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The new requirement that IRS review tax-exempt hospitals' community benefit activities every three years will not be an examination and will not be a compliance check, Tax Exempt and Government Entities Commissioner Sarah Hall Ingram says. “We have already started doing them. We don't tell you when we're looking,” she says. “We look at public records. We look at the Form 990 and other returns that might not be public that we have in our possession, and we look at stuff in the public [domain]. We are supposed to be getting a deeper understanding of the sector, looking for trends, looking for things we could do to fix returns, to provide more education, and to adjust our compliance selection criteria,” she says. The Patient Protection and Affordable Care Act put new requirements on both tax-exempt hospital practitioners and IRS, leading some in the exempt sector to worry about the outcome of IRS oversight in new areas. For IRS, health care-related issues have jumped to the forefront of its attention.
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