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22nd Annual Health SciencesTax ConferenceImplementing Section 501(r): best practices andpitfalls on the road to complianceDecember 3, 2012

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Disclaimer► Any US tax advice contained herein was not intended or written to be used, and cannot be used, for the purpose of avoiding penalties that may be imposed under the Internal Revenue Code or applicable state or local tax law provisions. Implementing Section 501(r): best practices andPage 2 pitfalls on the road to compliance

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DisclaimerErnst & Young refers to the global organization of member firms of Ernst & YoungGlobal Limited, each of which is a separate legal entity. Ernst & Young LLP is a client-serving member firm of Ernst & Young Global Limited operating in the US. For moreinformation about our organization, please visit www.ey.com.This presentation is © 2012 Ernst & Young LLP. All rights reserved. No part of thisdocument may be reproduced, transmitted or otherwise distributed in any form or byany means, electronic or mechanical, including by photocopying, facsimiletransmission, recording, rekeying, or using any information storage and retrievalsystem, without written permission from Ernst & Young LLP. Any reproduction,transmission or distribution of this form or any of the material herein is prohibited andis in violation of US and international law. Ernst & Young LLP expressly disclaims anyliability in connection with use of this presentation or its contents by any third party.Views expressed in this presentation are not necessarily those of Ernst & Young LLP. Implementing Section 501(r): best practices andPage 3 pitfalls on the road to compliance

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Presenters► Jeanne Schuster ► Amy Dosik Ernst & Young LLP Ernst & Young LLP Boston, MA Atlanta, GA + 1 617 585 0373 + 1 404 817 5488 jeanne.schuster@ey.com amy.dosik@ey.com Implementing Section 501(r): best practices andPage 4 pitfalls on the road to compliance

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Introduction to IRC Section 501(r)► Affordable Care Act (ACA) enacted new Internal Revenue Code (IRC) Sec. 501(r); law signed on March 23, 2010► U.S. Supreme Court upheld ACA on June 28, 2012► Sec. 501(r) — added four new requirements for a hospital to qualify for exemption under Sec. 501(c)(3) ► Sec. 501(r) — affects existing exempt hospitals and new hospitals applying for exemption Implementing Section 501(r): best practices andPage 5 pitfalls on the road to compliance

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Introduction to IRC Section 501(r) (cont.)► Sec. 501(r) imposes four new requirements for hospitals to qualify for Sec. 501(c)(3) exemption: ► Sec. 501(r)(3) — community health needs assessment ► Effective: taxable years beginning after 3/23/12 ► Sec. 501(r)(4) — financial assistance policy ► Sec. 501(r)(5) — limitation on charges ► Sec. 501(r)(6) — billing and collection requirements ► Effective: taxable years beginning after 3/23/10 Implementing Section 501(r): best practices andPage 6 pitfalls on the road to compliance

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Introduction to IRC Section 501(r) (cont.)► June 26, 2012 — U.S. Treasury Department and IRS issued proposed regulations: ► Sec. 501(r)(4) — financial assistance policy ► Sec. 501(r)(5) — limitation on charges ► Sec. 501(r)(6) — billing and collection requirements Implementing Section 501(r): best practices andPage 7 pitfalls on the road to compliance

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Introduction to IRC Section 501(r) (cont.)► Reliance on proposed regulations until final or temporary regulations are issued► Effective dates of final regulations: taxable years beginning on or after the date that final or temporary regulations are published in the Federal Register Implementing Section 501(r): best practices andPage 8 pitfalls on the road to compliance

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Introduction to IRC Section 501(r) (cont.)► Public comments on proposed regulations were due September 24, 2012. ► Comments were received from: ► American Hospital Association ► American Academy of Emergency Medicine ► Arizona Hospital Group ► California Children’s Hospital Association ► Massachusetts Law Reform Institute ► Others Implementing Section 501(r): best practices andPage 9 pitfalls on the road to compliance

