highlights of the redesigned form 990 part ii: … · 2014-09-03 · highlights of the redesigned...

HIGHLIGHTS OF THE REDESIGNED HIGHLIGHTS OF THE REDESIGNED FORM 990FORM 990

PART II: OPERATIONAL PART II: OPERATIONAL ASSESSMENT FOR CORPORATE ASSESSMENT FOR CORPORATE

COMPLIANCE PROGRAMSCOMPLIANCE PROGRAMSSeptember 28, 2007September 28, 2007

Michael C. HemsleyMichael C. Hemsley John R. WashlickJohn R. Washlick

Catholic Health EastCatholic Health East Cozen OCozen O’’ConnorConnor

Vice President for Legal ServicesVice President for Legal Services MemberMember

and General Counseland General Counsel [email protected]@cozen.com

[email protected]@che.org 215215--665665--21342134

610610--355355--20472047

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INTRODUCTIONINTRODUCTIONINTRODUCTIONINTRODUCTIONINTRODUCTIONINTRODUCTIONINTRODUCTIONINTRODUCTION

�� Impact of Form 990 on Corporate ComplianceImpact of Form 990 on Corporate Compliance

�� Why COs need to be aware and be involvedWhy COs need to be aware and be involved

�� How to engage?How to engage?

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INTRODUCTIONINTRODUCTIONINTRODUCTIONINTRODUCTIONINTRODUCTIONINTRODUCTIONINTRODUCTIONINTRODUCTION

�� DonDon’’t panic t panic -- Engage with management, especially Engage with management, especially finance to understand issues and how these issues and finance to understand issues and how these issues and compliance exposures can be addressed utilizing compliance exposures can be addressed utilizing compliance program processescompliance program processes�� Not new, just greater level of disclosureNot new, just greater level of disclosure�� COs not expected to be tax expertsCOs not expected to be tax experts

�� Have a general awareness and understanding of issues Have a general awareness and understanding of issues –– Can you answer board questions?Can you answer board questions?

�� What level? What level? Identify Identify ““subject matter expertssubject matter experts”” within within or for the organization in this areaor for the organization in this area

�� Form 990 Form 990 –– Information gathered could lead to Information gathered could lead to future rulings, regulations or enforcement actionfuture rulings, regulations or enforcement action

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BACK TO BASICSBACK TO BASICSBACK TO BASICSBACK TO BASICSBACK TO BASICSBACK TO BASICSBACK TO BASICSBACK TO BASICS

�� Scope of Corporate Compliance Scope of Corporate Compliance –– Federal Sentencing Federal Sentencing GuidelinesGuidelines

�� Basis for Federal Tax Exemption Basis for Federal Tax Exemption –– Community Community Benefit (Rev. Rul. 69Benefit (Rev. Rul. 69--545)545)

�� Preservation of Federal Tax ExemptionPreservation of Federal Tax Exemption

�� Form 990 Form 990 –– Detailed Information About Detailed Information About WhatWhatWhatWhatWhatWhatWhatWhat the the Organization is Doing and Organization is Doing and HowHowHowHowHowHowHowHow It is Doing It.It is Doing It.

�� Form 990 Overlap and Interplay with Fraud and Form 990 Overlap and Interplay with Fraud and Abuse IssuesAbuse Issues

�� Best PracticesBest Practices

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DRUMBEAT ALONG THE DRUMBEAT ALONG THE DRUMBEAT ALONG THE DRUMBEAT ALONG THE DRUMBEAT ALONG THE DRUMBEAT ALONG THE DRUMBEAT ALONG THE DRUMBEAT ALONG THE POTOMACPOTOMACPOTOMACPOTOMACPOTOMACPOTOMACPOTOMACPOTOMAC

Message: Increased disclosures and public access to 990s Message: Increased disclosures and public access to 990s Message: Increased disclosures and public access to 990s Message: Increased disclosures and public access to 990s Message: Increased disclosures and public access to 990s Message: Increased disclosures and public access to 990s Message: Increased disclosures and public access to 990s Message: Increased disclosures and public access to 990s increases likelihood of governmental and public increases likelihood of governmental and public increases likelihood of governmental and public increases likelihood of governmental and public increases likelihood of governmental and public increases likelihood of governmental and public increases likelihood of governmental and public increases likelihood of governmental and public scrutiny, regulation and enforcement effortsscrutiny, regulation and enforcement effortsscrutiny, regulation and enforcement effortsscrutiny, regulation and enforcement effortsscrutiny, regulation and enforcement effortsscrutiny, regulation and enforcement effortsscrutiny, regulation and enforcement effortsscrutiny, regulation and enforcement efforts

�� JULY 2003 HOUSE E&C COMMITTEE ON BILLING AND JULY 2003 HOUSE E&C COMMITTEE ON BILLING AND JULY 2003 HOUSE E&C COMMITTEE ON BILLING AND JULY 2003 HOUSE E&C COMMITTEE ON BILLING AND JULY 2003 HOUSE E&C COMMITTEE ON BILLING AND JULY 2003 HOUSE E&C COMMITTEE ON BILLING AND JULY 2003 HOUSE E&C COMMITTEE ON BILLING AND JULY 2003 HOUSE E&C COMMITTEE ON BILLING AND COLLECTION PRACTICESCOLLECTION PRACTICESCOLLECTION PRACTICESCOLLECTION PRACTICESCOLLECTION PRACTICESCOLLECTION PRACTICESCOLLECTION PRACTICESCOLLECTION PRACTICES

�� MAY 2005 SENATE FINANCE COMMITTEE INQUIRY ON HOSPITAL MAY 2005 SENATE FINANCE COMMITTEE INQUIRY ON HOSPITAL MAY 2005 SENATE FINANCE COMMITTEE INQUIRY ON HOSPITAL MAY 2005 SENATE FINANCE COMMITTEE INQUIRY ON HOSPITAL MAY 2005 SENATE FINANCE COMMITTEE INQUIRY ON HOSPITAL MAY 2005 SENATE FINANCE COMMITTEE INQUIRY ON HOSPITAL MAY 2005 SENATE FINANCE COMMITTEE INQUIRY ON HOSPITAL MAY 2005 SENATE FINANCE COMMITTEE INQUIRY ON HOSPITAL ACCOUNTING FOR CHARITABLE ACTIVITIESACCOUNTING FOR CHARITABLE ACTIVITIESACCOUNTING FOR CHARITABLE ACTIVITIESACCOUNTING FOR CHARITABLE ACTIVITIESACCOUNTING FOR CHARITABLE ACTIVITIESACCOUNTING FOR CHARITABLE ACTIVITIESACCOUNTING FOR CHARITABLE ACTIVITIESACCOUNTING FOR CHARITABLE ACTIVITIES

�� MARCH 2006 GAO SURVEY OF NONPROFIT HOSPITALS ON MARCH 2006 GAO SURVEY OF NONPROFIT HOSPITALS ON MARCH 2006 GAO SURVEY OF NONPROFIT HOSPITALS ON MARCH 2006 GAO SURVEY OF NONPROFIT HOSPITALS ON MARCH 2006 GAO SURVEY OF NONPROFIT HOSPITALS ON MARCH 2006 GAO SURVEY OF NONPROFIT HOSPITALS ON MARCH 2006 GAO SURVEY OF NONPROFIT HOSPITALS ON MARCH 2006 GAO SURVEY OF NONPROFIT HOSPITALS ON EXECUTIVE COMPENSATION POLICIES AND PRACTICESEXECUTIVE COMPENSATION POLICIES AND PRACTICESEXECUTIVE COMPENSATION POLICIES AND PRACTICESEXECUTIVE COMPENSATION POLICIES AND PRACTICESEXECUTIVE COMPENSATION POLICIES AND PRACTICESEXECUTIVE COMPENSATION POLICIES AND PRACTICESEXECUTIVE COMPENSATION POLICIES AND PRACTICESEXECUTIVE COMPENSATION POLICIES AND PRACTICES

