IRS Draft Schedule H for 2011 Form 990

December 23, 2011

Tax-exempt hospitals will be required in 2011 to respond to questions on financial assistance policies, billing and collection practices, emergency medical care and individuals eligible for financial assistance. See IRS Notice 2012-4 dated Dec. 16, 2011. Responding to questions on these issues was optional for 2010 but must now be answered for 2011. The Draft Schedule H and accompanying instructions, issued Dec. 15, can be found on the IRS website.

The draft instructions have been revised to more clearly follow the statutory provision of Section 501(r) of the IRC. Several of the changes relate to billing and collections. Tax-exempt hospitals with January filing due dates will have until March 30, 2012, to file the annual return. This extension applies to organizations with fiscal years ending Aug. 31 or Sept. 30, 2011. It also applies to those organizations that had already received an initial three-month filing extension and now have an extended filing deadline that falls on Jan. 17 or Feb. 15, 2012. Because a majority of tax-exempt hospitals operate on a calendar-year basis, they continue to have a May 15, 2012, filing deadline.

McGuireWoods attorneys are available to assist nonprofit hospitals on the filing of information required by the Internal Revenue Service as a result of the enactment of Section 501(r) and the Patient Protection and Affordable Care Act. Please contact Milton Cerny at mcerny@mcguirewoods.com.

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