Section 501(r)’s Financial Assistance, Limitation on Charges, and Billing and Collections Requirements Explored

Nicholas Smith is a manager in the Health Care Consulting Practice of Wipfli LLP, located in the Minneapolis, Minnesota, office. He has significant experience in the health care industry, consulting on a wide variety of issues related to strategy, service line development, facility master planning, and market planning and analysis. Nicholas regularly assists hospitals and health systems to plan and execute community health needs assessments and has published and spoken nationally on the topic. He holds a master’s degree in health care administration from the University of Minnesota. Previously, Nicholas held a position at a Fortune 500 insurance corporation.

Michael G. Bailey is a partner with Foley & Lardner LLP where he is chair of the firm’s Health Care Finance & Restructuring Practice and a member of the firm’s Taxation, Finance & Financial Institutions, and Public Finance Practices. He is also a member of the Health Care Industry and Energy Industry Teams.

Mr. Bailey’s practice focuses on tax-advantaged financing, including tax-exempt financing and tax credit transactions. He also focuses on development of tax compliance policies and procedures, energy tax issues, exempt organization tax issues and other federal and state income tax matters. His tax controversy practice focuses on tax-advantaged financing transactions and exempt organization matters.

Mr. Bailey joined the firm from the Internal Revenue Service, where he served as Counsel to the Assistant Chief Counsel for Financial Institutions and Products. At the IRS he played a key role in numerous projects involving taxation of financial products. He was one of the principal authors of the major federal income tax regulations concerning tax-exempt bonds, including the arbitrage regulations and the private activity bond regulations, and reviewed or authored most other administrative guidance issued by the IRS on tax-exempt bonds from 1990 through 1997, including published rulings, private letter rulings, and technical advice memoranda. He also played a key role in developing the IRS compliance program for tax-exempt bonds. He is a frequent speaker on matters relating to taxation of financial products and transactions.

Mr. Bailey is immediate past chair of the Internal Revenue Service Advisory Committee on Tax Exempt and Government Entities. He is also past chair of the Tax Exempt Financing Committee of the Section of Taxation of the American Bar Association.