�� MAY 2006 IRS COMPLIANCE CHECK QUESTIONNAIRE FOR TAXMAY 2006 IRS COMPLIANCE CHECK QUESTIONNAIRE FOR TAXMAY 2006 IRS COMPLIANCE CHECK QUESTIONNAIRE FOR TAXMAY 2006 IRS COMPLIANCE CHECK QUESTIONNAIRE FOR TAXMAY 2006 IRS COMPLIANCE CHECK QUESTIONNAIRE FOR TAXMAY 2006 IRS COMPLIANCE CHECK QUESTIONNAIRE FOR TAXMAY 2006 IRS COMPLIANCE CHECK QUESTIONNAIRE FOR TAXMAY 2006 IRS COMPLIANCE CHECK QUESTIONNAIRE FOR TAX--------EXEMPT HOSPITALS AND INTERIM REPORTEXEMPT HOSPITALS AND INTERIM REPORTEXEMPT HOSPITALS AND INTERIM REPORTEXEMPT HOSPITALS AND INTERIM REPORTEXEMPT HOSPITALS AND INTERIM REPORTEXEMPT HOSPITALS AND INTERIM REPORTEXEMPT HOSPITALS AND INTERIM REPORTEXEMPT HOSPITALS AND INTERIM REPORT

�� FEBRUARY 2007 IRS GOOD GOVERNANCE PRACTICES FEBRUARY 2007 IRS GOOD GOVERNANCE PRACTICES FEBRUARY 2007 IRS GOOD GOVERNANCE PRACTICES FEBRUARY 2007 IRS GOOD GOVERNANCE PRACTICES FEBRUARY 2007 IRS GOOD GOVERNANCE PRACTICES FEBRUARY 2007 IRS GOOD GOVERNANCE PRACTICES FEBRUARY 2007 IRS GOOD GOVERNANCE PRACTICES FEBRUARY 2007 IRS GOOD GOVERNANCE PRACTICES DISCUSSION DRAFTDISCUSSION DRAFTDISCUSSION DRAFTDISCUSSION DRAFTDISCUSSION DRAFTDISCUSSION DRAFTDISCUSSION DRAFTDISCUSSION DRAFT

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DRUMBEAT ALONG THE DRUMBEAT ALONG THE DRUMBEAT ALONG THE DRUMBEAT ALONG THE DRUMBEAT ALONG THE DRUMBEAT ALONG THE DRUMBEAT ALONG THE DRUMBEAT ALONG THE POTOMACPOTOMACPOTOMACPOTOMACPOTOMACPOTOMACPOTOMACPOTOMAC

�� JUNE 2007 IRS REVENUE RULING 2007JUNE 2007 IRS REVENUE RULING 2007JUNE 2007 IRS REVENUE RULING 2007JUNE 2007 IRS REVENUE RULING 2007JUNE 2007 IRS REVENUE RULING 2007JUNE 2007 IRS REVENUE RULING 2007JUNE 2007 IRS REVENUE RULING 2007JUNE 2007 IRS REVENUE RULING 2007--------41 RE: PROHIBITED 41 RE: PROHIBITED 41 RE: PROHIBITED 41 RE: PROHIBITED 41 RE: PROHIBITED 41 RE: PROHIBITED 41 RE: PROHIBITED 41 RE: PROHIBITED POLITICAL ACTIVITIES FOR TAX EXEMPT ORGANIZATIONSPOLITICAL ACTIVITIES FOR TAX EXEMPT ORGANIZATIONSPOLITICAL ACTIVITIES FOR TAX EXEMPT ORGANIZATIONSPOLITICAL ACTIVITIES FOR TAX EXEMPT ORGANIZATIONSPOLITICAL ACTIVITIES FOR TAX EXEMPT ORGANIZATIONSPOLITICAL ACTIVITIES FOR TAX EXEMPT ORGANIZATIONSPOLITICAL ACTIVITIES FOR TAX EXEMPT ORGANIZATIONSPOLITICAL ACTIVITIES FOR TAX EXEMPT ORGANIZATIONS

�� JUNE 2007 IRS DRAFT REDESIGN FORM 990JUNE 2007 IRS DRAFT REDESIGN FORM 990JUNE 2007 IRS DRAFT REDESIGN FORM 990JUNE 2007 IRS DRAFT REDESIGN FORM 990JUNE 2007 IRS DRAFT REDESIGN FORM 990JUNE 2007 IRS DRAFT REDESIGN FORM 990JUNE 2007 IRS DRAFT REDESIGN FORM 990JUNE 2007 IRS DRAFT REDESIGN FORM 990

�� JULY 17, 2007 SENATE FINANCE COMMITTEE MINORITY STAFF JULY 17, 2007 SENATE FINANCE COMMITTEE MINORITY STAFF JULY 17, 2007 SENATE FINANCE COMMITTEE MINORITY STAFF JULY 17, 2007 SENATE FINANCE COMMITTEE MINORITY STAFF JULY 17, 2007 SENATE FINANCE COMMITTEE MINORITY STAFF JULY 17, 2007 SENATE FINANCE COMMITTEE MINORITY STAFF JULY 17, 2007 SENATE FINANCE COMMITTEE MINORITY STAFF JULY 17, 2007 SENATE FINANCE COMMITTEE MINORITY STAFF DISCUSSION DRAFT ON NONPROFIT HOSPITAL REFORM DISCUSSION DRAFT ON NONPROFIT HOSPITAL REFORM DISCUSSION DRAFT ON NONPROFIT HOSPITAL REFORM DISCUSSION DRAFT ON NONPROFIT HOSPITAL REFORM DISCUSSION DRAFT ON NONPROFIT HOSPITAL REFORM DISCUSSION DRAFT ON NONPROFIT HOSPITAL REFORM DISCUSSION DRAFT ON NONPROFIT HOSPITAL REFORM DISCUSSION DRAFT ON NONPROFIT HOSPITAL REFORM PROPOSALSPROPOSALSPROPOSALSPROPOSALSPROPOSALSPROPOSALSPROPOSALSPROPOSALS

�� JULY 24, 2007 HOUSE WAYS AND MEANS OVERSIGHT JULY 24, 2007 HOUSE WAYS AND MEANS OVERSIGHT JULY 24, 2007 HOUSE WAYS AND MEANS OVERSIGHT JULY 24, 2007 HOUSE WAYS AND MEANS OVERSIGHT JULY 24, 2007 HOUSE WAYS AND MEANS OVERSIGHT JULY 24, 2007 HOUSE WAYS AND MEANS OVERSIGHT JULY 24, 2007 HOUSE WAYS AND MEANS OVERSIGHT JULY 24, 2007 HOUSE WAYS AND MEANS OVERSIGHT SUBCOMMITTEE HEARING REGARDING 501(C)(3) TAX EXEMPT SUBCOMMITTEE HEARING REGARDING 501(C)(3) TAX EXEMPT SUBCOMMITTEE HEARING REGARDING 501(C)(3) TAX EXEMPT SUBCOMMITTEE HEARING REGARDING 501(C)(3) TAX EXEMPT SUBCOMMITTEE HEARING REGARDING 501(C)(3) TAX EXEMPT SUBCOMMITTEE HEARING REGARDING 501(C)(3) TAX EXEMPT SUBCOMMITTEE HEARING REGARDING 501(C)(3) TAX EXEMPT SUBCOMMITTEE HEARING REGARDING 501(C)(3) TAX EXEMPT ORGANIZATIONSORGANIZATIONSORGANIZATIONSORGANIZATIONSORGANIZATIONSORGANIZATIONSORGANIZATIONSORGANIZATIONS

