Non-profit hospitals should take notice of changes the IRS has made in its Draft 2014 Form 990 Schedule H. The IRS is trying to make its Schedule H more closely mirror requirements in the Affordable Care Act, section 501(r). In particular, the updated draft form requires more commentary so that the IRS can get quicker visibility into whether hospitals are living up to the true purpose of the Community Health Needs Assessment (CHNA) regulations. Here are some key points to note in the updated form:
More specificity in check-the-box questions
501(r) details that a hospital must adopt an implementation strategy to meet the needs identified in the CHNA by the end of the same taxable year in which the CHNA was conducted. The Draft Schedule H now asks for the tax year in which the CHNA was adopted and either a link to or a copy of the implementation strategy. This updated draft also provides clarity to the IRS about allowable exceptions that might be missed in a simple review of previous forms.