Form 990 New Disclosure Requirements for Not-for-Profit Hospitals

Protecting Tax-Exempt Status While Complying With IRS Transparency Obligations

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

Conducted on Wednesday, May 6, 2009

Course Materials

This seminar will examine the legal implications of the new transparency requirements of Form 990 for not-for-profit hospitals and the current enforcement climate for tax law violations. The seminar will provide best practices for protecting tax-exempt status while complying with the new disclosure requirements.


The IRS recently overhauled the Form 990 to eliminate abuse by tax-exempt organizations. The new form forces nonprofit hospitals to prove they are eligible for favorable tax treatment and to disclose information on corporate governance practices and financial relationships.

Hospitals must submit the new form with returns filed beginning May 15, 2009, for the 2008 tax year. As hospitals prepare to comply with the new disclosure requirements, they should review and adjust practices regarding board composition, corporate governance and charity care.

Listen as a panel of health law attorneys explains the legal and business implications of the new transparency requirements and the increasingly challenging enforcement climate for tax law violations. The panelists will suggest best practices for protecting tax-exempt status while complying with the new disclosure requirements.



  1. Form 990 disclosure requirements
    1. Corporate governance implications
    2. Financial arrangements with insiders
    3. Community benefit standard
  2. Current enforcement environment
    1. Whistleblower statutes
    2. IRS compliance checks
  3. Best practices for protecting non-exempt status
    1. Conflicts of interest
    2. Whistleblower policy
    3. Document retention and destruction
    4. Investments and joint ventures
    5. Gift acceptance policy
    6. Compensation policies
    7. Charity care
    8. Debt collections policy


The panel will review these and other key questions:

  • What corporate governance implications arise from Form 990's new disclosure requirements?
  • How is the IRS increasing its efforts to identify and address tax law violations by not-for-profit hospitals?
  • What steps should not-for-profit hospitals take immediately to protect their non-exempt status when providing the information required by the Form 990?

Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.


James R. King
James R. King

Jones Day

He chairs the firm's healthcare practice's Tax Exempt Organization and Corporate Governance Team, counseling health...  |  Read More

Patrick S. Coffey
Patrick S. Coffey

Locke Lord Bissell & Liddell

He concentrates his practice in the representation of healthcare-related entities in complex business litigation,...  |  Read More

T. J. Sullivan
T. J. Sullivan

Drinker Biddle

He advises tax-exempt organizations on complex regulatory issues. He previously worked for the IRS, where he...  |  Read More

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