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AmericanHealthLawyersAssociationTaxIssuesforHealthcareOrganizations
Form990ScheduleH
October16,2012
Ronald J. Schultz, JD Karen L.P. Wolfson, JDManaging Director, EOTS Director, TaxationPricewaterhouseCoopers, LLP CareGroup, Inc.
ScopeofToday’sDiscussion
• Form 990 Schedule H Changes Over Time: How Did We Get Here?
• Backdrop: Ongoing Industry, Third Party Review and Government Focus
• 2011 Form 990 Schedule H Parts I – VI • Charity Care and Community Benefits at Cost / The Community Benefit Percentage• Community Building Activities• Bad Debt, Medicare Shortfalls and Collections• Management Companies and Joint Ventures• What is a Hospital Facility?• Community Health Needs Assessment• Financial Assistance Policies and Emergency Care• Billing and Collection • Supplemental Disclosures
• Trends in Schedule H Data
• Reporting Difficulties, Challenges and Key Areas of Focus
• Challenges to the IRS as the Tax Administration Agency
• Potential Implications of the IRC §501(r) Proposed Regulations
• Questions & Answers
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Form990ScheduleHHowDidWeGetHere?
• Tax Year 2008
• IRS Expanded / Overhauled Form 990
• New Schedule H for Hospitals ‐‐ Focus Charity Care and Community Benefit
• 6 Parts, 5 Parts Optional
• Face of Form, 4 pages
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Form990ScheduleHHowDidWeGetHere?
• Tax Year 2009
• No significant changes to face of Schedule H
• 6 Parts, all required
• Face of Form, 4 pages
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Form990ScheduleHHowDidWeGetHere?
• Tax Year 2010
• Focus expands beyond Charity Care and Community Benefit
• Significant changes to Schedule H to reflect the requirements of the new IRC §501(r)
• Expansion and Codification of Community Benefits and Financial Assistance Requirements to Maintain Exempt Status
• Face of Form length, 8 pages
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Form990ScheduleHHowDidWeGetHere?
• Tax Year 2010 (continued)
• Part V expanded and divided into 3 Sections; Detailed New Questions on:• Community Health Needs Assessment (CHNA)• Financial Assistance Policy (FAP)• Billing and Collections• Emergency Medical Care• Individuals Eligible for Assistance• Non‐Hospital Health Care Facilities
• Facility by Facility Reporting
• Part V Section B, Optional6
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Form990ScheduleHHowDidWeGetHere?
• Tax Year 2011
• No significant changes to face of Schedule H, but FAP, Billing, Collection, Emergency Medical Care Questions no longer optional
• Part V, Section B, Lines 1‐7 (CHNA) optional
• Face of Form length, 8 pages
• Comparison – The face of the 2007 Form 990 was 9 pages
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Form990ScheduleHBackdrop:OngoingIndustry,ThirdParty
ReviewandGovernmentFocus• First and foremost – Congressionally mandated IRS/Treasury/HHS studies and reports to Congress ‐ annual and 5‐year
• IRS to audit each hospital’s Schedule H once every three years
• But also important• Industry Articles and other published analysis• Academic and other studies of the data• State and local government review of specific hospital data
• And let’s not forget – the IRS for IRS purposes8
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Form990ScheduleHBackdrop:OngoingIndustry,ThirdParty
ReviewandGovernmentFocus
• Common Thread and Question:
• Are the benefits being provided by nonprofit hospitals sufficient to warrant the benefits they receive through governmental “subsidies”
• In the aggregate?
• At the hospital organization or facility level?
• Federal, state, or local level?
• Exemption, tax exempt bonds, charitable deduction, other?
