Schedule H (Form 990)

Hospitals

Part I

Financial Assistance and Certain Other Community Benefits at Cost

Part I requires reporting of financial assistance policies, the availability of community benefit reports, and the cost of financial assistance and other community benefit activities and programs.

LineQuestionInstructions
Schedule H
Part I
Line 1a

Did the organization have a financial assistance policy (FAP) during the tax year?

If “No,” skip to question 6a

Part I, Line 1. Financial Assistance Policy (FAP).


A FAP, sometimes referred to as a “charity care policy,” is a policy describing how the organization will provide financial assistance at its hospital(s) and other facilities, if any. Financial assistance includes free or discounted health services provided to persons who meet the organization’s criteria for financial assistance and are unable to pay for all or a portion of the services. Financial assistance doesn’t include:


  • Bad debt or uncollectible charges that the organization recorded as revenue but wrote off due to a patient’s failure to pay, or the cost of providing such care to such patients;

  • The difference between the cost of care provided under Medicaid or other means-tested government programs or under Medicare and the revenue derived therefrom;

  • Self-pay or prompt pay discounts; or

  • Contractual adjustments with any third-party payers.
Schedule H
Part I
Line 1b

If “Yes,” was it a written policy?

Part I, Line 1b.

Note: While there are no specific IRS instructions for this line, a “Yes” answer confirms that the Financial Assistance Policy (FAP) mentioned in Line 1a is a formally documented, written policy, which is a key requirement under § 501(r).

Schedule H
Part I
Line 2

Application of FAP across multiple hospital facilities (uniformly or tailored)?

Part I, Line 2. Check only one of the three boxes. “Applied uniformly to all hospitals” means that all of the organization’s hospital facilities use the same FAP. “Applied uniformly to most hospitals” means that the majority of the organization’s hospital facilities use the same FAP. “Generally tailored to individual hospitals” means that the majority of the organization’s hospital facilities use different financial assistance policies. If the organization operates only one hospital facility, check “Applied uniformly to all hospitals.”

Schedule H
Part I
Line 3

Answer the following based on the financial assistance eligibility criteria that applied to the largest number of the organization’s patients during the tax year.

Part I, Line 3. Answer lines 3a, 3b, and 3c, based on the financial assistance eligibility criteria that apply to (1) the largest number of the organization’s patients based on patient contacts or encounters, or (2) if the organization doesn’t operate its own hospital facility, the largest number of patients of a hospital facility operated by a joint venture in which the organization has an ownership interest.

For example, if the organization has two hospital facilities, use the financial assistance eligibility criteria used by the hospital facility that has the most patient contacts or encounters during the tax year.

Schedule H
Part I
Line 3a

Did the organization use federal poverty guidelines (FPG) as a factor in determining eligibility for providing free care?

If “Yes,” indicate which of the following was the FPG family income limit for eligibility for free care:


☐ 100%
☐ 150%
☐ 200%
☐ Other %

Part I, Line 3a. “Federal Poverty Guidelines” (FPG) are the Federal Poverty Guidelines published annually by the U.S. Department of Health and Human Services. If the organization has established a family or household income threshold that a patient must meet or fall below to qualify for free medical care, check the box in the “Yes” column and indicate the specific threshold by checking the appropriate box.

For instance, if a patient’s family or household income must be less than or equal to 250% of FPG for the patient to qualify for free care, then check the box marked “Other” and enter “250%.”

Schedule H
Part I
Line 3b

Did the organization use FPG as a factor in determining eligibility for providing discounted care?

If “Yes,” indicate which of the following was the family income limit for eligibility for discounted care:


☐ 200%
☐ 250%
☐ 300%
☐ 400%
☐ Other %

Part I, Line 3b. If the organization has established a family or household income threshold that a patient must meet or fall below to qualify for discounted medical care, check the box in the “Yes” column and indicate the specific threshold by checking the appropriate box.

