As we havepreviously reported, the Affordable Care Act (the "Act") included additional requirements for tax-exempt hospitals to maintain their tax-exempt status; these changes are effective for tax years starting after March 23, 2010, the enactment date of the Act.
These additional requirements included Form 990 reporting obligations for hospitals, which required some adjustments to Form 990 and the corresponding instructions. Late yesterday, the IRS released the 2010 Schedule H and instructions. The IRS also announced that hospitals should not file 2010 Forms 990 requiring Schedule H before July 1, 2011 and granted an automatic three-month extension to all such organizations whose Forms 990 would otherwise be due on or before August 15, 2011.
This announcement does not affect the ultimate due date for such returns, but simply means that the three-month automatic extension will be granted without filing a request. Although the IRS has not yet issued guidance on the new hospital requirements, the new Schedule H and instructions will shed some light on their interpretations.