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Form990ScheduleHBackdrop:OngoingIndustry,ThirdParty
ReviewandGovernmentFocus
• Some Schedule H Results Thus Far:
• Modern Health Care article
• AHA study
• Non‐statistical sample of publicly available Form 990 Schedule H’s as filed by some organizations
• Group return v. multiple facility filing entity v. single facility entities within a system
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2011Form990ScheduleHListofRequiredDisclosures
• Part I: Charity Care and Certain Other Community Benefits at Cost
• Part II: Community Building Activities• Part III: Bad Debt, Medicare, & Collection Practices• Part IV: Management Companies and Joint Ventures• Part V: Facility Information
• Section A: Hospital Facilities• Section B: Facility Polices and Practices• Section C: Other Health Care Facilities That Are Not Licensed, Registered or Similarly Recognized as a Hospital Facility
• Part VI: Supplemental Information
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2011Form990ScheduleHGeneralInformationandSchedulePurpose
• Hospital organizations use Form 990 Schedule H to provide information on the activities and policies of, and the community benefit provided by, its hospital facilities and other non‐hospital health care facilities that it operated during the tax year including operated:• Directly
• Indirectly through Disregarded Entity
• Indirectly through Joint Ventures
• For a Group Return, include all Hospitals operated by each facility within the Group, directly and indirectly
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2011Form990ScheduleHPartIFinancialAssistance,CharityCareand
CommunityBenefitsatCost
• Does the hospital have a written charity care policy?• Written policy as reviewed and adopted by board or subcommittee• Charity care reported only to extent provided pursuant to policy
• Is Free/Discounted care – Based on Federal Poverty Guidelines?• What Percentage of FPG? • Answer based on the charity care eligibility criteria that apply to the largest number of the organization’s patients.
• Does Financial Assistance Policy (FAP) have a “medically indigent” provision?• Defined as “persons whom the organization has determined are unable to pay some or all of their medical bills because their medical bills exceed a certain percentage of family or household income or assets”.
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2011Form990ScheduleHPartIFinancialAssistance,CharityCareand
CommunityBenefitsatCost
• Does the hospital budget for charity / discounted care?• Was budget exceeded? • Did the budget impact the hospital’s providing free / discounted care?
• Note that budgets can be based on charges or costs
• Did the hospital prepare a written annual community benefit report and is it available to the public?
• Additional questions in Schedule H Part V Section B
• Yes/No questions and charts don’t tell the whole story.• Required Supplemental Information provides opportunity to tell the entire story of the organization.
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2011Form990ScheduleHPartIFinancialAssistance,CharityCareand
CommunityBenefitsatCost
• What is charity care for Schedule H?• “…free or discounted health services provided to persons who meet the organization’s criteria for financial assistance and are thereby deemed unable to pay for all or a portion of the services.”
• General Rule – If create a bill, no longer charity care, but might be bad debt is ultimately written off.
• “Charity care” for Schedule H does not include:• Bad debt or uncollectible charges recorded but not paid• Medicare revenue shortfalls (exception – Subsidized Service Medicare Shortfalls are Community Benefit)
• Contractual adjustments 15
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2011Form990ScheduleHPartIFinancialAssistance,CharityCareandCommunityBenefits
atCost:TheCommunityBenefitPercentage
• “The Chart” on Page 1 which we know is a focal point for various internal and external constituents – board, media, IRS, AG, etc.• Before finalizing the Community Benefit Percentage calculation, total expenses must be adjusted to:
• Remove Bad Debt Expense generally at charges • Add Organization’s proportional share of joint venture expenses for a hospital operated within a joint venture
• Question – How do you define community for this purpose?
