H.R. 9504, the Tax-Exempt Hospital Transparency Act, is proposed federal legislation focused on expanding annual reporting and public transparency requirements for tax-exempt hospital organizations. The bill was scheduled for markup by the House Committee on Ways and Means on July 1, 2026. As of this date, it’s not an enacted law.
If enacted, H.R. 9504 would add a new IRC Section 6033A requiring expanded annual return reporting by tax-exempt hospital organizations. The proposal is primarily a transparency and reporting bill with a focus on expanded disclosures for Form 990, Schedule H.
For acute care hospital leaders, the significance is that information traditionally tracked for tax compliance, community benefit, financial assistance, service line profitability, advertising, and 340B program administration could become more detailed, more standardized, and more publicly visible through the Form 990 framework.
Hospitals don’t need to implement the proposed requirements today. However, hospital leaders should begin assessing data readiness now, particularly for facility-level reporting, financial assistance at cost, application approval and denial data, health service line revenue and cost accounting, shared cost allocation methods, advertising cost classification, and 340B reporting.
What H.R. 9504 is
H.R. 9504, the Tax-Exempt Hospital Transparency Act, is a proposal that would expand annual information reporting for tax-exempt hospital organizations by adding new IRC Section 6033A. At a high level, the bill would require tax-exempt hospitals to disclose more information regarding:
- How the hospital addresses community health needs identified in their most recent community health needs assessment.
- Audited financial statements.
- CMS certification numbers.
- The value, at cost, of financial assistance provided.
- The number of completed financial assistance applications received, granted, and denied.
- For larger hospitals, high-priority health needs, related spending, actions taken, and impact of actions.
- For higher-revenue hospitals, advertising costs and health service line gross receipts and cost information.
- For 340B-covered entities, specified information about 340B utilization, payment amounts, and program costs.
The proposal builds on the existing tax-exempt hospital reporting framework. Under current law, hospital organizations subject to IRC Section 501(r) must satisfy requirements relating to community health needs assessments, financial assistance policies, patient charges, and billing and collection practices. Current IRC Section 6033 already requires organizations subject to Section 501(r) to report how they are addressing needs identified in community health needs assessments and to provide audited financial statements.
H.R. 9504 would expand that framework by adding more granular reporting obligations, with particular focus on financial assistance, community benefit, service line economics, advertising, and 340B information.
Why acute care and finance leaders should pay attention
H.R. 9504 would move several high-sensitivity hospital finance and community benefit topics into a more explicit public reporting framework. Acute care and finance leaders should keep the below top of mind as it may help prepare health systems for future impact.
1. Expanded Form 990 reporting means expanded public visibility
The proposal would operate through annual return reporting. Current public inspection rules generally require 501(c)(3) exempt organizations to make annual returns filed available for public inspection.
The Joint Committee on Taxation description states that information required under the proposal would be treated as information required and generally subject to public inspection. That means these disclosures may be reviewed not only by the IRS, but also by policymakers, media, unions, rating agencies, community groups, competitors, plaintiffs’ attorneys, and other members of the public.
2. The proposal reaches beyond tax compliance
Although the bill is housed in the tax reporting framework, the operational implications extend across the organization. Depending on the hospital’s facts, implementation may require coordinated input from:
- Finance and accounting
- Tax and Form 990 preparation teams
- Community benefit and population health teams
- Revenue cycle and patient financial services
- 340B program administration
- Managed care and reimbursement
- Marketing and communications
- Legal and compliance
- Data analytics and cost accounting
- Executive leadership and board committees
3. Service line reporting could be operationally sensitive
High-revenue tax-exempt hospital organizations would be required to report specified health service line information, including a description of each service line, gross receipts generated by each line, and costs of each line, including cost allocation methods for shared costs. For acute care hospitals, that could involve areas such as emergency services, surgery, cardiology, oncology, orthopedics, women’s services, behavioral health, and other service lines once the federal taxonomy is developed.