�� AUGUST 27, 2007 IRS TAXAUGUST 27, 2007 IRS TAXAUGUST 27, 2007 IRS TAXAUGUST 27, 2007 IRS TAXAUGUST 27, 2007 IRS TAXAUGUST 27, 2007 IRS TAXAUGUST 27, 2007 IRS TAXAUGUST 27, 2007 IRS TAX--------EXEMPT BOND COMPLIANCE SURVEYEXEMPT BOND COMPLIANCE SURVEYEXEMPT BOND COMPLIANCE SURVEYEXEMPT BOND COMPLIANCE SURVEYEXEMPT BOND COMPLIANCE SURVEYEXEMPT BOND COMPLIANCE SURVEYEXEMPT BOND COMPLIANCE SURVEYEXEMPT BOND COMPLIANCE SURVEY

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ROLE OF CO RELATIVE TO TAX ROLE OF CO RELATIVE TO TAX ROLE OF CO RELATIVE TO TAX ROLE OF CO RELATIVE TO TAX ROLE OF CO RELATIVE TO TAX ROLE OF CO RELATIVE TO TAX ROLE OF CO RELATIVE TO TAX ROLE OF CO RELATIVE TO TAX COMPLIANCECOMPLIANCECOMPLIANCECOMPLIANCECOMPLIANCECOMPLIANCECOMPLIANCECOMPLIANCE

�� Gain an understanding of how the exempt Gain an understanding of how the exempt organization is organized to address tax organization is organized to address tax compliance, (i.e., persons/departments compliance, (i.e., persons/departments responsible; identify existing programs, responsible; identify existing programs, processes and/or practices to reasonably assure processes and/or practices to reasonably assure compliance);compliance);

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ROLE OF CO RELATIVE TO TAX ROLE OF CO RELATIVE TO TAX ROLE OF CO RELATIVE TO TAX ROLE OF CO RELATIVE TO TAX ROLE OF CO RELATIVE TO TAX ROLE OF CO RELATIVE TO TAX ROLE OF CO RELATIVE TO TAX ROLE OF CO RELATIVE TO TAX COMPLIANCECOMPLIANCECOMPLIANCECOMPLIANCECOMPLIANCECOMPLIANCECOMPLIANCECOMPLIANCE

�� Determine the educational needs and audiences Determine the educational needs and audiences for relevant topics; for relevant topics;

�� Note: Form 990 is not directed solely at Note: Form 990 is not directed solely at Health Care Organizations.Health Care Organizations.

�� Focus: Understand:Focus: Understand:�� The issue generallyThe issue generally

�� Who is responsibleWho is responsible

�� Processes to support complianceProcesses to support compliance

�� Identification and Remediation of any problematic Identification and Remediation of any problematic practicespractices

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REVISED FORM 990: SECTIONAL REVISED FORM 990: SECTIONAL REVISED FORM 990: SECTIONAL REVISED FORM 990: SECTIONAL REVISED FORM 990: SECTIONAL REVISED FORM 990: SECTIONAL REVISED FORM 990: SECTIONAL REVISED FORM 990: SECTIONAL ANALYSISANALYSISANALYSISANALYSISANALYSISANALYSISANALYSISANALYSIS

�� Glossary, Definitions of NoteGlossary, Definitions of Note

�� Audit CommitteeAudit Committee

�� Conflicts of interest policyConflicts of interest policy

�� ControlControl

�� Disqualified PersonDisqualified Person

�� Key EmployeeKey Employee

�� Independent Member of Governing BodyIndependent Member of Governing Body

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�� Glossary, Definitions of Note (contGlossary, Definitions of Note (cont’’d)d)

�� Excess Benefit TransactionExcess Benefit Transaction

�� Excess Benefit Transaction, Donor Advised FundsExcess Benefit Transaction, Donor Advised Funds

�� Excess Benefit Transaction, Supporting Excess Benefit Transaction, Supporting OrganizationOrganization

�� Document Retention and Destruction PolicyDocument Retention and Destruction Policy

�� OfficerOfficer

�� Related OrganizationRelated Organization

�� Whistleblower policyWhistleblower policy

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�� Part I: Summary Part I: Summary

�� Information reported in the return and all required Information reported in the return and all required schedules schedules

�� FrontFront--page snapshot of key information about the page snapshot of key information about the organization, e.g. number of independent Board organization, e.g. number of independent Board members, highest executive compensation paid members, highest executive compensation paid

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�� Part II: Compensation and Other Financial Part II: Compensation and Other Financial Arrangements with Officers, Directors, Trustees, Arrangements with Officers, Directors, Trustees, Key Employees, Highly Compensated Key Employees, Highly Compensated Employees and Independent ContractorsEmployees and Independent Contractors

�� Section A: More extensive; see Glossary for Section A: More extensive; see Glossary for definitions;definitions;

�� Section B: Questions raise the issue of compliance Section B: Questions raise the issue of compliance with the IRS intermediate sanctions rules for with the IRS intermediate sanctions rules for exempt organizations (Section 4958 of the Internal exempt organizations (Section 4958 of the Internal Revenue Code). Revenue Code).

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�� Part III:Part III: Statements Regarding Governance, Statements Regarding Governance, Management, and Financial ReportingManagement, and Financial Reporting

�� Advancing good governance principles, accountability, Advancing good governance principles, accountability, and transparencyand transparency

�� L3 L3 --conflict of interest policyconflict of interest policy

�� L4 L4 --whistleblower policy whistleblower policy

�� L5L5--document retention and destruction policy;document retention and destruction policy;

�� L6L6--Board Minutes; Board Minutes;

�� L11L11-- Public Access to 990s; (See 26 CFR 301.6104(d)) Public Access to 990s; (See 26 CFR 301.6104(d))

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�� Part IV:Part IV: Statement of Revenue Statement of Revenue

�� L1cL1c--Fundraising eventsFundraising events

�� L1dL1d--Related OrganizationsRelated Organizations

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�� Part V: Statement of Functional ExpensesPart V: Statement of Functional Expenses

�� Compliance with Intermediate Sanctions Compliance with Intermediate Sanctions -- §§ 49584958

�� L5 L5 –– Compensation to current officers, directors and key Compensation to current officers, directors and key employeesemployees

�� L6 L6 –– Compensation to disqualified persons (Not on L5) Compensation to disqualified persons (Not on L5) and substantial contributorsand substantial contributors

�� Query: Does the organization have Policies and Procedures Query: Does the organization have Policies and Procedures to comply with the Rebuttable Presumption Safe Harbor?to comply with the Rebuttable Presumption Safe Harbor?