• Important Discussion Item under the ACA and the new Schedule H disclosures and related to the CHNA required under §501(r) 16
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2011Form990ScheduleHPartIFinancialAssistance,CharityCareandCommunityBenefits
atCost:TheCommunityBenefitPercentage
• Financial Assistance and Means‐Tested Government Programs – Gross, Offsetting Revenue and Net
• Charity Care at Cost (No Bad Debt or Medicare Shortfalls)
• Unreimbursed Medicaid
• Unreimbursed Costs – Other Means Tested Government Programs
• Government sponsored health programs with eligibility determined by income or assets
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2011Form990ScheduleHPartIFinancialAssistance,CharityCareandCommunityBenefits
atCost:TheCommunityBenefitPercentage
• Other Benefits: Community Health Improvement Services and Community Benefit Operations / Cash and In‐Kind Contributions to Community Groups
• Cash to Community Groups
• In‐kind Contributions• Staff hours donated• Indirect cost of space used by TE community groups• Value of donated supplies, food and equipment
• Does not include• Restricted grant if funded by a related organization (i.e. only hospital funding counts)• But related organization funding and activities can be included in the narrative – tell
the story
• Employee emergency funds for own employees 18
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2011Form990ScheduleHPartIFinancialAssistance,CharityCareandCommunityBenefits
atCost:TheCommunityBenefitPercentage
• Other Benefits: Community Health Improvement Services and Community Benefit Operations / Cash and In‐Kind Contributions to Community Groups (continued)
• Activities/programs carried out or supported to improve community health and subsidized by the hospital
• Must seek to improve access to health services, enhance public health, advance generalizable knowledge and relieve government burden
• Must be documented community need
• Must be part of the defined community served
• Not Community Building (Schedule H Part II)
• But note the IRS has now stated that some Community Building Activities may also qualify as Community Benefit expenditures
• May be a nominal patient fee 19
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2011Form990ScheduleHPartIFinancialAssistance,CharityCareandCommunityBenefits
atCost:TheCommunityBenefitPercentage
• Other Benefits: Community Health Improvement Services and Community Benefit Operations / Cash and In‐Kind Contributions to Community Groups (continued)
• Services available to the public and serving low‐income consumers
• Services designed to reduce barriers to accessing health services (e.g., geographic, financial, or cultural )
• Services which if ceased to exist would result in access problems (e.g., increase wait times or travel distances)
• Note: Interpreter Services Do Not Count
• Services which address federal, state, or local public health priorities.
• Services provided leveraging government activities/resources ok (e.g. immunization efforts).
• Services which otherwise would become the responsibility of government or another tax‐exempt organization.
• Advance knowledge through education or research that benefits the public.20
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2011Form990ScheduleHPartIFinancialAssistance,CharityCareandCommunityBenefits
atCost:TheCommunityBenefitPercentage
• Other Benefits: Health Professions Education
• Result in degree, certificate or training required for license to practice under state law
• Not training specifically for employees or medical staff (ie. employee CME doesn’t count)
• Includes GME and programs to educate broad base of health professionals
• Medicare GME revenue and tuition, if any, for other paramedical programs must be reported as an offset
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2011Form990ScheduleHPartIFinancialAssistance,CharityCareandCommunityBenefits
atCost:TheCommunityBenefitPercentage
• Other Benefits: Subsidized Health Services
• Clinical services provided despite financial loss (after adjusting for bad debt, charity care, Medicaid and means tested programs)
• Must provide to community because meets identified need
• Inpatient – neonatal intensive care, psychiatric
• Ambulatory – ED/Trauma, satellite clinics, home health, certain SNFs
• Ancillary services – anesthesiology, radiology, lab
• Note: Medicare shortfall can be counted here…but need to adjust Medicare disclosure on Schedule H Page 2
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2011Form990ScheduleHPartIFinancialAssistance,CharityCareandCommunityBenefits
atCost:TheCommunityBenefitPercentage
• Other Benefits: Research
• “Any study or investigation the goal of which is to generate … knowledge that is made available to the public”
• Fundamental Bench Research and Clinical Trials (evaluation of safety and efficacy)
• Lab based studies
• Health Outcomes Research
• Behavioral and Sociological studies related to health, delivery of care and/or prevention
• Studies related to changes in the health care delivery system
• Costs associated with Communicating findings and observations (including journal costs)
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2011Form990ScheduleHPartIFinancialAssistance,CharityCareandCommunityBenefits
atCost:TheCommunityBenefitPercentage
• Other Benefits: Research (continued)
• Examples of Costs
• Salaries and benefits to researchers and research staff
• Facilities, Equipment and Supplies
• Computer and other Support Services
• Research Compliance Costs
• Reporting of Offsetting Revenue NOT Required for Certain Funding Sources:
• Government Funding (i.e. NIH, State, Local)
• Other Tax Exempt Funding
• Self‐Funded or Contribution Funding (exception – restricted contribution from affiliate) 24
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2011Form990ScheduleHPartIICommunityBuildingActivities
• Cost of activities to protect or improve the community’s health or safety, and not reportable as Charity Care, Bad Debt or Community Benefit
• Activities include:
• Physical improvements / housing;
• Economic development;
• Community support;
• Environmental improvements;
• Leadership development and training for community members;
• Coalition building;
• Community health improvement advocacy;
• Workforce development; and other
• Note: Look at the underlying activities carefully. Activities that look/sound like Community Building may in fact be Community Benefit and vice versa.
