Form 990: Schedule H, “Hospitals” for 2016

Form 990: Schedule H, “Hospitals” for 2016

The IRS has issued draft schedules to the 2016 Form 990, “Return of Organization Exempt from Income Tax” including a draft Schedule H, “Hospitals.”

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Read the draft Schedule H [PDF 344 KB]

Schedule H for 2016

In general, Schedule H must be filed by tax-exempt hospital organizations that operate hospital facilities. The schedule is divided into a number of sections. 

As expected, the changes to Schedule H for 2016 appear to focus on Part V, Section B, where hospital facilities are required to report on compliance with section 501(r). Changes have been anticipated due to the issuance of final regulations under section 501(r) which are generally effective for tax years beginning after December 29, 2015. 

The 2015 Schedule H was not fully aligned with the final regulations. Accordingly, new questions have been added to Schedule H, and some questions have been deleted. Section 501(r) has four major components, relating to:

  • Community health needs assessments and implementation strategies
  • Financial assistance and emergency medical care policies
  • Limitations on charges
  • Billing and collections

The changes to Schedule H for 2016 relate to each of these requirements, except for those that apply to emergency medical care policies. Many of the changes are significant.

KPMG observation

The IRS has not yet released draft instructions for Schedule H, so the full impact of the changes to Schedule H are not known at this time.

The IRS also has yet to release draft 2016 Forms 990 or 990-T, “Exempt Organization Business Income Tax Return”—although drafts of Form 990-EZ, “Short Form Return of Organization Exempt from Income Tax” and Form 990-PF, “Return of Private Foundations” are available. It appears that drafts of all of the 2016 schedules except Schedule A, “Public Charity Status and Public Support” and Schedule J, “Compensation Information” have been released. Use caution in relying on these draft forms and schedules because they are subject to change and cannot be used for filing.

 

For more information, contact the Managing Director-in-Charge of KPMG's Washington National Tax Exempt Organizations Tax group

D. Greg Goller | +1 (703) 286-8391 | greggoller@kpmg.com

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