In a comment letter to the Internal Revenue Service, the American Hospital Association addressed its concerns over the draft instructions for Form 990 and Schedule H, although it acknowledged the IRS willingness to work with the hospital community. However, the instructions should be improved keeping in mind the original goals of enhancing transparency, promoting compliance and minimizing the burden on filing organizations, the AHA said in the nine-page letter.
The letter focuses in particular on Schedule H, which was designed specifically for not-for-profit hospitals, and the AHA noted that it should be crafted with the idea that many tax-exempt hospitals are small and financially strapped. Among other things, the AHA raised concerns with the definition of subsidized services, community-benefit activities provided by related foundations or tax-exempt organizations within a multihospital system, and in the Form 990 in general the definition of key employee.
The comment period on the draft instructions is open until June 1. The instructions will be part of the redesigned 2008 Form 990released in its final form in December 2007that most tax-exempt organizations must use to report information about their operations. The draft instructions include new tools designed to make it easier for the organization to answer questions and to promote more uniform reporting, including a comprehensive glossary of terms, the IRS said. Other public comments can be viewed here. -- by Cinda Becker