NABL: IRS Issues Notice Clarifying Requirements Related to Hospital Facility Financial Assistance Policies.

Notice 2015-46 clarifies how a charitable hospital organization may comply with the requirement in the final regulations under section 501(r) published on December 31, 2014, that a hospital facility include a list of providers in its financial assistance policy (FAP). This notice affects charitable hospital organizations. Section 501(r) was added by the Affordable Care Act and added requirements that hospitals must meet to remain 501(c)(3) organizations.

In August 2014, NABL published The 501(c)(3) Opinion In Qualified 501(c)(3) Bond Transactions: Background, Opinion Formulations and Due Diligence, which, among other topics, discusses the requirements of section 501(r).

Notice 2015-46 will appear in IRB 2015-28 dated July 13, 2015.



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