In addition to non-profit hospitals needing to do these CHNAs every three years, organizations also need to publicly publish a financial assistance plan for those in the community who may need it. This plan must include the eligibility criteria for financial assistance, and explain how the hospital calculates patient charges and how patients can apply for assistance.
The paperwork for Form 990 and 990 Schedule H is onerous. So much so, that the American Hospital Association recently released a statement responding to the proposed changes to for 990 Schedule H contending that it leads to redundancies. However, as of now, the filing requirements haven't changed and whether the regulation is redundant or not, failing to adhere to the tax provisions can result in a $50,000 penalty.
Most non-profit hospitals and health systems have filed at least one Form 990 and 990 Schedule H, however, now that the Supreme Court has affirmed the constitutionality of the PPACA, more providers will be pursuing accountable care organizations and which changes how providers get paid. Milton Cerny, attorney at McGuireWoods, LLP in Washington, DC, and a former member of the National Office of the IRS in Washington, DC notes this regulation will have an impact on CEO compensation, joint ventures, unrelated business income tax, and ACOs.