Understanding IRS Proposed Regulations on Community Health Needs Assessments
Tax-exempt hospitals must understand the proposed regulations under Section 501(r) (3) of the Internal Revenue Code. The regulations, issued by the IRS, aim to provide guidelines on how to comply with Community Health Needs Assessments (CHNA) requirements. Furthermore, the proposed regulations also address: Penalties for Non-Compliance, Financial Assistance Policy, Limitation on Charges; and Billing and Collection Requirements.
Join us for this two-hour LIVE webcast as our panel of distinguished leaders and practitioners provide an in-depth discussion of the significant issues included in the proposed regulations, along with training and best practices.
- Overview (Elizabeth)
- Introduction: where did 501(r) come from (ACA purpose)
- Long-running debate over charity care, billing and collection practices, and hospital tax exemption
- State statutes, Scruggs suits, property tax exemption cases, Senate Finance Committee efforts, IRS hospital study
- What are the issues addressed by 501(r)
- High-level overview of 501(r) provisions
- How they address perceived issues: by procedure, not substantive standards
- Status of guidance and regulations
- IRS Notice 2011-52
- Proposed Regulations
- IRS hospital reviews
- Requirements for Community Health Needs Assessments (CHNA)
- Items to include in written report (Susan)
- Differences between IRS Notice 2011-52 and Proposed Regulations
- Implementation Strategy (Marjorie)
- Timing/deadlines (Marjorie)
- Best Practices in Conducting a CHNA (All)
- Dissemination to public
- Effective Date & Transitional Rules (Susan)
- Wait for final rules for details? For CHNA, not always possible
- Penalties (Marjorie)
- Form 990 Schedule H: compliance disclosure vehicle
- A corporation’s partial loss of 501(c)(3) status: what does it mean?
- Other 501(r) provisions/ Strategies for Implementation (Elizabeth)
- Public-facing policies and notices
- Throughout the patient experience: must be right every time
- Practical difficulties in identifying charity care
- Underinsured vs. Uninsured
- Other Affordable Care Act provisions affecting the process
- Presumptive Medicaid eligibility
- Patients with exchange insurance who don’t pay premiums: retroactive coverage lapse
- Coordination between hospital departments and functions
Who Should Attend:
– Directors and Officers of Healthcare Firms
– Hospital Executives (Finance, CFOs, General Counsel and Related)
– Healthcare Organization- Financial Reporting & Accounting
– Executive Directors
– Tax Managers
– Financial Officers
– Senior Officers
– Tax-exempt Auditors
– Tax-exempt Organization Lawyers
– Nonprofit Organization Executives
– Other Related Professionals
Elizabeth M. Mills is a Senior Counsel in Proskauer Rose LLP’s Health Care Department in the Chicago office. Elizabeth’s practice is focused both on health care organizations and tax exemption issues for not-for-profit organizations. She addresses regulatory and transactional issues for all types of health care providers, including hospitals, academic medical centers, large physician group practices, retirement facilities and health maintenance organizations.
In addition, Elizabeth assists tax-exempt organizations in addressing tax compliance and governance issues such as Form 990 reporting, executive compensation, payroll taxes, compliance with supporting organization and private foundation restrictions, new hospital tax exemption requirements, and use of tax-exempt bond-financed property. She has worked extensively with joint ventures between tax-exempt and for-profit entities, the formation and restructuring of integrated health delivery systems, and the tax issues facing exempt organizations in captive insurance and group insurance. Elizabeth is a member of both the Tax Section and the Health Law Section of the American Bar Association and is the Chair of the American Health Lawyers Association Tax and Finance Practice Group.
Elizabeth M. Mills is a Senior Counsel in Proskauer Rose LLP’s Health Care Department in the Chicago office. Elizabeth’s practice …
Susan Clark is a Senior Manager in the Atlanta office of Pershing Yoakley & Associates P.C., who specializes in tax-exempt and healthcare organizations. Her twenty three plus years of experience in public accounting includes all aspects of federal and state income taxation. Susan has specific experience in tax accounting and reporting issues for exempt organizations, including issues and studies related to private inurement, private benefit, unrelated business income tax, and tax-exempt status. She has represented clients before the Internal Revenue Service, including the filing of applications for recognition of exempt status and coordination of the approval process
Susan received her BBA in Accounting (1989) and MAcc in Taxation (1990) from the University of Georgia. She is an active member of the AICPA, Georgia Society of CPAs (GSCPA), and is an advanced member of the Georgia Chapter of Healthcare Financial Management Association (HFMA). She participates as a member of the leadership committees (TEAMS) of HFMA and is a Past President for the Georgia Chapter. In July 2002, she received her certification as a Fellow in HFMA. Susan is currently Chairperson of the Healthcare Section of the GSCPA and has served on the Healthcare Conference Committee Task Force for the society for the past ten years.
Susan has also served as Treasurer for the Gamma Alpha Chapter of Alpha Gamma Delta House Association, Stockbridge Middle School Band Boosters, and Woodland High School Band Boosters Association.
Susan Clark is a Senior Manager in the Atlanta office of Pershing Yoakley & Associates P.C., who specializes in tax-exempt …
Marjorie M. Glover is the Chair of Employee Benefits and Executive Compensation at Chadbourne & Parke LLP. She has experience in all aspects of health care, employee benefits and executive compensation law and has particular expertise in recent health care reform laws including the Patient Protection and Affordable Care Act. Ms. Glover conducts regular seminars and workshops on numerous aspects of health care reform. Ms. Glover has published numerous articles and is a monthly Ask the Expert columnist for Employee Benefit Plan Review magazine. Ms. Glover is recognized in Best Lawyers in America and SuperLawyers and is a member of the American Bar Association, New York State Bar Association and New York City Bar Association.
Ms. Glover may be contacted at firstname.lastname@example.org or 212 408-1016
Marjorie M. Glover is the Chair of Employee Benefits and Executive Compensation at Chadbourne & Parke LLP. She has experience …
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About Proskauer Rose LLP
Proskauer is a leading global law firm with more than 700 highly skilled lawyers active in virtually every major market around the world. Headquartered in New York City since 1875, we also have offices in Beijing, Boca Raton, Boston, Chicago, Hong Kong, London, Los Angeles, New Orleans, Newark, Paris, São Paulo and Washington, DC. Our practice is highly diverse and purposefully interdisciplinary. Consistently recognized as a leader in the legal marketplace for our work ranging from complex, cross-border transactions to high-stakes litigation, we represent many of the world’s leading businesses, financial institutions, investment funds, not-for-profit institutions, governmental entities and other organizations across a wide array of industries, and individuals in their most important deals and other matters.
Pershing Yoakley & Associates was founded in 1983 as a healthcare consulting and accounting firm committed to exceptional client service and strong community involvement. It has approximately 180 staff members and more than 2,200 clients in the U.S. and the Virgin Islands. It is currently ranked by Modern Healthcare as the nation’s 11th largest privately owned healthcare management consulting firm PYA is nationally known for its expertise in healthcare consulting, valuation services, accounting, and litigation support.
About Chadbourne & Parke LLP
A New York-based international law firm, Chadbourne & Parke partners with our clients to promote their business objectives around the world. We offer a full range of legal services and deliver innovative and effective results drawing on our local expertise and relationships in our international platform of 12 offices across 4 continents. Recognized by Chambers Global in 22 practice areas and in 16 regions, we have developed a unique focus on emerging markets and offer significant experience and depth in energy and infrastructure, international disputes, Latin American corporate and finance transactions, corporate M&A, and bankruptcy and financial restructuring.