�� IndependenceIndependence

�� Comparative DataComparative Data

�� Contemporaneous DocumentationContemporaneous Documentation

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�� L11dL11d--LobbyingLobbying

�� Determine nature and scopeDetermine nature and scope

�� Compliance with Federal and/or State Registration Compliance with Federal and/or State Registration Requirements and limitations (See generally Requirements and limitations (See generally www.irs.gov/charities/article/0,,id=141537,00.html)www.irs.gov/charities/article/0,,id=141537,00.html)

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�� Part VI:Part VI: Balance SheetBalance Sheet

�� L5 L5 –– Receivables from current officers, directors, Receivables from current officers, directors, trustees, key employees and related parties. trustees, key employees and related parties. (Schedule L)(Schedule L)

�� L6 L6 –– Receivables from Other Disqualified Persons Receivables from Other Disqualified Persons (See Definition in Glossary) and Section (See Definition in Glossary) and Section

4958 (c)(3)(B) (Schedule L)4958 (c)(3)(B) (Schedule L)

�� L21 L21 -- TaxTax--Exempt Bond Liability (Schedule K) Exempt Bond Liability (Schedule K)

�� L23 L23 –– Payables to Officers, Directors and Trustees, Payables to Officers, Directors and Trustees, or Key Employees (Schedule L)or Key Employees (Schedule L)

18


�� Part VII: Statements Regarding General Part VII: Statements Regarding General Activities Activities –– A Trap for the UnwaryA Trap for the Unwary

�� L 1a)L 1a) Activities outside the U.S. Activities outside the U.S. –– Impact on Impact on Border StatesBorder States

�� L 6 Tax Exempt BondsL 6 Tax Exempt Bonds

(See IRS Tax Exempt Bond Financings Compliance (See IRS Tax Exempt Bond Financings Compliance Check QCheck Q’’s, August 2007)s, August 2007)

19


�� Part VII: Statements Regarding General Part VII: Statements Regarding General Activities (contActivities (cont’’d)d)�� L 8a Exempt Activities through Partnerships (Rev. L 8a Exempt Activities through Partnerships (Rev.

Rul. 98Rul. 98--15; Redlands Surgical Services; St. David15; Redlands Surgical Services; St. David’’s s Health Care System, Inc.Health Care System, Inc.

�� L 9 Hospitals L 9 Hospitals -- Schedule HSchedule H

�� L 11L 11 Policies to review investment or Policies to review investment or participation in participation in …… joint venturesjoint ventures

�� L 12L 12 Policy(s) relating to protection of exempt Policy(s) relating to protection of exempt status in transactions with related organizations status in transactions with related organizations (see p. 42 of Instructions)(see p. 42 of Instructions)

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�� Part VIII: Statements Regarding Other IRS Part VIII: Statements Regarding Other IRS FilingsFilings

�� L 1 & 2: Lobbying and Political Campaign L 1 & 2: Lobbying and Political Campaign Activities Activities

�� Political campaign activities on behalf of a candidate for Political campaign activities on behalf of a candidate for public office is prohibitedpublic office is prohibited

�� Does the organization have a policy banning internal Does the organization have a policy banning internal and external communications by employees regarding and external communications by employees regarding political activities?political activities?

�� L 5: Excess Benefit Transactions (see 26 CFR L 5: Excess Benefit Transactions (see 26 CFR 53.495853.4958--IT) IT) –– SelfSelf--DisclosureDisclosure

21


�� Part IX:Part IX: Statement of Program Service Statement of Program Service Accomplishments Accomplishments

�� A document of much more serious importance A document of much more serious importance and attention than in the past in justifying and attention than in the past in justifying continued tax exemption.continued tax exemption.

�� Opportunity to tell your storyOpportunity to tell your story

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SUPPLEMENTAL SCHEDULESSUPPLEMENTAL SCHEDULESSUPPLEMENTAL SCHEDULESSUPPLEMENTAL SCHEDULESSUPPLEMENTAL SCHEDULESSUPPLEMENTAL SCHEDULESSUPPLEMENTAL SCHEDULESSUPPLEMENTAL SCHEDULES

�� ScheduleSchedule •• DescriptionDescription�� AA •• Public Charity StatusPublic Charity Status

�� BB •• ContributionsContributions

�� CC •• Political & Lobbying ActivitiesPolitical & Lobbying Activities

�� DD •• Financial Statement (including FIN 48)Financial Statement (including FIN 48)

�� EE •• SchoolsSchools

�� FF •• Foreign ActivitiesForeign Activities

�� GG •• Fundraising & GamingFundraising & Gaming

�� HH •• HospitalsHospitals

�� II •• GrantsGrants

�� JJ •• CompensationCompensation

�� KK •• TaxTax--exempt Bondsexempt Bonds

�� LL •• LoansLoans

�� MM •• NonNon--cash Contributionscash Contributions

�� NN •• Termination Significant Disposition AssetsTermination Significant Disposition Assets

�� RR •• Related OrganizationsRelated Organizations

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SCHEDULES TO REVISED SCHEDULES TO REVISED SCHEDULES TO REVISED SCHEDULES TO REVISED SCHEDULES TO REVISED SCHEDULES TO REVISED SCHEDULES TO REVISED SCHEDULES TO REVISED FORM 990FORM 990FORM 990FORM 990FORM 990FORM 990FORM 990FORM 990

�� Schedule C:Schedule C: Political Campaign and Political Campaign and Lobbying ActivitiesLobbying Activities

�� (See Glossary, Rev. Rule 2007(See Glossary, Rev. Rule 2007--41 and 2006 IRS 41 and 2006 IRS Compliance Initiative)Compliance Initiative)

�� Relevant State laws?Relevant State laws?

�� Internet Policies?Internet Policies?

�� Has the organization ever made a Section 501(b) Has the organization ever made a Section 501(b) election? (IRS Form 5768)election? (IRS Form 5768)

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�� Schedule F: Statement of Activities Outside of Schedule F: Statement of Activities Outside of U.S.U.S.

�� Issue of greater significance in Border states Issue of greater significance in Border states

�� Mission Activities?Mission Activities?

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�� Schedule G: Supplemental Information Schedule G: Supplemental Information Regarding Fundraising ActivitiesRegarding Fundraising Activities

�� L3 L3 -- listing all jurisdictions in which the listing all jurisdictions in which the organization is authorized to solicit. (Compare organization is authorized to solicit. (Compare with states where it actually solicits). See The with states where it actually solicits). See The Unified Registration Statement Multi=State Filter Unified Registration Statement Multi=State Filter Project (Project (http://www.multishtatefiling.orghttp://www.multishtatefiling.org))

�� Has the organization properly registered with each Has the organization properly registered with each applicable state?applicable state?

26


�� Schedule H: HospitalSchedule H: Hospital

�� Part I:Part I: Community BenefitCommunity Benefit

Charity Care Policies and DataCharity Care Policies and Data

�� Part II: Billing & Collection PracticesPart II: Billing & Collection Practices

�� Policy; Scope & CompliancePolicy; Scope & Compliance

�� State Consumer Protection LawsState Consumer Protection Laws

�� Fair Credit Reporting ActFair Credit Reporting Act

�� Vendor ComplianceVendor Compliance

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�� Schedule H: Hospital (contSchedule H: Hospital (cont’’d)d)

�� Part III: Management Companies and Joint Part III: Management Companies and Joint VenturesVentures

�� Good crossGood cross--check for known Joint Ventures and Fraud check for known Joint Ventures and Fraud & Abuse Compliance& Abuse Compliance

�� Relevant also to Tax Exempt Bond Compliance; private Relevant also to Tax Exempt Bond Compliance; private use limitations.use limitations.