Schedule H
Part I
Line 3c

If the organization used factors other than FPG in determining eligibility, describe in Part VI the criteria used for determining eligibility for free or discounted care. Include in the description whether the organization used an asset test or other threshold, regardless of income, as a factor in determining eligibility for free or discounted care.

Part I, Line 3c. If applicable, describe on Part VI of this schedule the other criteria used, such as an asset test or other means test or threshold for free or discounted care. An “asset test” includes a limit on the amount of total or liquid assets that a patient or the patient’s family can own for the patient to qualify for free or discounted care.

Schedule H
Part I
Line 4

Did the organization’s FAP that applied to the largest number of its patients during the tax year provide for free or discounted care to the “medically indigent”?

Part I, Line 4. “Medically indigent” means persons whom the organization has determined are unable to pay some or all of their medical bills because their medical bills exceed a certain percentage of their family or household income or assets (for example, due to catastrophic costs or conditions), even though they have income or assets that otherwise exceed the generally applicable eligibility requirements for free or discounted care under the organization’s FAP.

Schedule H
Part I
Line 5a

Did the organization budget amounts for free or discounted care provided under its FAP during the tax year?

Part I, Line 5a. Answer “Yes” if the organization established or had in place at any time during the tax year an annual or periodic budgeted amount of free or discounted care to be provided under its FAP. If “No,” skip to line 6a.

Schedule H
Part I
Line 5b

If “Yes,” did the organization’s financial assistance expenses exceed the budgeted amount?

Part I, Line 5b. Answer “Yes” if the free or discounted care the organization provided in the applicable period exceeded the budgeted amount of costs or charges for that period. If “No,” skip to line 6a.

Schedule H
Part I
Line 5c

If “Yes” to line 5b, as a result of budget considerations, was the organization unable to provide free or discounted care to a patient who was eligible for free or discounted care?

Part I, Line 5c. Answer “Yes” if the organization denied financial assistance to any patient eligible for free or discounted care under its FAP or under any of its hospital facilities’ financial assistance policies because the organization’s or the facility’s financial assistance budget was exceeded.

Schedule H
Part I
Line 6a

Did the organization prepare a community benefit report during the tax year?

Part I, Line 6. Answer lines 6a and 6b based on the community benefit report that the organization prepared for the organization as a whole during the tax year.


Part I, Line 6a. Answer “Yes” if the organization prepared a written report during the tax year that describes the organization’s programs and services that promote the health of the community or communities served by the organization. If the organization’s community benefit report is contained in a report prepared by a related organization, answer “Yes” and identify the related organization on Part VI, line 1. If “No,” skip to line 7.


Schedule H
Part I
Line 6b

If “Yes,” did the organization make it available to the public?

Part I, Line 6b. Answer “Yes” if the organization made the community benefit report it prepared during the tax year available to the public.


TIP: Examples of how an organization can make its community benefit report available to the public are to post the report on the organization’s website and to make a paper copy of the community health needs assessment (CHNA) report available for public inspection upon request and without charge at the hospital facility.

Line 7 Financial Assistance and Certain Other Community Benefits at Cost

LineQuestionInstructions
Schedule H
Part I
Line 7

Financial Assistance and Certain Other Community Benefits at Cost




Worksheets

Line 7. Complete the following table using the worksheets provided in the Schedule H instructions. Do not submit these worksheets with the Schedule H.


Worksheets and accompanying instructions are provided at the end of the instructions to Schedule H to assist in completing the table in Part I, line 7.


Note: These worksheets are available in the official IRS Instructions for Schedule H. They are not currently reproduced on this website but may be added in the future.

Schedule H
Part I
Lines 7a-k

Financial Assistance and Means-Tested Government Programs


  • 7a. Financial assistance at cost (from Worksheet 1)

  • 7b. Medicaid (from Worksheet 3, column a)

  • 7c. Costs of other means-tested government programs (from Worksheet 3, column b)

  • 7d. Total. Financial assistance and means-tested government programs

Other Benefits

  • 7e. Community health improvement services and community benefit operations (from Worksheet 4)

  • 7f. Health professions education (from Worksheet 5)

  • 7g. Subsidized health services (from Worksheet 6)

  • 7h. Research (from Worksheet 7)

  • 7i. Cash and in-kind contributions for community benefit (from Worksheet 8)

  • 7j. Total. Other benefits

  • 7k. Total. Add lines 7d and 7j

Part I, Lines 7a through 7k.

