HFMA expressed concerns to the IRS with the agency’s draft redesigned Form 990, used by tax-exempt organizations in reporting charity care. In a Sept. 14 letter to the IRS, HFMA asked that the form and instructions be revised to better capture charity care and bad debt, and that its implementation date be moved back, among other concerns, including appropriate reporting of Medicare payment shortfalls. In the letter, the Association praised the IRS for revising the form and adding a schedule “to reflect today’s complex healthcare environment,” adding, “We are delighted to see that the form and schedule clearly reflect the fact that charitable activity extends well beyond the provision of charity care.”
However, the letter encouraged the IRS to ensure that form 990 and schedules allow healthcare providers to capture clearly all the relevant attributes by which they support the community benefit standard. The Association also recommended that the IRS incorporate HFMA Principles and Practices Board Statement 15 guidance into its instructions for measuring and reporting charity care and bad debt. In addition, it recommended that Schedule H Part II be removed, or that the IRS explain how each set of information requested serves to demonstrate a provider’s exempt-organization compliance.
Finally, HFMA urged an extension to the filing deadline for the revised form and new schedules to tax year 2010. Stating that the revisions the IRS makes to the form are likely to be extensive, “combined with the complexity of the information that the IRS seeks to capture, makes an additional review period prudent.” Read the letter.
