Industry Insights

Charitable Hospital Organizations Receive Clarification on Provider List Requirements

July 2015
Author:  Amy Catcher

Amy Catcher

Senior Manager


Health Care

Two Warren Place
6120 S. Yale Avenue, Suite 1400
Tulsa, OK 74136-4223


Charitable hospital organizations have received new guidance from the IRS on how to comply with the requirements for their financial assistance policies (FAP).

IRS Notice 2015-46 clarifies how a charitable hospital organization may comply with the requirement that it include a list of providers in its FAP. A charitable hospital must include a list of any providers—other than the hospital facility itself—delivering emergency or other medically necessary care in the hospital facility; the hospital also must specify which providers are and aren’t covered by the hospital facility’s FAP. The list may be included in the FAP or in a separate document such as an appendix, provided the FAP explains how to obtain the list free of charge—both online and on paper.

The hospital facility may list the names of individual doctors, practice groups or any other entities providing emergency or medically necessary care in the hospital facility by the name used either to contract with the hospital or bill patients for care provided. If all doctors in a practice group are covered, the hospital facility only may list the name of the practice group. In addition, if all doctors providing a service in a department are or aren’t covered by the FAP, the list may include the department rather than the names of the doctors or the practice group.

If a provider is covered by the hospital’s FAP in some instances but not others, the hospital facility must describe the circumstances under which the provider will and won’t be covered. However, if services aren’t covered by the facility’s FAP, the policy need not indicate whether the provider’s services may be covered by another entity’s financial aid policy.

For the organization to be considered to have taken reasonable steps to ensure the list is accurate and have corrected any minor omissions or errors to meet the requirements of Internal Revenue Code Section 501(r), the provider list must be updated at least quarterly. If the only change the hospital makes to the FAP is updating the provider list, it doesn’t need to be adopted by an authorized body of the hospital facility again.

For more information on how this guidance could affect your organization, contact your BKD advisor.

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