An IRS official confirmed, while speaking at an American Health Lawyers Association conference on October 16th, that the IRS has identified 3,377 tax-exempt hospitals that are being reviewed for compliance with the tax exemption community benefit standard.The reviews will be conducted by the IRS review of operations unit in three annual waves and will look at those hospitals’ Form 990 annual information return. Hospitals will not be notified of the reviews and will not know when the reviews begin or end. The first wave of reviews already began last April.

The IRS identified the hospitals through a search of (i) IRS systems, (ii) a Medicare/Medicaid website with hospital information, and (iii) District of Columbia websites for newly licensed hospitals.

The Affordable Care Act requires the IRS to conduct a community benefit review every three years.

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