Proposed Regulations on Additional Requirements for Charitable Hospitals: Compliance and Public Comments

We will discuss these new requirements and their practical effect on the policies and practices of charitable hospital organizations. As the deadline for making public comments to the IRS is September 24, 2012, we also will discuss the role that hospitals can play through the comment process and areas where changes or additional guidance from the IRS would be important.

The proposed regulations will not be effective until after final regulations are published; however, they provide guidance on statutory requirements that currently apply to 501(c)(3) hospitals. We will cover how the proposed regulations have significant practical implications for tax compliance, both now and in the future. Additionally, we will review how the proposed regulations would potentially require substantial rewrites and changes to financial assistance policies and the practices of many charitable hospital organizations to reflect new detailed regulatory requirements.

We also will review some of the more important and controversial aspects of the proposed regulations in detail, including the new specific required methods for determining limitations on certain charges and the specific types of “extraordinary collection actions” that cannot be taken until certain prior actions are taken by the hospital.

Moderator
Lawrence W. Vernaglia, Partner and Health Care Industry Team Chair, Foley & Lardner LLP

Speakers
Michael G. Bailey, Partner, Foley & Lardner LLP
Kenneth R Appleby, Partner, Foley & Lardner LLP

Foley & Lardner LLP will apply for CLE credit after the program, wherever applicable. Foley & Lardner LLP certifies that this activity has been approved for California MCLE credits by the State Bar of California in the amount of one General credit. Foley & Lardner LLP is a State Bar of California MCLE approved provider. Please note that participants must log in to both the teleconference and LiveMeeting portions on the date of the event; credit may not be obtained by viewing and/or listening to a program recording after the event.