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2011Form990ScheduleHPartIIIBadDebt,MedicareShortfall,CollectionPractices
• Bad Debt Expense
• Bad debt estimate associated with patients “likely” eligible for charity care & not reported as charity care
• New for 2011 – No longer needs to be reported at cost
• Required in narrative disclosure:
• Description of costing methodology used to determine bad debts
• Footnote language from the organization’s financial statements on bad debt expense is required
• Medicare Surplus or Shortfall
• Report all Medicare allowable costs reported in the organization’s Medicare Cost Report (less amounts reported as subsidized health services on Line 7)
• Collection Practices
• Written Debt Collection Policy in place?
• Additional Questions to those included on Page 1 of Schedule H and in the new Part V Section B
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2011Form990ScheduleHPartIVManagementCompaniesandJointVentures
• Joint Venture / Management Company Detail
• IRS is looking for arrangements with physicians, management or governing body members with ownership interests
• This Management Company detail may be different from review of management services for Schedule K and private use
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2011Form990ScheduleHPartVFacilities
• Hospital Facilities• Must list all of the organization’s hospital facilities operated during the tax year
• Facilities required to be licensed, registered or similarly recognized as a hospital under state law
• Operated directly by the reporting organization; or
• Operated indirectly through a disregarded entity or joint venture treated as a partnership
• List largest to smallest
• Must complete a separate Schedule H Section B for EACH Hospital Facility listed in Section A 28
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2011Form990ScheduleHPartVFacilitiesBackdrop:WhyCommunityHealthNeeds
AssessmentsWillBeCritical
• The hospital’s assessment of the community’s health needs, based on community representatives’ input, and the later implementation strategy, that identifies which needs the hospital will try to meet, are public documents (one on the hospital’s web site, the other in the 990)
• The public disclosure of these documents is intended to promote accountability by the hospital to the community or communities it serves
• Very difficult to adopt a bright line exemption standard that is fair and takes into account the diverse and significant variations across the universe of nonprofit hospitals
• What better way to assess whether a hospital should be tax exempt than to examine whether the hospital has surveyed the community for prioritized health needs, and helped to satisfy important needs which are not being met elsewhere?• Both an opportunity and a risk
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2011Form990ScheduleHPartVFacilities:CHNAInquiries
• Did the Hospital conduct a CHNA during the tax year? If yes, did it (check the boxes):
• Include a definition of community?
• Include community demographics?
• Describe health care facilities and resources available to respond to the communities’ health needs?
• Describe how was data obtained?
• Describe the heath needs of the community?
• Describe primary and chronic health needs and other health issues of uninsured, low‐income and minority populations?
• Describe the process for consulting with community representatives?
• Describe information gaps which impede assessing community needs / additional?
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2011Form990ScheduleHPartVFacilities:CHNAInquiries
• Does the CHNA process include input from community representatives?
• Describe how the information is reflected in the CHNA
• Identify the individuals• Notice 2011‐52 requires identification of individuals by name, title and affiliation
and requires description of each individuals’ expertise
• Was the CHNA conducted with other hospitals? If yes, provide a list
• Was the Hospital’s CHNA made widely available? How?