The disclosure of service line economics may raise strategic, competitive, and reputational considerations, particularly where profitable service lines are viewed alongside charity care, community benefit, and unmet community needs.
4. Financial assistance reporting may invite comparisons
All tax-exempt hospital organizations would report the value, at cost, of financial assistance provided (FAP) and the number of completed financial assistance applications received, granted, and denied. These figures may be compared across facilities, systems, regions, and peer organizations.
Because current Section 501(r) rules already require tax-exempt hospitals to maintain financial assistance policies, limit charges for FAP-eligible patients, and restrict extraordinary collection actions before making reasonable efforts to determine FAP eligibility, hospitals should expect any new financial assistance reporting to be assessed in the broader context of community benefit, billing practices, and patient affordability.
Key proposed changes for reporting
New reporting for all tax-exempt hospital organizations
- H.R. 9504 would require all tax-exempt hospital organizations to report:
- How the organization is addressing needs identified in its most recent community health needs assessment.
- Which identified needs are not being addressed and why.
- Audited financial statements.
- CMS certification number.
- The value, at cost, of financial assistance provided during the taxable year.
- The number of completed financial assistance applications received, granted, and denied.
For many tax-exempt acute care hospitals, some of this information is already part of current reporting or internal tracking. The proposal, however, would make financial assistance cost and application disposition data more explicit.
Additional reporting for “large” tax-exempt hospital organizations
A “large” tax-exempt hospital organization generally means a tax-exempt hospital organization that:
- Is not a critical access hospital.
- Is not a rural emergency hospital.
- Has more than 100 staffed inpatient beds.
Large tax-exempt hospital organizations would also report:
- The three highest priority health needs identified in the most recent community health needs assessment (CHNA).
- Spending on programs addressing each priority need.
- Actions taken to address each need.
- The impact of those actions on community health.
- Spending on quality improvement, nonclinical programming, and other community benefits prescribed by the Secretary.
This may require hospitals to more clearly connect CHNA priorities, implementation strategy commitments, budgeted and actual spending, operational activities, and measurable community impact.
Additional reporting for “high-revenue” tax-exempt hospital organizations
A “high-revenue” tax-exempt hospital organization generally means a tax-exempt hospital organization that:
- Is not a critical access hospital.
- Is not a rural emergency hospital.
- Has more than $100 million of net patient revenue, adjusted for inflation.
High-revenue tax-exempt hospital organizations would also report:
- Specified advertising information.
- Specified health service line information.
- For covered 340B entities, specified Federal 340B drug discount program information.
Specified advertising information would include allowable and unallowable advertising costs reported to CMS.
Specified health service line information would include:
- A description of each health service line.
- Gross receipts generated by each service line.
- Costs of each service line, including cost allocation methods for shared costs.
For covered 340B entities, required information would include:
- The total number of individuals, by insurance type, who received 340B drugs.
- The aggregate net 340B payment amount.
- The aggregate costs of participating in and complying with the 340B program.
Facility-level reporting
For large and high-revenue organizations, required information generally would need to be separately stated for each hospital facility.
For multihospital systems, this may be one of the most operationally significant aspects of the proposal. System-level community benefit, finance, 340B, and cost accounting data may need to be disaggregated and validated at each facility level.
How to prepare now
H.R. 9504 is not yet enacted, but it’s a clear signal that Congress continues to scrutinize hospital tax exemption, community benefit, financial assistance, service line economics, and 340B transparency. Acute care hospital leaders should use this period to:
- Assign ownership for monitoring H.R. 9504 and related guidance.
- Map applicability across hospitals and facilities.
- Assess data readiness for financial assistance, CHNA, service line, advertising, and 340B reporting.
- Identify gaps in facility-level reporting and cost allocation methods.
- Prepare a public disclosure narrative that connects financial data to mission, access, and community benefit.
- Brief executive leadership and the board on potential operational, financial, compliance, and reputational implications.
Even if the bill changes, the direction of travel is clear: tax-exempt hospitals should expect continued pressure for more detailed, standardized, and publicly accessible reporting on the value they provide to their communities.