(See IRS Publication 4077, Tax Exempt Bonds (See IRS Publication 4077, Tax Exempt Bonds Compliance Guide, available at www.irs.gov)Compliance Guide, available at www.irs.gov)

28


�� Part IV Part IV –– General InformationGeneral Information

�� Community/Health Care Needs Assessment Community/Health Care Needs Assessment –– see CHA see CHA Community Benefit Reporting ModelCommunity Benefit Reporting Model

�� ER Policies ER Policies –– Tax v. EMTALATax v. EMTALA

�� Patient Assistance Eligibility ProceduresPatient Assistance Eligibility Procedures

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�� Schedule J: Supplemental Compensation Schedule J: Supplemental Compensation InformationInformation

�� Relevant to Intermediate Sanction Rule Relevant to Intermediate Sanction Rule Compliance Compliance

�� Written travel and entertainment expense policiesWritten travel and entertainment expense policies

�� Per Se Excess Benefit Transactions Per Se Excess Benefit Transactions –– Certain Certain Personal Expenses (PPA 2006)Personal Expenses (PPA 2006)

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�� Schedule K: Information on Tax Exempt Schedule K: Information on Tax Exempt BondsBonds

�� Typically beyond purview of COsTypically beyond purview of COs

�� See IRS Tax Exempt Bond Compliance Check See IRS Tax Exempt Bond Compliance Check Questionnaire, July Questionnaire, July ‘‘0707

�� Suggested Areas for Compliance Review and Suggested Areas for Compliance Review and Process DevelopmentProcess Development

�� PoliciesPolicies

�� EducationEducation

�� Documentation of Private UseDocumentation of Private Use

31


�� Schedule K: Information on Tax Exempt Schedule K: Information on Tax Exempt Bonds (contBonds (cont’’d)d)

�� Form 13907 Form 13907 –– TaxTax--exempt Bond Financings exempt Bond Financings Compliance Check Questionnaire Compliance Check Questionnaire –– Information Information regarding postregarding post--issuance bond compliance and issuance bond compliance and record retentionrecord retention

32


�� Schedule L: Supplemental Information on Schedule L: Supplemental Information on LoansLoans

(To/From Officers, Directors, Key Employees (To/From Officers, Directors, Key Employees and Disqualified Persons)and Disqualified Persons)�� Relevant to Compliance with SOX; Intermediate Relevant to Compliance with SOX; Intermediate

Sanction Rules and where physicians involved, the Sanction Rules and where physicians involved, the Federal Fraud & Abuse Rules.Federal Fraud & Abuse Rules.

�� Loans from 509(a)(3) Supporting Organization to Loans from 509(a)(3) Supporting Organization to Disqualified Persons and other 509(a)(3) Disqualified Persons and other 509(a)(3) organization are per se excess benefit transactions organization are per se excess benefit transactions (PPA 2006)(PPA 2006)

33


�� Schedule R: Related OrganizationsSchedule R: Related Organizations

Relevance:Relevance:

�� Awareness of new related organizationsAwareness of new related organizations

�� Determination of applicability of compliance Determination of applicability of compliance program to related organizationprogram to related organization

34

Suggested Compliance PlanningSuggested Compliance PlanningSuggested Compliance PlanningSuggested Compliance PlanningSuggested Compliance PlanningSuggested Compliance PlanningSuggested Compliance PlanningSuggested Compliance Planning

�� Education Education –– Start with the BoardStart with the Board

�� Identify individuals within the organization with Identify individuals within the organization with operational responsibility for preparation of Form operational responsibility for preparation of Form 990, etc.990, etc.

�� Prepare Mock Form 990Prepare Mock Form 990

�� Prepare Mock Form 13907 (Bonds)Prepare Mock Form 13907 (Bonds)

�� Review IS to assess capability to capture required Review IS to assess capability to capture required information for Form 990information for Form 990

�� Review hospital/community benefit assessment and Review hospital/community benefit assessment and compliance compliance -- QuantifyQuantify

35


�� Inventory Policies and Procedures cited in Inventory Policies and Procedures cited in Form 990 and UpdateForm 990 and Update

�� Identify Identify ““Key EmployeesKey Employees”” and Review and Review Compensation Policies for Compliance with Compensation Policies for Compliance with the the ““Rebuttable PresumptionRebuttable Presumption””

�� Review and Document Joint Venture Review and Document Joint Venture ArrangementsArrangements

�� Update Organization Chart for Related Update Organization Chart for Related Organizations and JVsOrganizations and JVs

36


�� Adoption of Best Practices Adoption of Best Practices –– TransparencyTransparency

�� Conflict of InterestConflict of Interest

�� Independent Audit Committee Independent Audit Committee –– Financial Financial ExpertiseExpertise

�� Compliance with SOX principles Compliance with SOX principles –– Whistleblower/ Whistleblower/ NonNon--Retaliation and Record RetentionRetaliation and Record Retention

�� Reevaluate the scope of financial and governance Reevaluate the scope of financial and governance information available on organization websiteinformation available on organization website

�� Post Form 990 on organizationPost Form 990 on organization’’s website s website

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�� Board review and approval of Form 990Board review and approval of Form 990

�� Consider adopting a policy for CEO to sign Consider adopting a policy for CEO to sign Form 990Form 990

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ADDITIONAL RESOURCESADDITIONAL RESOURCESADDITIONAL RESOURCESADDITIONAL RESOURCESADDITIONAL RESOURCESADDITIONAL RESOURCESADDITIONAL RESOURCESADDITIONAL RESOURCES

�� JULY 2003 HOUSE E&C COMMITTEE ON BILLING AND JULY 2003 HOUSE E&C COMMITTEE ON BILLING AND JULY 2003 HOUSE E&C COMMITTEE ON BILLING AND JULY 2003 HOUSE E&C COMMITTEE ON BILLING AND JULY 2003 HOUSE E&C COMMITTEE ON BILLING AND JULY 2003 HOUSE E&C COMMITTEE ON BILLING AND JULY 2003 HOUSE E&C COMMITTEE ON BILLING AND JULY 2003 HOUSE E&C COMMITTEE ON BILLING AND COLLECTION PRACTICESCOLLECTION PRACTICESCOLLECTION PRACTICESCOLLECTION PRACTICESCOLLECTION PRACTICESCOLLECTION PRACTICESCOLLECTION PRACTICESCOLLECTION PRACTICES

�� http://republicans.energycommerce.house.gov/108/Letters/0http://republicans.energycommerce.house.gov/108/Letters/0http://republicans.energycommerce.house.gov/108/Letters/0http://republicans.energycommerce.house.gov/108/Letters/0http://republicans.energycommerce.house.gov/108/Letters/0http://republicans.energycommerce.house.gov/108/Letters/0http://republicans.energycommerce.house.gov/108/Letters/0http://republicans.energycommerce.house.gov/108/Letters/07162003_1039print.htm7162003_1039print.htm7162003_1039print.htm7162003_1039print.htm7162003_1039print.htm7162003_1039print.htm7162003_1039print.htm7162003_1039print.htm (Letter from Energy and (Letter from Energy and (Letter from Energy and (Letter from Energy and (Letter from Energy and (Letter from Energy and (Letter from Energy and (Letter from Energy and Commerce O&I SubCommittee on July 16, 2003 to Commerce O&I SubCommittee on July 16, 2003 to Commerce O&I SubCommittee on July 16, 2003 to Commerce O&I SubCommittee on July 16, 2003 to Commerce O&I SubCommittee on July 16, 2003 to Commerce O&I SubCommittee on July 16, 2003 to Commerce O&I SubCommittee on July 16, 2003 to Commerce O&I SubCommittee on July 16, 2003 to hospitals on billing and collection practices)hospitals on billing and collection practices)hospitals on billing and collection practices)hospitals on billing and collection practices)hospitals on billing and collection practices)hospitals on billing and collection practices)hospitals on billing and collection practices)hospitals on billing and collection practices)