• All “Describe” questions provide both an opportunity and a risk within both the CHNA and Implementation Plan, and on the Schedule H
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2011Form990ScheduleHPartVFacilities:CHNAInquiries
• If the Hospital addressed identified needs, how were they addressed? (check the boxes):
• Adoption of Implementation Strategy• Execution of Implementation Strategy• Participation in developing a community‐wide community benefit plan• Participation in executing a community‐wide community benefit plan• Including a community benefit section in operational plans• Adopting a budget to address community needs identified in the CHNA• Prioritization of community health needs• Other
• Did the Hospital address all of the needs identified in the health assessment? If not, explain which were not addressed and why
• i.e. Limited financial or other resources
• Note: Although these CHNA questions remain optional for the 2011 Schedule H, each hospital needs to be aware of the CHNA requirements as they are currently law
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2011Form990ScheduleHBackdrop:StatutoryRequirements–Qualified
FinancialAssistanceandEmergencyCarePolicies
• To preserve IRC §501(c)(3) status a hospital must establish a written financial assistance policy (and a policy related to emergency medical care) that describes:
• The eligibility for financial assistance, and whether such assistance includes free or discounted care
• The basis for calculating amounts charged to patients
• The method for applying assistance
• The actions an organization may take to collect outstanding debts
• Methods to widely publicize the financial assistance policy
• A written policy requiring the organization to provide nondiscriminatory emergency care (as defined in 42 USC 1395dd) regardless of the ability to qualify under the written financial assistance policy
• This is a statutory, facility by facility requirement under IRC §501(r)(4)
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2011Form990ScheduleHPartVFacilities:FAPInquiries
• Did the hospital have a written financial assistance policy (FAP) which:
• Explains eligibility criteria for free and discounted care
• Use Federal Poverty Guidelines (FPG)? or if not, explain criteria
• Explains the basis for calculating patient charges (check the box)
• Income
• Assets
• Medical indigency
• Insurance status
• Uninsured discount
• Medicaid / Medicare
• State regulations
• Other
• Explains methods for applying financial assistance34
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2011Form990ScheduleHPartVFacilities:FAPInquiries
• Was the FAP publicized within the community? How?
• Hospital website?
• Attached to invoices?
• Posted in emergency department or waiting rooms?
• Posted in admissions office?
• Provided in writing to patients on admission?
• Available on request?
• Other
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2011Form990ScheduleHBackdrop:StatutoryRequirement–LimitationonCollectionEfforts
• To preserve IRC §501(c)(3) status a hospital cannot engage in extraordinary means of collection until reasonably exploring the eligibility for assistance under the financial assistance program
• Extraordinary collections include:• Lawsuits• Liens on residences• Arrests• Body attachments• Other similar collection processes
• Reasonable efforts include: • Notification by the hospital of its financial assistance policy upon admission• Written & oral communications regarding the patient’s bill before collection action
• Invoices• Telephone calls
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2011Form990ScheduleHPartVFacilities:FAP,Billingand
CollectionsInquiries
• Did the hospital have a separate billing and collection policy or a written FAP explaining collection procedures and methods?
• Were the following allowed under the policy before making reasonable efforts to determine eligibility under the FAP (directly or via a third party):
• Credit agency reporting
• Lawsuits
• Liens
• Body attachments
• Other similar collection processes
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2011Form990ScheduleHPartVFacilities:FAP,Billingand
CollectionsInquiries
• Did the hospital engage in any of the following before making reasonable efforts to determine eligibility under its FAP (directly or via third party)?
• Credit agency reporting
• Lawsuits
• Liens
• Body attachments
• Other similar collection processes
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2011Form990ScheduleHPartVFacilities:FAPand
EmergencyMedicalCareInquiries
• Did the hospital have a written FAP in place relating to emergency care that requires the hospital to provide emergency medical care without discrimination and without regard to the patients eligibility under the FAP? If not, why (check the box)?
• Hospital does not provide any emergency care
• Hospital policy was not in writing
• Hospital limited who was eligible to receive care for emergency medical care
• Other
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2011Form990ScheduleHPartVFacilities:FAPand
EmergencyMedicalCareInquiries
• How does the hospital determine the maximum amounts to charge FAP eligible individuals for emergency and other medically necessary care (check the box)?