Enter on the table (lines 7a through 7k), at cost, the organization’s financial assistance (as defined in the instructions for line 1) and certain other community benefits (as defined in the instructions to Worksheets 1-8). Enter on line 7i contributions that the organization restricts, in writing, to one or more of the community benefit activities listed on lines 7a through 7h. Don’t enter such contributions on lines 7a through 7h. To calculate the amounts to be entered on the table, use the worksheets or other equivalent documentation that substantiates the information entered consistent with the methodology used on the worksheets. Don’t include bad debt in these amounts. Bad debt will be entered in Part III.

TIP: If the organization completed worksheets other than on a combined basis (for example, facility by facility, joint venture by joint venture), the organization should combine all information from these worksheets for purposes of entering amounts on the table. Only the portion of each joint venture or partnership that represents the organization’s proportionate share, based on capital interest, can be entered on lines 7a through 7k. See Purpose of Schedule for instructions on aggregation.


Use the organization’s most accurate costing methodology (cost accounting system, cost-to-charge ratio, or other) to calculate the amounts entered on the table. If the organization uses a cost-to-charge ratio, it can use Worksheet 2, Ratio of Patient Care Cost to Charges, for this purpose. See the instructions for Part VI, line 1, regarding an explanation of the costing methodology used to calculate the amounts entered on the table.


If the organization included any costs for a physician clinic as subsidized health services in Part I, line 7g, enter these costs on Part VI. line 1.


If the organization included any bad debt expense on Form 990, Part IX, line 25, but subtracted this bad debt for purposes of calculating the amount entered on line 7, column (f), enter this bad debt expense on Part VI, line 1.


The following are descriptions of the type of information reported in each column of the table.

Schedule H
Part I
Column (a)

(a) Number of activities or programs (optional)

Column (a). “Number of activities or programs” means the number of the organization’s activities or programs conducted during the year that involve the community benefit entered on the line. Enter each activity and program on only one line so that it isn’t counted more than once. Entering in this column is optional.

Schedule H
Part I
Column (b)

(b) Persons served (optional)

Column (b). “Persons served” means the number of patient contacts or encounters in accordance with the filing organization’s records. Persons served can be entered in multiple rows, as services across different categories may be provided to the same patient. Entering in this column is optional.

Schedule H
Part I
Column (c)

(c) Total community benefit expense

Column (c). “Total community benefit expense” means the total gross expense of the activity incurred during the year, calculated by using the pertinent worksheets for each line item. “Total community benefit expense” includes both “direct costs” and “indirect costs.”

Schedule H
Part I
Column (d)

(d) Direct offsetting revenue

Column (d). “Direct offsetting revenue” means revenue from the activity during the year that offsets the total community benefit expense of that activity, as calculated on the worksheets for each line item. “Direct offsetting revenue” also includes restricted grants or contributions that the organization uses to provide a community benefit. It doesn’t include unrestricted grants or contributions.

Schedule H
Part I
Column (e)

(e) Net community benefit expense

Column (e). Don’t enter negative numbers. If the net community benefit expense is less than $0, enter “0.”

Schedule H
Part I
Column (f)

(f) Percent of total expense

Column (f). Don’t enter a negative percent in column (f), if less than 0%,” enter “0”.


TIP: Column (f) “percent of total expense” is based on column (e) “net community benefit expense,” rather than column (c) “total community benefit expense.” Organizations that enter amounts of direct offsetting revenue might also wish to enter total community benefit expense (Part I, line 7, column (c)) as a percentage of total expenses. Although this percentage cannot be entered in Part I, line 7, column(f), it can be entered on Schedule H (Form 990), Part VI, line 1.