�� Additional Related Websites:Additional Related Websites:Additional Related Websites:Additional Related Websites:Additional Related Websites:Additional Related Websites:Additional Related Websites:Additional Related Websites:http://republicans.energycommerce.house.gov/108/Letters/0http://republicans.energycommerce.house.gov/108/Letters/0http://republicans.energycommerce.house.gov/108/Letters/0http://republicans.energycommerce.house.gov/108/Letters/0http://republicans.energycommerce.house.gov/108/Letters/0http://republicans.energycommerce.house.gov/108/Letters/0http://republicans.energycommerce.house.gov/108/Letters/0http://republicans.energycommerce.house.gov/108/Letters/04252005_1502print.htm4252005_1502print.htm4252005_1502print.htm4252005_1502print.htm4252005_1502print.htm4252005_1502print.htm4252005_1502print.htm4252005_1502print.htm (Follow up letter sent on April 25, (Follow up letter sent on April 25, (Follow up letter sent on April 25, (Follow up letter sent on April 25, (Follow up letter sent on April 25, (Follow up letter sent on April 25, (Follow up letter sent on April 25, (Follow up letter sent on April 25, 2005 to 10 hospitals on uninsured and self2005 to 10 hospitals on uninsured and self2005 to 10 hospitals on uninsured and self2005 to 10 hospitals on uninsured and self2005 to 10 hospitals on uninsured and self2005 to 10 hospitals on uninsured and self2005 to 10 hospitals on uninsured and self2005 to 10 hospitals on uninsured and self--------pay patients and pay patients and pay patients and pay patients and pay patients and pay patients and pay patients and pay patients and billing and collection practices)billing and collection practices)billing and collection practices)billing and collection practices)billing and collection practices)billing and collection practices)billing and collection practices)billing and collection practices)

39


http://energycommerce.house.gov/reparchives/108/Hearinghttp://energycommerce.house.gov/reparchives/108/Hearinghttp://energycommerce.house.gov/reparchives/108/Hearinghttp://energycommerce.house.gov/reparchives/108/Hearinghttp://energycommerce.house.gov/reparchives/108/Hearinghttp://energycommerce.house.gov/reparchives/108/Hearinghttp://energycommerce.house.gov/reparchives/108/Hearinghttp://energycommerce.house.gov/reparchives/108/Hearings/06242004hearing1299/hearing.htms/06242004hearing1299/hearing.htms/06242004hearing1299/hearing.htms/06242004hearing1299/hearing.htms/06242004hearing1299/hearing.htms/06242004hearing1299/hearing.htms/06242004hearing1299/hearing.htms/06242004hearing1299/hearing.htm (Hearing held in June (Hearing held in June (Hearing held in June (Hearing held in June (Hearing held in June (Hearing held in June (Hearing held in June (Hearing held in June 2004 by O&I SubCommittee on billing and collection 2004 by O&I SubCommittee on billing and collection 2004 by O&I SubCommittee on billing and collection 2004 by O&I SubCommittee on billing and collection 2004 by O&I SubCommittee on billing and collection 2004 by O&I SubCommittee on billing and collection 2004 by O&I SubCommittee on billing and collection 2004 by O&I SubCommittee on billing and collection practices)practices)practices)practices)practices)practices)practices)practices)

http://republicans.energycommerce.house.gov/108/Letters/0http://republicans.energycommerce.house.gov/108/Letters/0http://republicans.energycommerce.house.gov/108/Letters/0http://republicans.energycommerce.house.gov/108/Letters/0http://republicans.energycommerce.house.gov/108/Letters/0http://republicans.energycommerce.house.gov/108/Letters/0http://republicans.energycommerce.house.gov/108/Letters/0http://republicans.energycommerce.house.gov/108/Letters/01222004_1195print.htm1222004_1195print.htm1222004_1195print.htm1222004_1195print.htm1222004_1195print.htm1222004_1195print.htm1222004_1195print.htm1222004_1195print.htm (Letter from Energy & Commerce (Letter from Energy & Commerce (Letter from Energy & Commerce (Letter from Energy & Commerce (Letter from Energy & Commerce (Letter from Energy & Commerce (Letter from Energy & Commerce (Letter from Energy & Commerce O&I Subcommittee on January 22, 2004 to HHS Secretary O&I Subcommittee on January 22, 2004 to HHS Secretary O&I Subcommittee on January 22, 2004 to HHS Secretary O&I Subcommittee on January 22, 2004 to HHS Secretary O&I Subcommittee on January 22, 2004 to HHS Secretary O&I Subcommittee on January 22, 2004 to HHS Secretary O&I Subcommittee on January 22, 2004 to HHS Secretary O&I Subcommittee on January 22, 2004 to HHS Secretary Thompson requesting additional information on hospital Thompson requesting additional information on hospital Thompson requesting additional information on hospital Thompson requesting additional information on hospital Thompson requesting additional information on hospital Thompson requesting additional information on hospital Thompson requesting additional information on hospital Thompson requesting additional information on hospital billing and collection practices)billing and collection practices)billing and collection practices)billing and collection practices)billing and collection practices)billing and collection practices)billing and collection practices)billing and collection practices)

40

ADDITIONAL RESOURCESADDITIONAL RESOURCESADDITIONAL RESOURCESADDITIONAL RESOURCESADDITIONAL RESOURCESADDITIONAL RESOURCESADDITIONAL RESOURCESADDITIONAL RESOURCES�� MAY 2005 SENATE FINANCE COMMITTEE INQUIRY ON MAY 2005 SENATE FINANCE COMMITTEE INQUIRY ON MAY 2005 SENATE FINANCE COMMITTEE INQUIRY ON MAY 2005 SENATE FINANCE COMMITTEE INQUIRY ON MAY 2005 SENATE FINANCE COMMITTEE INQUIRY ON MAY 2005 SENATE FINANCE COMMITTEE INQUIRY ON MAY 2005 SENATE FINANCE COMMITTEE INQUIRY ON MAY 2005 SENATE FINANCE COMMITTEE INQUIRY ON

HOSPITAL ACCOUNTING FOR CHARITABLE HOSPITAL ACCOUNTING FOR CHARITABLE HOSPITAL ACCOUNTING FOR CHARITABLE HOSPITAL ACCOUNTING FOR CHARITABLE HOSPITAL ACCOUNTING FOR CHARITABLE HOSPITAL ACCOUNTING FOR CHARITABLE HOSPITAL ACCOUNTING FOR CHARITABLE HOSPITAL ACCOUNTING FOR CHARITABLE ACTIVITIESACTIVITIESACTIVITIESACTIVITIESACTIVITIESACTIVITIESACTIVITIESACTIVITIES�� 55555555--------2525252525252525--------05 05 05 05 05 05 05 05 Grassley Asks NonGrassley Asks NonGrassley Asks NonGrassley Asks NonGrassley Asks NonGrassley Asks NonGrassley Asks NonGrassley Asks Non--------profit Hospitals to Account for Activities profit Hospitals to Account for Activities profit Hospitals to Account for Activities profit Hospitals to Account for Activities profit Hospitals to Account for Activities profit Hospitals to Account for Activities profit Hospitals to Account for Activities profit Hospitals to Account for Activities

