As of the 2008 tax year (returns filed in 2009), a change in IRS Form 990 and Schedule H for tax-exempt hospitals will require disclosure of all a hospital’s management companies and joint ventures where physicians hold an aggregate five percent (5%) or greater ownership interest.  Hospitals will need to report: (1) name of the entity; (2) description of the primary activities of the entity; (3) percent of ownership and profit attributed to the hospital; (4) percent of ownership and profit attributed to physicians; and (5) percent of ownership and profit attributed to officers, directors, trustees or key employees.           

            While this information will only be furnished to the IRS, we can reasonably conclude that it may be made available to other federal regulatory agencies, including the Center for Medicare and Medicaid Services and the Office of the Inspector General.  To this end, these IRS revisions should serve as a reminder to ensure that your practice and business ventures fully comply with all federal and state regulations.  Should you have any questions or would like us to assess your current business structures, please do not hesitate to contact our office.