Notice 2015-46: Charitable hospitals to include a provided list in financial assistance policy

Hospitals include provided list in financial assistance

The IRS today released an advance version of Notice 2015-46 to clarify how a charitable hospital can comply with certain requirements under the section 501(r) regulations.

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Notice 2015-46 [PDF 25 KB] specifically addresses how a charitable hospital organization may comply with the requirement in Reg. section 1.501(r)-4(b)(1)(iii)(F) that a hospital facility include a provider list in its financial assistance policy.

The provider list must include any providers, other than the hospital facility itself, delivering emergency or other medically necessary care in the hospital facility and specify which providers are and are not covered by the hospital facility’s financial assistance policy. 

Notice 2015-46 clarifies a few key points, including: 

  • Guidance as to how providers may be grouped 
  • A clarification that updates to the provider list need not be adopted by an authorized body of the hospital facility 
  • A hospital facility that updates its provider list at least quarterly will be treated as having taken reasonable steps to determine that the list is accurate

KPMG observation

While the notice does not rescind the provider list requirement, as had been advocated by some, it provides clarification concerning some of the trickier issues left unanswered by the regulations, and may be viewed as providing a degree of administrative relief to hospital facilities. 


For more information, contact a KPMG tax professional:

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

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