Related to Their TaxRelated to Their TaxRelated to Their TaxRelated to Their TaxRelated to Their TaxRelated to Their TaxRelated to Their TaxRelated to Their Tax--------exempt Statusexempt Statusexempt Statusexempt Statusexempt Statusexempt Statusexempt Statusexempt Status. . . . . . . . ((((((((http://www.finance.senate.gov/sitepages/grassley2006.htmhttp://www.finance.senate.gov/sitepages/grassley2006.htmhttp://www.finance.senate.gov/sitepages/grassley2006.htmhttp://www.finance.senate.gov/sitepages/grassley2006.htmhttp://www.finance.senate.gov/sitepages/grassley2006.htmhttp://www.finance.senate.gov/sitepages/grassley2006.htmhttp://www.finance.senate.gov/sitepages/grassley2006.htmhttp://www.finance.senate.gov/sitepages/grassley2006.htm and scroll and scroll and scroll and scroll and scroll and scroll and scroll and scroll down to May 25, 2005 and click on link there.)down to May 25, 2005 and click on link there.)down to May 25, 2005 and click on link there.)down to May 25, 2005 and click on link there.)down to May 25, 2005 and click on link there.)down to May 25, 2005 and click on link there.)down to May 25, 2005 and click on link there.)down to May 25, 2005 and click on link there.)

�� MARCH 2006 GAO SURVEY OF NONPROFIT HOSPITALS MARCH 2006 GAO SURVEY OF NONPROFIT HOSPITALS MARCH 2006 GAO SURVEY OF NONPROFIT HOSPITALS MARCH 2006 GAO SURVEY OF NONPROFIT HOSPITALS MARCH 2006 GAO SURVEY OF NONPROFIT HOSPITALS MARCH 2006 GAO SURVEY OF NONPROFIT HOSPITALS MARCH 2006 GAO SURVEY OF NONPROFIT HOSPITALS MARCH 2006 GAO SURVEY OF NONPROFIT HOSPITALS ON EXECUTIVE COMPENSATION POLICIES AND ON EXECUTIVE COMPENSATION POLICIES AND ON EXECUTIVE COMPENSATION POLICIES AND ON EXECUTIVE COMPENSATION POLICIES AND ON EXECUTIVE COMPENSATION POLICIES AND ON EXECUTIVE COMPENSATION POLICIES AND ON EXECUTIVE COMPENSATION POLICIES AND ON EXECUTIVE COMPENSATION POLICIES AND PRACTICESPRACTICESPRACTICESPRACTICESPRACTICESPRACTICESPRACTICESPRACTICES�� http://www.gao.gov/docsearch/abstract.php?rptno=GAOhttp://www.gao.gov/docsearch/abstract.php?rptno=GAO--0606--907R907R

(Links to Summary Page and from there access to full report)(Links to Summary Page and from there access to full report)

41


�� MAY 2006 IRS COMPLIANCE CHECK QUESTIONNAIRE MAY 2006 IRS COMPLIANCE CHECK QUESTIONNAIRE MAY 2006 IRS COMPLIANCE CHECK QUESTIONNAIRE MAY 2006 IRS COMPLIANCE CHECK QUESTIONNAIRE MAY 2006 IRS COMPLIANCE CHECK QUESTIONNAIRE MAY 2006 IRS COMPLIANCE CHECK QUESTIONNAIRE MAY 2006 IRS COMPLIANCE CHECK QUESTIONNAIRE MAY 2006 IRS COMPLIANCE CHECK QUESTIONNAIRE FOR TAXFOR TAXFOR TAXFOR TAXFOR TAXFOR TAXFOR TAXFOR TAX--------EXEMPT HOSPITALS AND INTERIM REPORTEXEMPT HOSPITALS AND INTERIM REPORTEXEMPT HOSPITALS AND INTERIM REPORTEXEMPT HOSPITALS AND INTERIM REPORTEXEMPT HOSPITALS AND INTERIM REPORTEXEMPT HOSPITALS AND INTERIM REPORTEXEMPT HOSPITALS AND INTERIM REPORTEXEMPT HOSPITALS AND INTERIM REPORT

�� http://www.irs.gov/charities/charitable/article/0,,id=172267,http://www.irs.gov/charities/charitable/article/0,,id=172267,http://www.irs.gov/charities/charitable/article/0,,id=172267,http://www.irs.gov/charities/charitable/article/0,,id=172267,http://www.irs.gov/charities/charitable/article/0,,id=172267,http://www.irs.gov/charities/charitable/article/0,,id=172267,http://www.irs.gov/charities/charitable/article/0,,id=172267,http://www.irs.gov/charities/charitable/article/0,,id=172267,00.html00.html00.html00.html00.html00.html00.html00.html (General Information on IRS Interim Report and (General Information on IRS Interim Report and (General Information on IRS Interim Report and (General Information on IRS Interim Report and (General Information on IRS Interim Report and (General Information on IRS Interim Report and (General Information on IRS Interim Report and (General Information on IRS Interim Report and includes links to Compliance Check Questionnaire and includes links to Compliance Check Questionnaire and includes links to Compliance Check Questionnaire and includes links to Compliance Check Questionnaire and includes links to Compliance Check Questionnaire and includes links to Compliance Check Questionnaire and includes links to Compliance Check Questionnaire and includes links to Compliance Check Questionnaire and Interim Report)Interim Report)Interim Report)Interim Report)Interim Report)Interim Report)Interim Report)Interim Report)

�� FEBRUARY 2007 IRS GOOD GOVERNANCE PRACTICES FEBRUARY 2007 IRS GOOD GOVERNANCE PRACTICES FEBRUARY 2007 IRS GOOD GOVERNANCE PRACTICES FEBRUARY 2007 IRS GOOD GOVERNANCE PRACTICES FEBRUARY 2007 IRS GOOD GOVERNANCE PRACTICES FEBRUARY 2007 IRS GOOD GOVERNANCE PRACTICES FEBRUARY 2007 IRS GOOD GOVERNANCE PRACTICES FEBRUARY 2007 IRS GOOD GOVERNANCE PRACTICES DISCUSSION DRAFTDISCUSSION DRAFTDISCUSSION DRAFTDISCUSSION DRAFTDISCUSSION DRAFTDISCUSSION DRAFTDISCUSSION DRAFTDISCUSSION DRAFT

�� http://www.irs.gov/charities/charitable/article/0,,id=167626,http://www.irs.gov/charities/charitable/article/0,,id=167626,http://www.irs.gov/charities/charitable/article/0,,id=167626,http://www.irs.gov/charities/charitable/article/0,,id=167626,http://www.irs.gov/charities/charitable/article/0,,id=167626,http://www.irs.gov/charities/charitable/article/0,,id=167626,http://www.irs.gov/charities/charitable/article/0,,id=167626,http://www.irs.gov/charities/charitable/article/0,,id=167626,00.html00.html00.html00.html00.html00.html00.html00.html

42


�� JUNE 2007 IRS REVENUE RULING 2007JUNE 2007 IRS REVENUE RULING 2007JUNE 2007 IRS REVENUE RULING 2007JUNE 2007 IRS REVENUE RULING 2007JUNE 2007 IRS REVENUE RULING 2007JUNE 2007 IRS REVENUE RULING 2007JUNE 2007 IRS REVENUE RULING 2007JUNE 2007 IRS REVENUE RULING 2007--------41 RE: 41 RE: 41 RE: 41 RE: 41 RE: 41 RE: 41 RE: 41 RE: PROHIBITED POLITICAL ACTIVITIES FOR TAX EXEMPT PROHIBITED POLITICAL ACTIVITIES FOR TAX EXEMPT PROHIBITED POLITICAL ACTIVITIES FOR TAX EXEMPT PROHIBITED POLITICAL ACTIVITIES FOR TAX EXEMPT PROHIBITED POLITICAL ACTIVITIES FOR TAX EXEMPT PROHIBITED POLITICAL ACTIVITIES FOR TAX EXEMPT PROHIBITED POLITICAL ACTIVITIES FOR TAX EXEMPT PROHIBITED POLITICAL ACTIVITIES FOR TAX EXEMPT ORGANIZATIONSORGANIZATIONSORGANIZATIONSORGANIZATIONSORGANIZATIONSORGANIZATIONSORGANIZATIONSORGANIZATIONS

