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Comment Letter on Draft Redesigned Form 990 and Schedules
Regulatory Advocacy
Last Updated: 9/13/2007
September 13, 2007
Internal Revenue Service
Form 990 Redesign, SE:T: EO
1111 Constitution Avenue, NW
Washington, D.C. 20224
RE: Comments on Draft Redesigned Form 990 and Schedules
To Whom It May Concern:
On behalf of Pennsylvania’s 225 hospitals and health care systems, The Hospital & Healthsystem Association of Pennsylvania (HAP) welcomes the opportunity to comment on the Internal Revenue Service’s Redesigned Form 990 draft. While we applaud your efforts in developing a new Form 990, which has not been revised since 1979, we have significant concerns about the draft redesign. These concerns include the aggressive implementation date and filing deadlines, as well as the additional cost and burden that will result from the proposed expansion of reporting requirements for the hospitals as well as our own association. Please note that more technical comments on the core form and its various schedules are attached. Obviously, of particular concern is the Proposed Schedule H, which our member hospitals and health systems would be required to file.
Our concerns can be summarized as follows:
- The filing deadline is far too short and should be extended to tax year 2010 for Form 990 and all schedules.
- Additional resources/time will be needed in order to complete the Redesigned Form 990 and the various schedules for our member’s hospitals as well as the association itself.
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Form 990 and other schedules have numerous questions that require substantial revisions or clarification to ensure that the goals the IRS set for itself can be achieved (reduce burden on filing organization, promote tax compliance and enhance transparency).
- Schedule H does not recognize the full value of community benefit provided by hospitals and schedule K would require significant resources to compile the information required to be reported.
We appreciate the opportunity to comment on the redesigned Form 990 and related schedules, and thank you in advance for consideration of our comments and recommendations. Should you have further questions, please contact Tina Latin-True, Vice President and Controller at (717) 561-5311 or Melissa Speck, Director, Policy Development at (717) 561-5356.
Sincerely,
CAROLYN F. SCANLAN
President & Chief Executive Officer
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