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Introduction to IRC Section 501(r) (cont.)► Proposed regulations do not address Sec. 501(r)(3), Community Health Needs Assessments (CHNAs). ► Internal Revenue Service (IRS) Notice 2011-52 (July 7, 2011) addressed many Sec. 501(r)(3) issues. ► Hospitals can rely on Notice 2011-52 until six months after IRS issues further guidance. ► IRS will issue proposed regulations on CHNAs. Implementing Section 501(r): best practices andPage 10 pitfalls on the road to compliance

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Introduction to IRC Section 501(r) (cont.)► Proposed regulations include: ► Extensive detailed explanations ► Many specific rules and definitions ► Many helpful detailed examples► IRS requests comments on many issues not addressed► Estimated average annual burden hours per record- keeper: 11.5 Implementing Section 501(r): best practices andPage 11 pitfalls on the road to compliance

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Key Section 501(r) principle► A hospital organization that operates more than one hospital facility must meet each Sec. 501(r) requirement separately for each hospital facility. Implementing Section 501(r): best practices andPage 12 pitfalls on the road to compliance

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Hospital organization► Two-part definition: ► An organization exempt under Sec. 501(c)(3) (or which has applied for exemption under Sec. 501(c)(3)) that operates one or more hospital facilities ► Includes a hospital facility operated through a disregarded entity ► Includes “dual status” governmental hospitals also recognized as exempt under Sec. 501(c)(3) ► Comments requested on alternative methods that 501(c)(3) government hospitals may use to meet the Sec. 501(r) requirements (except CHNAs) Implementing Section 501(r): best practices andPage 13 pitfalls on the road to compliance

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Hospital organization (cont.) ► Any other organization if IRS determines that its principal function or purpose for Sec. 501(c)(3) exemption is the provision of hospital care ► Not explained in proposed regulations ► Comments requested on whether additional organizations should be included ► Until future regulations are effective – applies only to hospital organizations operating a hospital facility required by a state to be licensed, registered or similarly recognized as a hospital Implementing Section 501(r): best practices andPage 14 pitfalls on the road to compliance

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Hospital organization (cont.)► Partnerships► Notice 2011-52 (CHNAs): ► States that IRS intends to treat as a hospital organization any Sec. 501(c)(3) organization operating a hospital facility through a partnership ► Comments requested on whether (or under which circumstances) an organization should not be considered to operate a hospital facility as a result of owning a small interest (other than as a general partner) in a partnership that operates the hospital facility ► IRS to address partnerships in separate guidance Implementing Section 501(r): best practices andPage 15 pitfalls on the road to compliance

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Hospital facility► A facility required by a state to be licensed, registered or similarly recognized as a hospital ► A hospital organization may treat multiple buildings operated under a single state license as a single hospital facility. ► Future IRS guidance — whether a hospital organization operating in a single building under more than one state license is treated as one hospital facility or multiple hospital facilities. Implementing Section 501(r): best practices andPage 16 pitfalls on the road to compliance

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Failure to meet Sec. 501(r) requirements► Proposed regulations — consequences not addressed► IRS to address in separate guidance► Possible consequences: ► Revocation of Sec. 501(c)(3) exemption ► Correction within specified period ► Financial penalties ► De minimis exception ► Closing agreement ► Voluntary disclosure program ► A combination of these Implementing Section 501(r): best practices andPage 17 pitfalls on the road to compliance

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Discussion of proposed regulations► Sec. 501(r)(4) — financial assistance policy► Sec. 501(r)(5) — limitation on charges► Sec. 501(r)(6) — billing and collection requirements Implementing Section 501(r): best practices andPage 18 pitfalls on the road to compliance

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Sec. 501(r)(4) — financial assistancepolicy► Each hospital facility must establish a written: ► Financial assistance policy (FAP) that applies to all emergency and other medically necessary care the hospital facility provides ► Emergency medical care policy Implementing Section 501(r): best practices andPage 19 pitfalls on the road to compliance

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Sec. 501(r)(4) — financial assistancepolicy (cont.)► Requirements for FAP must include: ► Eligibility criteria for financial assistance and whether they include free or discounted care ► Basis of calculating amounts charged to patients ► Method of applying financial assistance ► Actions that may be taken in the event of non-payment (if organization does not have separate billing and collection policy) ► Measures to widely publicize the FAP in the community served by the hospital Implementing Section 501(r): best practices andPage 20 pitfalls on the road to compliance

