Nonprofit Hospitals Granted 2010 Filing Extension—Don’t File Early
Tax-exempt hospitals filing Form 990 (and its related Schedule H) with regular due dates prior to August 15, 2011, have been given an automatic three-month extension on their 2010 returns; applications for extensions are not necessary. In fact, the IRS will not accept Form 990 and Schedule H filings before July 1, 2011.
Extra filing time accommodates changes from health care reform
According to the IRS announcement, the delay in the filing season for 501(c)(3) tax-exempt hospitals gives the agency time to make updates to forms and systems necessitated by the health care reform legislation (Patient Protection and Affordable Care Act or PPACA) and allows organizations time to address those changes. The provisions in the health reform law require affected hospitals to meet four specific requirements, which the new forms will reflect:
- Adoption and implementation of written financial assistance and emergency medical care policies
- Limitation on charges for emergency or other medically necessary care
- Compliance with new billing and collection restrictions
- Completion of community health needs assessment at least once every three years (effective for tax years beginning after March 23, 2012)
Revisions to the 2010 Form 990 and Schedule H will incorporate these new reporting requirements and prompt hospitals to describe how their policies and activities comply with the PPACA’s provisions. Many of the updated forms’ questions will be optional for hospital organizations with tax years beginning on or before March 23, 2010. Those with tax years beginning after March 23, 2010, however, will be required to answer all questions in the revised Schedule H.
“Filers will notice questions on the new Schedule H related to the community needs assessment provisions, but don’t panic—those are optional this year,” says Karen Gries, a tax principal with LarsonAllen. “Those particular provisions will be effective for tax years beginning after March 23, 2012, and don’t apply in 2010.”
Financial statements must be attached with Schedule H
Gries reminds hospitals that they are required to attach a copy of their most recently audited financial statements if they file a Schedule H and their organization’s tax year began after March 23, 2010. “This applies regardless of whether the return is filed electronically or on paper,” she says.
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