�� http://www.irs.gov/charities/article/0,,id=165718,00.htmlhttp://www.irs.gov/charities/article/0,,id=165718,00.html

�� JUNE 2007 IRS DRAFT REDESIGN FORM 990JUNE 2007 IRS DRAFT REDESIGN FORM 990JUNE 2007 IRS DRAFT REDESIGN FORM 990JUNE 2007 IRS DRAFT REDESIGN FORM 990JUNE 2007 IRS DRAFT REDESIGN FORM 990JUNE 2007 IRS DRAFT REDESIGN FORM 990JUNE 2007 IRS DRAFT REDESIGN FORM 990JUNE 2007 IRS DRAFT REDESIGN FORM 990

�� http://www.irs.gov/charities/article/0,,id=171216,00.htmlhttp://www.irs.gov/charities/article/0,,id=171216,00.html(general information)(general information)

�� http://www.irs.gov/charities/article/0,,id=171213,00.htmlhttp://www.irs.gov/charities/article/0,,id=171213,00.html(redesigned form and schedules)(redesigned form and schedules)

43


�� JULY 17, 2007 SENATE FINANCE COMMITTEE JULY 17, 2007 SENATE FINANCE COMMITTEE JULY 17, 2007 SENATE FINANCE COMMITTEE JULY 17, 2007 SENATE FINANCE COMMITTEE JULY 17, 2007 SENATE FINANCE COMMITTEE JULY 17, 2007 SENATE FINANCE COMMITTEE JULY 17, 2007 SENATE FINANCE COMMITTEE JULY 17, 2007 SENATE FINANCE COMMITTEE MINORITY STAFF DISCUSSION DRAFT ON NONPROFIT MINORITY STAFF DISCUSSION DRAFT ON NONPROFIT MINORITY STAFF DISCUSSION DRAFT ON NONPROFIT MINORITY STAFF DISCUSSION DRAFT ON NONPROFIT MINORITY STAFF DISCUSSION DRAFT ON NONPROFIT MINORITY STAFF DISCUSSION DRAFT ON NONPROFIT MINORITY STAFF DISCUSSION DRAFT ON NONPROFIT MINORITY STAFF DISCUSSION DRAFT ON NONPROFIT HOSPITAL REFORM PROPOSALSHOSPITAL REFORM PROPOSALSHOSPITAL REFORM PROPOSALSHOSPITAL REFORM PROPOSALSHOSPITAL REFORM PROPOSALSHOSPITAL REFORM PROPOSALSHOSPITAL REFORM PROPOSALSHOSPITAL REFORM PROPOSALS

�� 77777777--------1818181818181818--------0707070707070707 Grassley Releases Staff Discussion Draft of Potential Grassley Releases Staff Discussion Draft of Potential NonNon--profit Hospital Reforms, Solicits Public Commentprofit Hospital Reforms, Solicits Public Comment

�� Staff Discussion Draft of Potential NonStaff Discussion Draft of Potential Non--profit Hospital profit Hospital Reforms Reforms

�� (Links to .pdf documents, see also (Links to .pdf documents, see also http://www.senate.gov/~finance/sitepages/grassley.htmhttp://www.senate.gov/~finance/sitepages/grassley.htm; ; scroll down to July 18, 2007 for additional links.) scroll down to July 18, 2007 for additional links.)

44


�� JULY 24, 2007 HOUSE WAYS AND MEANS OVERSIGHT JULY 24, 2007 HOUSE WAYS AND MEANS OVERSIGHT JULY 24, 2007 HOUSE WAYS AND MEANS OVERSIGHT JULY 24, 2007 HOUSE WAYS AND MEANS OVERSIGHT JULY 24, 2007 HOUSE WAYS AND MEANS OVERSIGHT JULY 24, 2007 HOUSE WAYS AND MEANS OVERSIGHT JULY 24, 2007 HOUSE WAYS AND MEANS OVERSIGHT JULY 24, 2007 HOUSE WAYS AND MEANS OVERSIGHT SUBCOMMITTEE HEARING REGARDING 501(C)(3) TAX SUBCOMMITTEE HEARING REGARDING 501(C)(3) TAX SUBCOMMITTEE HEARING REGARDING 501(C)(3) TAX SUBCOMMITTEE HEARING REGARDING 501(C)(3) TAX SUBCOMMITTEE HEARING REGARDING 501(C)(3) TAX SUBCOMMITTEE HEARING REGARDING 501(C)(3) TAX SUBCOMMITTEE HEARING REGARDING 501(C)(3) TAX SUBCOMMITTEE HEARING REGARDING 501(C)(3) TAX EXEMPT ORGANIZATIONSEXEMPT ORGANIZATIONSEXEMPT ORGANIZATIONSEXEMPT ORGANIZATIONSEXEMPT ORGANIZATIONSEXEMPT ORGANIZATIONSEXEMPT ORGANIZATIONSEXEMPT ORGANIZATIONS

�� http://waysandmeans.house.gov/hearings.asp?formmode=dehttp://waysandmeans.house.gov/hearings.asp?formmode=detail&hearing=577&comm=3tail&hearing=577&comm=3

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�� AUGUST 27, 2007 IRS TAXAUGUST 27, 2007 IRS TAXAUGUST 27, 2007 IRS TAXAUGUST 27, 2007 IRS TAXAUGUST 27, 2007 IRS TAXAUGUST 27, 2007 IRS TAXAUGUST 27, 2007 IRS TAXAUGUST 27, 2007 IRS TAX--------EXEMPT BOND COMPLIANCE EXEMPT BOND COMPLIANCE EXEMPT BOND COMPLIANCE EXEMPT BOND COMPLIANCE EXEMPT BOND COMPLIANCE EXEMPT BOND COMPLIANCE EXEMPT BOND COMPLIANCE EXEMPT BOND COMPLIANCE SURVEYSURVEYSURVEYSURVEYSURVEYSURVEYSURVEYSURVEY

�� http://www.irs.gov/taxexemptbond/article/0,,id=132042,00.http://www.irs.gov/taxexemptbond/article/0,,id=132042,00.htmlhtml (Second Item on Page, entitled TEB and EOCA (Second Item on Page, entitled TEB and EOCA Partner in Qualified 501(c)(3) Bonds Compliance Partner in Qualified 501(c)(3) Bonds Compliance Questionnaire includes general information and a link to Questionnaire includes general information and a link to the Compliance Questionnaire).the Compliance Questionnaire).

�� OnOn--Line Workshop for Exempt Organizations Line Workshop for Exempt Organizations –– Including Including Form 990 Preparation (60 min.)Form 990 Preparation (60 min.)

http://www.irs.gov/charities/article/0,,id=166625,00.htmlhttp://www.irs.gov/charities/article/0,,id=166625,00.html

highlights of the redesigned form 990 part ii: … · 2014-09-03 · highlights of the redesigned...

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