The Internal Revenue Service (IRS) is seeking comments on the CHNA requirements for 501(c)(3) hospitals established by the ACA. In the notice, the IRS describes anticipated regulatory provisions regarding, among other things: hospital organizations required to meet the CHNA requirements; how and when a CHNA is conducted; the community served by a hospital facility; making a CHNA available to the public; how and when an implementation strategy is adopted; excise taxes on failures to meet the CHNA requirements; reporting and documentation requirements; and effective dates. Although the CHNA requirements are not effective until taxable years beginning after March 23, 2012, the IRS is publishing the notice now since some hospital organizations may choose to start conducting CHNAs and developing implementation strategies before the effective date. Comments on the notice are due by September 23, 2011.
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IRS seeks comments on ACA community health needs assessment (CHNA) requirements for tax-exempt hospitals
- Reed Smith LLP
- Debra A. McCurdy
- USA
- July 18 2011
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Sonja Sarantis
Legal Counsel
State Street Bank and Trust Company
