Not-For-Profit Hospital Status Under Heightened Government Scrutiny

Latest Strategies for Protecting Tax-Exempt Status

Recording of a 90-minute CLE webinar/teleconference with Q&A


Conducted on Wednesday, May 19, 2010
Recorded event now available


This CLE webinar will provide guidance to counsel for not-for-profit (NFP) hospitals on the proactive measures necessary to protect the hospital's tax-exempt status, in light of the recent Provena Covenant ruling and other federal and state initiatives targeting NFP hospitals.

Description

Not-for-profit hospitals (NFPs) have operated under heightened scrutiny for the past several years amid allegations of unfair billing and collection practices, failure to provide charity care and participation in for-profit schemes.

Lawsuits in federal and state courts accuse NFPs of failing to meet their tax-exempt obligations under 501(c)(3) and state law. Additionally, NFPs face investigations by state attorneys general, initiatives by state legislatures, and challenges to property tax exemptions.

In March, the Illinois Supreme Court upheld the loss of Provena Covenant hospital’s tax-exempt status, finding that it served too few charity care patients. Hospitals must closely analyze this decision and review whether their level of charity care is sufficient to maintain tax exempt status.

Listen as our authoritative panel discusses how hospitals can protect their tax-exempt status amid increased IRS and state scrutiny.

Outline

  1. New federal law requirements after Patient Protection and Affordable Care Act (PPACA)
    1. New IRC § 501(r) requirements to maintain tax exempt status
    2. Role of nonprofit health care under PPACA (new disclosure requirements, studies, reports to Congress)
  2. The Illinois Supreme Court decision in Provena Covenant
    1. What the opinion says and doesn't say; where the law is now
    2. Can plurality opinion be exported?
    3. Putting Provena in context (How we got from 2002 to today)
  3. How hospitals should react to new federal law requirements and Provena

Benefits

The panel will review these and other key questions:

  • What is the impact of the attacks on NFPs and new requirements for hospitals whose tax-exempt status results in substantial financial benefits every year?
  • How can NFPs balance the requirements to maintain tax-exempt status while managing the rising costs of charity care?
  • What steps should hospitals take to comply with state and federal law requirements for NFPs and avoid government penalties or civil liability?
  • What are the additional requirements imposed on NFP hospitals by the new healthcare reform law?

Faculty

Patrick S. Coffey, Partner
Locke Lord Bissell & Liddell, Chicago

He is an experienced trial lawyer and corporate counselor. His practice concentrates on the representation of corporate and individual clients in complex business litigation, internal investigations, regulatory and government enforcement proceedings, and white collar criminal defense matters. He represented Provena Covenant Medical Center in the recent case regarding its tax-exempt status.

James R. King, Partner
Jones Day, Columbus, Ohio

He advises tax-exempt healthcare organizations and other tax-exempt and nonprofit organizations regarding tax, transactional, regulatory, and corporate governance matters. He has substantial experience representing clients in federal and state tax controversy matters, including IRS team examinations of hospitals and health systems, and state challenges to real estate and other tax exemptions.

T. J. Sullivan, Partner
Drinker Biddle & Reath, Washington, D.C.

He is a healthcare transactional and tax partner with more than 20 years experience advising tax-exempt organizations on complex regulatory and business issues. Until 1996, he was Special Assistant (healthcare) to the IRS Assistant Commissioner (employee plans and exempt organizations). At the IRS, he specialized in matters involving the tax treatment of hospitals and HMOs.

Ordering

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Program Materials

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Customer Reviews

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The seminar provided good practical examples and advice plus good Q&A.

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Health Law Advisory Board

Lowell C. Brown

Partner

Arent Fox

Gina M. Kastel

Partner

Faegre Baker Daniels

Karen S. Lovitch

Member

Mintz, Levin, Cohn, Ferris, Glovsky and Popeo

David A. Manko

Partner

Rivkin Radler

John J. Miles

Principal

Ober Kaler

Gregg D. Reisman

Partner

Garfunkel Wild & Travis

J. Peter Rich

Partner

McDermott Will & Emery

Donald H. Romano

Of Counsel

Foley & Lardner

Judith A. Waltz

Partner

Foley & Lardner

John R. Washlick

Shareholder

Cozen O’Connor

Jesse A. Witten

Partner

Drinker Biddle & Reath

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