• Lowest negotiated commercial rate
• Average of the three lowest commercial rates
• Medicare rates
• Other
• Did the hospital charge any FAP eligible patient more than amounts generally billed to individuals who had insurance for emergency or other medically necessary care? If yes, explain
• Did the hospital charge any FAP eligible patients gross charges for any service provided? 40
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2011Form990ScheduleHPartVFacilities
• Other Health Care Facilities that are not Licensed, Registered or Similarly Recognized as a Hospital
• Name, Address, Type of Facility
• What is an “Other Health Care Facility?”
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2011Form990ScheduleHPartVISupplementalInformation
• Additional Burden or Opportunity?
• Face of Form 990 Schedule H is 8 pages
• Narrative for a large academic medical center could be 80 pages or more
• Some (not all) of Required Explanatory Detail:
• Methodology for determining free or discounted care if other than FPG
• How Community Benefit Report is made public
• Any physician clinic included in Subsidized Health Services
• Graduate medical education and other paraprofessional training programs
• Research contributions to the advancement of science
• Methodology for calculating total expenses used as the denominator in Line 7, if back out bad debt or add joint venture expenses 42
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2011Form990ScheduleHPartVISupplementalInformation
• Some (not all) of Required Explanatory Detail (continued):
• Community Building Activities and how they promote community health
• Bad Debt Expense Footnote, costing methodology and rationale for including a portion of bad debt in charity care
• Extent to which Medicare shortfall should be considered charity care
• How the hospital’s collection policy apply to the largest number of patients qualifying for financial assistance
• Supplementary detail related to the CHNA definition of community, methodology, process and implementation
• Respective roles of reporting hospital and its affiliates if within an affiliated system of entities
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TrendsInDataReportingbyScheduleHFilers
• Part I, Question 7, Community Benefit Expenditure Table – percentages, gross v. net cost
• Community Building
• Medicare and Bad Debt Expense
• Supplemental information – Part VI
• Community being served
• Roles of others within the system44
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ReportingDifficulties,ChallengesandKeyAreasofFocusRelatedtoScheduleH
• Part I Community Benefit Expenditures and Percentages• Is a dollar of charity care worth more than a dollar of research, or education, or other CBE items?
• Government program (e.g., Medicaid) amounts – is net cost the right measure?
• How do you adjust the calculation denominator if you only have net joint venture activity?
• Part II Community Building • Should any of this be moved to Part I for credit as community benefit?• How do you account for “environmental initiatives” expenses (i.e. Efficient transportation vehicles or facilities operational equipment may have higher cost but result in decreased particulates in the immediate environment)?
• Measure by full cost of asset?• Measure by additional cost of asset?• Allocation of depreciation or interest?• Other?• Are these expenses CBEs?
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ReportingDifficulties,ChallengesandKeyAreasofFocusRelatedtoScheduleH(continued)
• Part III – Medicare shortfalls
• if a Medicare Accountable Care Organization is regarded as lessening the burdens of government, an exempt purpose, should Medicare also count as Community Benefit?
• Practical and Procedural Issues – Items to Consider
• To withstand challenge its own organization is not doing enough –organization has an interest in making sure its reported information looks good relative to others
• To withstand challenge the nonprofit hospital sector is not doing enough –organization also has an interest in the entire sector reporting information that is accurate and looks good on the whole 46
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ReportingDifficulties,ChallengesandKeyAreasofFocusRelatedtoScheduleH(continued)
• Practical and Procedural Issues – Items to Consider (continued)
• Who and how many “sit around the Schedule H preparation table” with Tax?
• Community Benefit
• Reimbursement
• General Finance
• Financial Services / Billing and Collections
• Graduate Medical Education
• Research
• Other??
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ReportingDifficulties,ChallengesandKeyAreasofFocusRelatedtoScheduleH(continued)
• Practical and Procedural Issues – Items to Consider (continued)
• Which Board Committee(s) is / are best suited to review Schedule H before filing with the IRS?
