In Part IV, you’ll list certain management companies, joint ventures, and other entities, of which you’re a partner or shareholder. This includes entities outside the US. Entities should be listed if they fall into both of these categories:

  1. At least 10% of the share of profits of a partnership, LLC interest, or stock of a corporation is owned by one or more
    1. People who were officers, directors, trustees, or key employees of your organization at any time during the fiscal year you’re reporting on your Form 990, and/or
    2. Physicians who were employed as physicians, or had staff privileges, at one or more of your hospitals
  2. Either:
    1. Provided management services used by your organization in your provision of medical care, or
    2. Provided medical care, or owned or provided real property, tangible property, or intangible property that you or others use to provide medical care.

When calculating the 10% ownership, include both direct and indirect ownership interests. For example, if a joint venture is partially owned by a physician group practice, and the group practice is owned by physicians on staff at your hospital, include the physicians’ ownership of the joint venture, proportionally to their ownership share of the group practice. E.g. if the physicians own 50% of the group practice, and the group practice owns 40% of the joint venture, then the physician’s own 20% of the joint venture.

If an organization is publicly traded, or only has revenue that’s passive income from interest or dividends, don’t include it in Part IV.

When calculating the ownership percentages of people described in point 1 above, measure the ownership on the earlier of:

  1. The last day of the fiscal year you’re reporting on your Form 990
  2. The last day you were a member of the joint venture

In the chart in Part IV, provide information about each entity that meets the criteria at the top of this post.

  • Column (a): the legal name of the entity
  • Column (b): the primary business activity or activities of the entity
  • Column (c): the percentage of the entity that your organization owns, measured as the share of profits of a partnership or LLC, or stock in a corporation
  • Column (d): the percentage of the entity owned by your organization’s current officers, directors, trustees, or key employees
  • Column (e): the percentage of the entity owned by physicians who are employed as such or have staff privileges with one or more of your organization’s hospitals
  • If a physician meets the criteria of both column (d) and (e), report him or her in column (d).

Schedule H can be found here, and more detailed instructions for filling it out are provided here. I am covering other parts of Schedule H in additional posts. (Part I | Part II | Part III)