Part II

Community Building Activities.
Complete this table if the organization conducted any community building activities during the tax year, and describe in Part VI how its community building activities promoted the health of the communities it serves.

If the organization is filing a group return or has a disregarded entity or an ownership interest in one or more joint ventures, the organization may find it helpful to complete Part II separately for itself and for each disregarded entity, joint venture in which the organization had an ownership interest during the tax year, and group affiliate. The organization should combine the amounts from all such tables, according to the combined instructions in Purpose of Schedule, and include the combined information in Part II.

Part III

Bad Debt, Medicare, & Collection Practices

Part IV

Management Companies and Joint Ventures

Part V

Facility Information

Part VI

Supplemental Information

Use Part VI to provide the narrative explanations required by the following questions, and to supplement responses to other questions on Schedule H (Form 990). In addition, use Part VI to make disclosures described in section 7 of Rev. Proc. 2015-21. Identify the specific part, section, and line number that the response supports, in the order in which they appear on Schedule H (Form 990). Part VI can be duplicated if more space is needed.

Rev. Proc. 2015-21, 2015-13 I.R.B. 817, provides guidance regarding correction and disclosure procedures for hospital organizations to follow so that certain failures to meet the requirements of section 501(r) will be excused for purposes of sections 501(r)(1) and 501(r)(2)(B). Section 7 of the revenue procedure provides that certain information must be disclosed on the organization’s Form 990. Provide this information in Part VI.

LineQuestionLine Instructions:
Schedule H
Part VI
Line 1

Required descriptions. Provide the descriptions required for Part I, lines 3c, 6a, and 7; Part II, and Part III, lines 2, 3, 4, 8, and 9b.

Line 1. Provide the following supplemental information:


Part I, line 3c. If applicable, describe the criteria used for determining eligibility for free or discounted care under the organization’s FAP. Also, describe whether the organization uses an asset test or other threshold, regardless of income, to determine eligibility for free or discounted care.


Part I, line 6a. If the organization’s community benefit report is in a report prepared by a related organization, and not in a separate report prepared by the organization, identify the related organization and list its EIN.


Part I, line 7g. If applicable, describe if the organization included as subsidized health services any costs attributable to a physician clinic, and enter such costs the organization included.


Part I, line 7, column (f). If applicable, enter the bad debt expense included in Form 990, Part IX, line 25, column (A) (but subtracted for purposes of calculating the percentages in this column).


Part I, line 7. Provide an explanation of the costing methodology used to calculate the amounts entered for each line in the table. If a cost accounting system was used, indicate whether the cost accounting system addresses all patient segments (for example, inpatient, outpatient, emergency room, private insurance, Medicaid, Medicare, uninsured, or self-pay). Also, indicate if a cost-to-charge ratio was used for any of the figures in the table. Describe whether this cost-to-charge ratio was derived from Worksheet 2, Ratio of Patient Care Cost-to-Charges, and, if not, what kind of cost-to-charge ratio was used and how it was derived. If some other costing methodology was used besides a cost accounting system, cost-to-charge ratio, or a combination of the two, describe the method used.


Part II. Describe how the organization’s community building activities, as reported in Part II, promote the health of the community or communities the organization serves.


Part III, line 2. Describe the methodology used to determine the amount on Part III, line 2, including how the organization accounts for discounts and payments on patient accounts in determining bad debt expense.


Part III, line 3. Describe the methodology used to determine the amount entered on line 3. Also, describe the rationale, if any, for including any portion of bad debt as community benefit.


Part III, line 4. Provide, if applicable, the text of the footnote to the organization’s financial statements that describes bad debt expense, or enter the page number(s) of the organization’s most recent audited financial statements on which the footnote appears. If the organization’s financial statements include a footnote on these issues that also includes other information, enter only the relevant portions of the footnote. If the organization’s financial statements don’t contain such a footnote, enter that the organization’s financial statements don’t include such a footnote, and explain how the financial statements account for bad debt, if at all.