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FAP eligibility requirements► The FAP must: ► Specify all financial assistance available under the FAP ► Specify all the eligibility criteria an individual must satisfy to receive free or discounted care or other level of assistance ► State that an individual determined to be FAP-eligible will not be charged more for emergency or other medically necessary care than the amounts generally billed (AGB) to individuals with insurance covering such care Implementing Section 501(r): best practices andPage 21 pitfalls on the road to compliance

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FAP eligibility requirements (cont.)► The FAP must: ► Describe the method used to determine AGB (the look-back method or the prospective Medicare method) ► If the look-back method is used, apply one of the following: ► State the AGB percentages and describe how they were calculated ► Explain how this information in writing may be obtained for free Implementing Section 501(r): best practices andPage 22 pitfalls on the road to compliance

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Method of applying for financial assistance► FAP must describe application process for financial assistance.► FAP or FAP application form (and instructions) must: ► Describe the information and documentation that may be required to be submitted ► Provide hospital staff with contact information regarding the FAP► Financial assistance may not be denied based on an applicant’s failure to provide information or documentation the FAP or FAP application form does not require. Implementing Section 501(r): best practices andPage 23 pitfalls on the road to compliance

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Actions that may be taken in the event ofnon-payment► The FAP (or a separate, written billing and collections policy) must describe: ► Any actions that may be taken to obtain payment of medical bill, including extraordinary collection actions (ECAs) ► The process and time frames used to obtain payment of a medical bill, including reasonable efforts hospital facility will make to determine whether an individual is FAP-eligible before engaging in any ECAs ► The office, department or committee having the final authority or responsibility to determine that the hospital facility has made reasonable efforts to determine whether an individual is FAP-eligible Implementing Section 501(r): best practices andPage 24 pitfalls on the road to compliance

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Sec. 501(r)(4) — financial assistance policy► If the hospital facility has a separate, written billing and collections policy, the FAP must: ► State that the actions that may be taken in the event of non- payment are described in a separate billing and collections policy ► Explain how a free copy of the separate policy can be obtained Implementing Section 501(r): best practices andPage 25 pitfalls on the road to compliance

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Widely publicizing the FAP► An FAP must explain that the hospital facility will publicize the FAP by: ► Making the FAP, the FAP application form and a plain-language summary of the FAP widely available on a website ► Making paper copies of the FAP, FAP application form and plain- language summary of the FAP available free upon request ► Informing and notifying visitors to the hospital facility about the FAP through conspicuous public displays (or other measures reasonably calculated to attract visitors’ attention) ► Informing and notifying residents of the community about the FAP in a manner reasonably calculated to reach those members of the community most likely to require financial assistance Implementing Section 501(r): best practices andPage 26 pitfalls on the road to compliance

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Emergency medical care policy► General rule: each hospital facility must also establish a written emergency medical care policy that requires the hospital facility to provide, without discrimination, care for emergency medical conditions to all individuals whether or not they are eligible for financial assistance.► A hospital facility will comply with this requirement if the policy requires it to provide the care for emergency medical conditions that it is required to provide under EMTALA (Emergency Medical Treatment and Labor Act). Implementing Section 501(r): best practices andPage 27 pitfalls on the road to compliance

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Emergency medical care policy (cont.)► Emergency medical care policy must: ► Prohibit the hospital facility from engaging in actions that discourage individuals from seeking emergency medical care ► For example: ► By demanding that emergency room (ER) patients pay before receiving treatment for emergency medical conditions ► By permitting debt collection activities: ► In the ER ► Elsewhere in the hospital facility, where such activities could interfere with the provision of non-discriminatory emergency medical care Implementing Section 501(r): best practices andPage 28 pitfalls on the road to compliance

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Establishing policies► A hospital has established an FAP, an emergency medical care policy, and a billing and collections policy for a hospital facility only if: ► An authorized body of the hospital has adopted the policy for the hospital facility ► The hospital facility has implemented the policy Implementing Section 501(r): best practices andPage 29 pitfalls on the road to compliance

