On June 29, 2026, Representative Greg Murphy (R-NC), joined by Representative Lloyd Smucker (R-PA), introduced H.R. 9504, the Tax Exempt Hospital Transparency Act. The bill was referred to the House Committee on Ways and Means and approved for floor consideration on July 1, 2026. As introduced, the bill would add a new Section 6033A to the Internal Revenue Code (IRC) and create a hospital-specific reporting regime for tax-exempt hospital organizations. The proposal would build on the existing §501(r) community benefit framework and, in several respects, require more granular reporting than is currently reflected on Form 990, Schedule H.
What New Reporting Requirements Would H.R. 9504 Create for Tax-Exempt Hospitals?
At a high level, H.R. 9504 would require tax-exempt hospital organizations to report additional information regarding Community Health Needs Assessment (CHNA) implementation (§501(r)(3), financial assistance applications received, granted, and denied, financial assistance provided at cost under the financial assistance policy (§501(r)(4)), and CMS certification information. The bill would also carry forward the existing audited financial statements reporting requirement into the proposed new §6033A. The proposal is significant because it would expand tax-exempt hospital reporting into areas that may not currently be captured, classified, or maintained in a manner that supports Form 990 reporting. The legislation would add new CHNA, financial assistance, facility-level, health service line, advertising, and 340B reporting elements, raising practical questions about whether hospitals can collect, classify, reconcile, and support the required information through existing systems and controls.
The proposal would include additional reporting tiers for hospital organizations that meet either of the bill’s defined categories: “large tax-exempt hospital organization” or “high revenue tax-exempt hospital organization.” Large tax-exempt hospital organizations would report additional CHNA priority, spending, impact, quality-improvement, and “nonclinical-programming” information. High revenue tax-exempt hospital organizations would report additional advertising, health service line revenue and cost, and 340B information, if applicable. For multi-hospital systems, the facility-level reporting requirement may be one of the proposal’s most important practical implications, particularly where data is currently tracked or reviewed on a consolidated basis.
The health service line reporting requirement may warrant particular attention because it would require “high revenue” organizations to connect internal service line accounting to a standardized federal taxonomy. H.R. 9504 would require Health and Human Services (HHS), in consultation with the U.S. Department of the Treasury, to publish that taxonomy within two years after enactment. The bill also would treat certain Medicare cost report cost centers as presumptive health service lines unless the organization demonstrates otherwise.
Forvis Mazars Insight: H.R. 9504 should also be viewed alongside H.R. 3019, the Holding Nonprofit Hospitals Accountable Act, which would amend §501(r) to add a quantified community benefit spending standard tied to the value of a hospital organization’s federal, state, and local tax exemptions. Together, the bills reflect continued congressional interest in tax-exempt hospital transparency, community benefit measurement, financial assistance reporting, and facility-level accountability. H.R. 9504 is primarily a reporting bill, while H.R. 3019 would go further by proposing a quantified community benefit standard.
What Should Tax-Exempt Hospitals Watch if H.R. 9504 Advances?
Because H.R. 9504 has only been introduced and its ultimate passage remains uncertain, tax-exempt hospital organizations do not need to treat the proposal as a current compliance obligation. However, the bill may be useful as an indicator of the types of reporting issues continuing to draw congressional attention. Tax-exempt hospital organizations, particularly those with more than 100 staffed inpatient beds, more than $100 million in net patient revenue, multiple hospital facilities, 340B activity, or complex service line accounting, should monitor the legislation and consider whether their current systems can support this level of reporting. Key areas to review include CHNA implementation tracking, financial assistance application data, cost-basis charity care calculations, service line revenue and cost accounting, 340B data, advertising cost classification, and facility-level reporting controls.
How Forvis Mazars Can Help
Our team will continue tracking these proposed bills and their implications for tax-exempt hospital reporting readiness. Please reach out if you would like to discuss how these proposals could affect hospital reporting readiness, §501(r) compliance, Schedule H processes, CHNA implementation tracking, financial assistance reporting, or facility-level data systems.