Part III, line 8. Describe the costing methodology used to determine the Medicare allowable costs entered on Part III, line 6. Describe, if applicable, the extent to which any shortfall entered on Part III, line 7, should be treated as a community benefit, and the rationale for the organization’s position.


Part III, line 9b. If the organization has a written debt collection policy and answered “Yes” to Part III, line 9b, describe the collection practices in the policy that apply to patients who it knows qualify for financial assistance, whether the practices apply specifically to such patients or also cover other types of patients.

Schedule H
Part VI
Line 2

Needs assessment. Describe how the organization assesses the health care needs of the communities it serves, in addition to any CHNAs reported in Part V, Section B.

Line 2. If applicable, describe whether and how the organization assesses the health care needs of the community or communities it serves, in addition to any CHNA entered in Part V, Section B.

Schedule H
Part VI
Line 3

Patient education of eligibility for assistance. Describe how the organization informs and educates patients and persons who may be billed for patient care about their eligibility for assistance under federal, state, or local government programs or under the organization’s FAP.

Line 3. Describe how the organization informs and educates patients and persons who are billed for patient care about their eligibility for assistance under federal, state, or local government programs or under the organization’s FAP. For example, enter whether the organization posts its FAP, or a summary thereof, applications for financial assistance, and financial assistance contact information in admissions areas, emergency rooms, and other areas of the organization’s facilities where eligible patients are likely to be present; provides a copy of the policy, or a summary thereof, applications for financial assistance, and financial assistance contact information to patients as part of the intake process; provides a copy of the policy, or a summary thereof, applications for financial assistance, and financial assistance contact information to patients with discharge materials; includes the policy, or a summary thereof, an application for financial assistance, and financial assistance contact information, in patient bills; or discusses with the patient the availability of various government benefits, such as Medicaid or state programs, and assists the patient with qualification for such programs, where applicable.


Schedule H
Part VI
Line 4

Community information. Describe the community the organization serves, taking into account the geographic area and demographic constituents it serves.

Line 4. Describe the community or communities the organization serves, taking into account the geographic service area(s) (urban, suburban, rural, etc.), the demographics of the community or communities (population, average income, percentages of community residents with incomes below the federal poverty guideline, percentage of the hospital’s and community’s patients who are uninsured or Medicaid recipients, etc.), the number of other hospitals serving the community or communities, and whether one or more federally designated medically underserved areas or populations are present in the community.

Schedule H
Part VI
Line 5

Promotion of community health. Provide any other information important to describing how the organization’s hospital facilities or other health care facilities further its exempt purpose by promoting the health of the community (for example, open medical staff, community board, use of surplus funds, etc.).

Line 5. Provide any other information important to describing how the organization’s hospitals or other health care facilities further its exempt purpose by promoting the health of the community or communities. Your response should include, but need not be limited to, whether:

  • A majority of the organization’s governing body is comprised of persons who reside in the organization’s primary service area who are neither employees nor independent contractors of the organization, nor family members thereof;

  • The organization extends medical staff privileges to all qualified physicians in its community for some or all of its departments or specialties; and

  • How the organization applies surplus funds to improvements in facilities and equipment, patient care, medical training, education, and research.
Schedule H
Part VI
Line 6

Affiliated health care system. If the organization is part of an affiliated health care system, describe the respective roles of the organization and its affiliates in promoting the health of the communities served.

Line 6. If the organization is part of an affiliated health care system, describe the roles of the organization and its affiliates in promoting the health of the communities served by the system. For purposes of this question, an “affiliated health care system” is a system that includes affiliates under common governance or control, or that cooperate in providing health care services to their community or communities.

Schedule H
Part VI
Line 7

State filing of community benefit report. If applicable, identify all states with which the organization, or a related organization, files a community benefit report.

Line 7. Identify all states with which the organization files (or a related organization files on its behalf) a community benefit report. Enter only those states in which the organization’s own community benefit report is filed, either by the organization itself or by a related organization on the organization’s behalf.

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