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Sec. 501(r)(5) — limitation on charges► A hospital facility must limit the amounts charged for the care it provides to any individual eligible for assistance under its FAP: ► In the case of emergency or other medically necessary care: ► To not more than the AGB for individuals who have insurance covering such care ► In the case of all other medical care: ► To less than the gross charges for such care ► Note: “Gross charges” not defined Implementing Section 501(r): best practices andPage 30 pitfalls on the road to compliance

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Sec. 501(r)(5) — limitation on charges (cont.)► AGB ► Applies only to emergency or other medically necessary care to FAP-eligible individuals► To determine AGB, a hospital facility must adopt and continue to use either: ► The look-back method ► The prospective Medicare method Implementing Section 501(r): best practices andPage 31 pitfalls on the road to compliance

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Sec. 501(r)(5) — limitation on charges (cont.)► The look-back method ► Multiply hospital facility’s gross charges for the provided care by one or more percentages of gross charges (AGB percentages) ► AGB percentages ► Numerator: the sum of all claims for emergency and other medically necessary care paid by the hospital facility during the prior 12-month period ► Claims paid by Medicare fee-for-service and amounts paid by beneficiaries as co-insurance or deductibles ► Or claims paid by Medicare fee-for-service and all private health insurers and amounts paid by beneficiaries as co-payments, co- insurance or deductibles ► Denominator: the sum of the gross charges for those claims Implementing Section 501(r): best practices andPage 32 pitfalls on the road to compliance

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Sec. 501(r)(5) — limitation on charges (cont.)► Under the look-back method, the AGB percentage may be one of the following: ► One average percentage of gross charges for all emergency and other medically necessary care provided by the hospital facility ► Multiple AGB percentages: ► For separate categories of care (such as inpatient and outpatient care or care provided by different departments) ► For separate items or services► Start date for using look-back method AGB percentages ► Must begin using AGB percentages by the 45th day after the end of the 12-month period used to calculate the AGB percentage(s) Implementing Section 501(r): best practices andPage 33 pitfalls on the road to compliance

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Sec. 501(r)(5) — limitation on charges (cont.)► Prospective Medicare method ► Use the billing and coding process that would be used if the FAP-eligible individual were a Medicare fee-for-service beneficiary ► Set AGB equal to the sum of expected payments from: ► Medicare ► Medicare beneficiary Implementing Section 501(r): best practices andPage 34 pitfalls on the road to compliance

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Sec. 501(r)(5) — limitation on charges (cont.)► Gross charges ► Must charge an FAP-eligible individual less than the gross charges for any medical care provided to that individual ► A billing statement may state the gross charges as a starting point for allowances, discounts and deductions Implementing Section 501(r): best practices andPage 35 pitfalls on the road to compliance

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Sec. 501(r)(5) — limitation on charges (cont.)► Safe harbor for charges more than AGB ► Even if a hospital facility charges more than AGB, it will meet the Sec. 501(r)(5) limitations if: ► FAP-eligible individual has not submitted a completed FAP application at the time of the charge ► Hospital facility makes reasonable efforts to determine if the individual is FAP-eligible during the required time periods Implementing Section 501(r): best practices andPage 36 pitfalls on the road to compliance

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Sec. 501(r)(6) — billing and collection► A hospital facility may not engage in ECAs against an individual before the hospital facility has made “reasonable efforts to determine whether the individual is FAP-eligible.”► ECAs against an individual include: ► ECAs against any other individual who is responsible for the individual’s hospital bills ► Any ECAs taken by: ► Any purchaser of the individual’s debt ► Any debt collection agency to which the hospital facility has referred the debt Implementing Section 501(r): best practices andPage 37 pitfalls on the road to compliance

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Sec. 501(r)(6) — billing and collection (cont.)► ECAs are: ► Actions taken by a hospital facility against an individual related to obtaining payment of a bill for care covered under its FAP: ► Requiring a legal or judicial process ► Involving selling an individual’s debt ► Reporting adverse information about the individual to consumer credit reporting agencies or credit bureaus Implementing Section 501(r): best practices andPage 38 pitfalls on the road to compliance

