Treasury anticipates technical correction to effective date of section 6033

Treasury anticipates technical correction, section 6033

A Treasury Department official today announced that Treasury intends to make a technical correction to the section 6033 regulations concerning the effective date.

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At a conference concerning exempt organizations, sponsored by Georgetown University law school, an attorney advisory in Treasury’s Office of Tax Policy, announced that the disconnect between the 6033 regulations and the 2013 Form 990 was a result of an error in the effective date provisions of the 6033 regulations. A technical correction to the regulations is forthcoming—expected to be issued later this year—and will change the effective date to apply to “returns filed for tax years ending on or after December 29, 2014.”

Therefore, 2013 Forms 990 generally will not be required to comply with these regulations.


In relevant part, the regulations require hospitals to: 

  • Attach a copy of the most recently adopted implementation strategy, or otherwise provide a URL where it can be found 
  • Describe the actions taken during the tax year to address the significant health needs identified in its most recently conducted community health needs assessment (CHNA)

Reg. section 1.6033-2(a)(2)(ii)(l)(2), (3).

Under the current regulations, the effective date of these new reporting requirements apply to Forms 990 filed on or after December 29, 2014. The effective date is contained in Reg. section 1.6033-2(k)(4). 

Absent the announced technical correction, the regulations appeared to apply to fiscal year organizations filing 2013 Forms 990 on extension.

While the 2014 Form 990, Schedule H includes appropriate questions to elicit responses to these new requirements (see Schedule H, Part V, Section B, Lines 10 and 11), the 2013 Form 990, Schedule H does not contain such “trigger questions.”


For more information, contact a KPMG tax professional:

D. Greg Goller | +1 (703) 286-8391 |

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