have annually been required to complete Schedule H of the Form 990. Unfortunately for hospitals, the Internal Revenue Service has continually tinkered with the Schedule H reporting requirements. The 2011 version of Schedule H reveals that this tinkering has not subsided. Please find following a summary of the more substantial revisions which have been made to the 2011 version of Schedule H:

  • Part V of Schedule H has been expanded to include the requirement that a hospital must list all of its hospital facilities.
  • Part V of Schedule H also now requires disclosure of the hospital’s policies and practices on meeting the new hospital requirements set forth in §501(r) of the Internal Revenue Code.
  • There is now a requirement for a hospital to attach a copy of its most recent audited financial statements to the Form 990 which they are filing.
  • If applicable, a hospital must complete a single Schedule H that combines information from hospital facilities it operates directly with hospital facilities operated by disregarded entities and other hospital facilities operated by joint ventures which the filing hospital is participating in.
  • The requirements that hospitals conduct community health needs assessments are effective for tax years beginning after March 23, 2012.