Regier predicts Congress will again have to weigh in as the process is tweaked, but with the idea that future standards will come from establishing the baseline, Regier says hospitals must do the difficult, almost fortune-telling work of determining where they might fall on the community benefit bell curve.
"In part that's because organizations have established patterns of community benefit work," Regier says. "Will that be seen as adequate? If not, will that put my tax status in jeopardy? Are there squandered investments here?" he asks rhetorically.
The answer is, no one really knows. But the work doesn't have to rely on predicting future standards, Regier adds. He says generally, hospitals and health systems should remember that IRS form 990, the annual information return, is a public relations document in addition to a regulatory compliance document. See if it passes the "smell test."
"Make sure the story of your organization is told in a complete, authentic way and shows you in the best light that you can," he says. "Secondly, don't rely on your form 990 to tell your story to the community.
You have to get the word out, he says, with a public relations effort. After all, nobody will tell your story for you.