The Senate Finance Committee released on September 16th its health care reform bill, America’s Health Future Act. The bill proposes additional requirements for nonprofit hospitals, including the following:

• Community Needs Assessment. To be preformed at least once every three years with input from the community and the assistance of individuals with special knowledge or expertise of public health issues.

• Community Benefit Review. To be performed by the IRS at least once every three years based on information provided in the IRS Form 990.

• HHS Annual Reports to Congress. To report levels of charity care, bad debt expenses, unreimbursed costs of government programs and the cost of community benefit activities. • Promotion of Financial Assistance Policy. Creation and implementation of a policy to widely publicize the health care organization’s financial assistance policy and how to apply for assistance, and to prevent discrimination against those eligible for financial assistance who seek emergency treatment.

• Limitation on Charges & Collections. Limitation on billing patients who qualify for financial assistance to no more than the amount generally billed to insured patients and a limitation on taking extraordinary collection actions against patients without first making attempts to inform the patient about the health care organization’s financial assistance policy.

If passed, some of these requirements could directly affect health care philanthropy. For example, the community needs assessment could become the responsibility of development offices and supporting foundations. And ensuring that your health care organization is fully reporting community benefit in their IRS Form 990 will become that much more important with the proposed IRS review.