A hospital organization uses Form 990, Schedule H, Hospitals, to provide information on the activities and policies of, and community benefit provided by, its hospital facilities and other non-hospital health care facilities that it operated during the tax year. This includes facilities operated either directly or through disregarded entities or joint ventures.
Hospital organizations report information on policies and practices that are addressed in Section 501(r) on Part V, Section B of Schedule H. The section asks for information concerning each hospital facility’s CHNA, financial assistance, emergency medical care, and billing and collection policies. The hospital organization must complete a separate Section B for each of its hospital facilities or facility reporting groups listed in Section A of Schedule H.
Hospital organizations are also required to submit a copy of their audited financial statements to the IRS. A hospital organization that is required to file Form 990 must attach a copy of its most recent audited financial statements.
Government Hospital Organizations
Section 501(r) requirements apply to all hospital organizations that are (or seek to be) recognized as tax-exempt under Section 501(c)(3), including those that are government hospital organizations. However, government hospital organizations that have previously been recognized as tax-exempt under Section 501(c)(3) but do not wish to comply with the requirements of Section 501(r) may submit a request to voluntarily terminate their Section 501(c)(3) recognition as described in section 3.01(12) of Revenue Procedure 2018-5 (or a successor revenue procedure.)
Revenue Procedure 95-48 provides that certain government entities are relieved from any requirement to file Form 990, Return of Organization Exempt from Income Tax. Accordingly, a government hospital organization (other than a supporting organization described in Section 509(a)(3)) described in Revenue Procedure 95-48 is not required to file a Form 990 (including Schedule H) or include any CHNA-related information with a Form 990. However, to be treated as a Section 501(c)(3) tax-exempt organization, government hospital organizations still must meet all section 501(r) requirements that do not involve disclosure on or with the Form 990, including making their CHNA reports and FAPs widely available on a web site.