The IRS released Revenue Procedure 2015-21, which provides correction and disclosure procedures under which failures to meet the additional requirements for charitable hospital organizations added by the Patient Protection and Affordable Care Act (ACA) will be excused. Section 501(r), added by the ACA, establishes requirements for hospitals exempt under Section 501(c)(3). Regulations under Section 501(r) provide that a hospital’s failure to meet some of these requirements shall be excused if the failure is neither willful nor egregious and if the hospital corrects and discloses the failure. Revenue Procedure 2015-21 establishes procedures for such correction and disclosure.
The Revenue Procedure states that charitable hospitals correcting minor omissions and errors that are either inadvertent or due to reasonable cause need not use the correction and disclosure procedures.