• Finance?
• Audit?
• Compliance?
• Community Benefit?
• Other?
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ChallengestoIRSastheTaxAdministrationAgency
• Developing the answers to the difficult technical questions raised by the law and addressed in public comments
• Coordinating the reporting requirements of the new Schedule H (and any future changes to that schedule) with substantive guidance
• How does the IRS enforce the new substantive rules, taking into account the information it gets on the new schedule?
• How will the IRS apply on a facility by facility basis and what are the consequences?
• What will the IRS learn from the three year reviews and how does the Schedule H fit in with that?
• Will it have the resources it needs to conduct the Congressionally mandated studies?
• How will it administer the operational detail included in the section 501(r) regulations once they are made temporary or final?
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PotentialImplicationsofProposed§501(r)RegulationsonScheduleHReporting
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26
Questions&Answers
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Bio
Ronald J. Schultz
Ron Schultz joined PwC's Washington, DC Exempt Organization National Tax practice in January 2011, where he advises the firm's nonprofit clients in the health care, higher education, and private foundation areas. Ron came to PwC from the Internal Revenue Service where he held a number of key advisory positions from 2006 through 2010. These included Senior Technical Advisor positions to the Commissioner of Tax Exempt and Government Entities (TEGE) and to the Deputy Commissioner for Services and Enforcement. Prior to that, Ron served as Legislation Counsel on the Staff of the Joint Committee on Taxation of the United States Congress and practiced tax law, specializing in exempt organization and nonprofit law in Minneapolis, Minnesota.
While at the IRS, Ron worked extensively in the development and implementation of major exempt organization projects, including the redesigned IRS Form 990, nonprofit hospital reporting, foreign activities, joint ventures and other related organizations, insider transactions, executive compensation, and governance. He also assisted in the design and implementation of IRS EO compliance initiatives and programs pertaining to nonprofit governance, executive compensation, unrelated business income tax, nonprofit hospitals, and public and private colleges and universities. Ron worked extensively on the design and implementation of the Form 990 Schedule H.
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Bio
Karen L.P. Wolfson (Karen L. Printz Wolfson)
Karen is the Director, Taxation for the CareGroup, Inc. and its affiliated entities which combined are a regional health care delivery system located in Boston, MA and the surrounding communities. CareGroup is comprised of tax‐exempt teaching and community hospitals, physician groups and other taxable and non‐taxable entities. Beth Israel Deaconess Medical Center, a non‐profit tertiary care academic medical center and teaching affiliate of Harvard Medical School, is a member.
In her role Karen is responsible for advising senior management and handling both large and small matters related to tax compliance, special projects and other tax matters. She has extensive experience with Form 990, Form 1023, Form 5500 and associated filings; unrelated business income analysis and reporting; foreign national taxation analysis and reporting; private use of bond financed facilities’ analysis; bond offering tax due diligence; human resources and payroll tax issues review, analysis and tax compliance, including medical resident FICA issues; real estate tax issues and other matters. Karen regularly makes presentations to the affiliate Boards and Board Committees related to the Form 990 and its various disclosures and other tax matters and has also worked with the Massachusetts Hospital Association to educate member hospitals on the expanded compliance requirements when the IRS released its overhauled Form 990 and related schedules and other tax matters.
Prior to her current role, Karen worked in the Tax Department of Coopers & Lybrand’s Boston office. Combined she has over 20 years of experience working tax‐exempt organizations.
Karen has a B.S. in Economics from The Wharton School, University of Pennsylvania and a J.D. from Boston University. She is a member of the Massachusetts Bar Association, American Health Lawyer’s Association, Healthcare Financial Management Association and various other organizations.
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ContactInformation
• Karen L.P. Wolfson
Director, Taxation
CareGroup, Inc.
617‐667‐1885
• Ronald J. Schultz
Managing Director, EOTS
PricewaterhouseCoopers
202‐346‐5096 54
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