On July 22, the AHA provided comments to the IRS on its request for additional comments on tax exemption. The ACA imposes four requirements on hospitals that seek to qualify for and maintain tax-exempt status. The requirements are for a health needs assessment, a financial assistance policy, a limitation on charges, and billing and collections. Although the community health needs assessment requirement is effective for tax years beginning after March 23, 2012, the remaining three requirements are effective immediately.
The AHA urges the Departure of Treasury and the IRS to seek formal legislative action to establish a "reasonable "cure" period for any failure to meet the new requirements, such as the later of 90 days or the end of the fiscal year in which the failure is discovered.