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IRS releases correction to charitable hospital NPRM

Posted on August 10, 2012 | No Comments

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Today, the Internal Revenue Service, a branch of the Department of Treasury, released a one pager correction to the June notice of proposed rulemaking regarding requirements for charitable hospitals. The NPRM contains proposed regulations that provide guidance regarding the requirements for charitable hospital organizations relating to financial assistance and emergency medical care policies, charges for certain care provided to individuals eligible for financial assistance, and billing and collections. The regulations reflect changes to the law made by the Affordable Care Act (ACA).

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The Affordable Care Act (ACA) mandates that charitable hospitals perform community health needs assessments (CHNA). The proposed rule released by the Internal Revenue Service (IRS) provides guidance on specific components of the CHNA, including related excise tax and reporting obligations, as well as clarification on consequences of failing to meet CHNA and other requirements.
The Department of Treasury's Internal Revenue Service (IRS) released a notice of proposed rulemaking (NPRM) providing guidance regarding the requirements for charitable hospital organizations relating to financial assistance and emergency medical care policies, charges for certain care provided to individuals eligible for financial assistance, and billing and collections. The regulations reflect changes to the law made by the Affordable Care Act (ACA). The regulations will affect charitable 501(r) hospital organizations.
On July 7, 2011, the Treasury Department and the Internal Revenue Service (IRS) published a Notice and Request for Comments on a proposed policy regarding the Affordable Care Act’s new requirements related to tax exempt hospitals’ community health needs assessment (CHNA) obligations. Section 9007 of the Act added new Section 501(r) to the Internal Revenue Code, which delineates a series of statutory requirements, outlined in a previous implementation brief, applicable to nonprofit hospitals that seek tax-exempt status under Section 501(c)(3). The purpose of the Treasury/IRS Notice is to both describe the agencies’ approach to implementing hospital organizations’ CHNA obligations and to invite comments regarding their proposals. The CHNA requirements are effective for taxable years beginning after March 23, 2012. However, the Notice specifies that hospitals currently engaged in conducting CHNA-related activities -- including development and wide publication of a needs assessment and adoption of an implementation strategy -- can rely on the policies contained in the Notice as they move forward.
The Internal Revenue Service (IRS) has issued a notice and request for comment (RFC) on the community health needs assessment requirement, which was established by the Affordable Care Act (ACA). Part of a broader group of new rules and requirements for certain tax-exempt, 501(r) organizations, the community health needs assessment (CHNA) must be done every 3 years by the tax-exempt hospital. The CHNA must be made available to the public and include an "implementation strategy" that focuses on the particular health needs of the communities that these not-for-profit hospitals serve.
On July 7, 2011, the Treasury Department and the Internal Revenue Service (IRS) published a Notice and Request for Comments on a proposed policy regarding the Affordable Care Act’s new requirements related to tax exempt hospitals’ community health needs assessment (CHNA) obligations. Section 9007 of the Act added new Section 501(r) to the Internal Revenue Code, which delineates a series of statutory requirements, outlined in a previous implementation brief, applicable to nonprofit hospitals that seek tax-exempt status under Section 501(c)(3). The purpose of the Treasury/IRS Notice is to both describe the agencies’ approach to implementing hospital organizations’ CHNA obligations and to invite comments regarding their proposals. The CHNA requirements are effective for taxable years beginning after March 23, 2012. However, the Notice specifies that hospitals currently engaged in conducting CHNA-related activities -- including development and wide publication of a needs assessment and adoption of an implementation strategy -- can rely on the policies contained in the Notice as they move forward.
This implementation brief examines the addition of Section 501(r) to the Internal Revenue Code under the Affordable Care Act (ACA), which sets out new requirements for not-for-profit, tax-exempt hospitals.