H.R. 9504: the Tax-Exempt Hospital Transparency Act
Recently introduced federal legislation could bring a new level of transparency to how nonprofit hospitals report community benefits. Here’s what’s in the bill and what it could mean for tax-exempt hospitals.
H.R. 9504, the Tax-Exempt Hospital Transparency Act, cleared the House Ways and Means Committee on July 1, 2026, just days after Representative Greg Murphy, a Republican from North Carolina, introduced it in late June.
The bill would add new disclosure requirements to IRS Form 990 Schedule H, the primary mechanism through which not-for-profit hospitals report the community benefit that justifies their tax-exempt status, with the scope of reporting tiered by hospital size and revenue, meaning large and high-revenue systems would face more detailed facility-level reporting than smaller organizations.
First introduced in 2008 as part of a broader Form 990 redesign, Schedule H gave the IRS and the public a standardized way to track community benefit, charity care, health education, and other services nonprofit hospitals provide in exchange for their tax-exempt status.
A few years later, the Affordable Care Act layered on additional requirements under section 501(r), things like community health needs assessments (CHNAs), financial assistance policies, and billing and collection practices. H.R. 9504 would be the next chapter, pushing hospitals toward even more granular, facility-level reporting.
With this new bill, Schedule H’s scope would become even sharper, asking questions hospitals have never had to answer publicly before. H.R. 9504 doesn’t treat every hospital the same. The bill establishes a baseline set of disclosures that would apply to every tax-exempt hospital, then layers on more detailed, facility-level requirements for large and high-revenue tax-exempt hospital organizations. In this report, we break down what each tier would mean in practice, what areas of a hospital’s work are impacted, and how the 340B prescription program may be even more regulated.