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Sec. 501(r)(6) — billing and collection (cont.)► Examples of actions requiring a legal or judicial process: ► Placing a lien on an individual’s property ► Foreclosing on an individual’s real property ► Attaching or seizing an individual’s bank account or other personal property ► Commencing a civil action against an individual ► Causing an individual’s arrest ► Causing an individual to be subject to a writ of body attachment ► Garnishing an individual’s wages Implementing Section 501(r): best practices andPage 39 pitfalls on the road to compliance

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Sec. 501(r)(6) — billing and collection (cont.)► “Reasonable efforts to determine whether an individual is FAP-eligible”: ► The hospital facility notifies the individual about the FAP during the notification period ► For an individual who submits an incomplete FAP application during the application period, there are certain required actions ► For an individual who submits a complete FAP application during the application period, there are certain required actions. Implementing Section 501(r): best practices andPage 40 pitfalls on the road to compliance

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Sec. 501(r)(6) — billing and collection (cont.)► Notification ► A hospital facility notifies an individual about its FAP when it: ► Distributes a plain-language summary of the FAP and offers the individual an FAP application form before discharge from the hospital facility ► Includes a plain-language summary of the FAP with at least three billing statements and with all other written communication regarding the bill given to the individual during the notification period Implementing Section 501(r): best practices andPage 41 pitfalls on the road to compliance

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Sec. 501(r)(6) — billing and collection (cont.) ► Informs the individual about the FAP in all oral communication regarding the amount due for care occurring during the notification period ► Gives the individual at least one written notice that: ► Informs the individual about the ECAs that may be taken if the individual does not submit an FAP application or pay the amount due by a specified deadline (not before the end of the notification period) ► Is given to the individual at least 30 days before the specified deadline Implementing Section 501(r): best practices andPage 42 pitfalls on the road to compliance

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Sec. 501(r)(6) — billing and collection (cont.)► Notification occurs: ► If a complete or incomplete FAP application is submitted and the hospital facility has met the requirements for addressing a complete or an incomplete FAP ► If no FAP application is submitted and the hospital facility has met the notification requirements► Notification period ► As to any care the hospital facility provides: ► Begins on the first date care is provided ► Ends on the 120th day after the hospital facility gives the individual the first billing statement for the care Implementing Section 501(r): best practices andPage 43 pitfalls on the road to compliance

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Sec. 501(r)(6) — billing and collection (cont.)► FAP application situations: ► No application submitted ► Incomplete application submitted ► Completed by completion deadline ► Not completed by completion deadline ► Complete application submitted Implementing Section 501(r): best practices andPage 44 pitfalls on the road to compliance

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Sec. 501(r)(6) — billing and collection (cont.)► Completion deadline is no earlier than the later of: ► 30 days after the hospital facility gives the individual the written notice ► The last day of the application period► Application period ► As to any care the hospital facility provides: ► Begins on the first date care is provided ► Ends on the 240th day after the hospital facility gives the individual the first billing statement for the care Implementing Section 501(r): best practices andPage 45 pitfalls on the road to compliance

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Sec. 501(r)(6) — billing and collection (cont.)► No FAP application submitted ► If an individual does not submit an FAP application during the notification period (or by the deadline specified in the written notice) and the facility has properly notified the individual: ► The facility will have made “reasonable efforts to determine whether the individual is FAP-eligible.” ► The facility may engage in ECAs against the individual. Implementing Section 501(r): best practices andPage 46 pitfalls on the road to compliance

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Sec. 501(r)(6) — billing and collection (cont.)► Incomplete FAP application submitted ► If an incomplete application is submitted during the application period, “reasonable efforts to determine whether the individual is FAP-eligible” will have been made if the hospital facility: ► Suspends any ECAs against the individual ► Gives the individual written notice describing the additional information and/or documentation required to complete the FAP application, including a plain-language summary of the FAP ► Gives the individual a written notice that: ► Describes the ECAs that may be taken if the FAP application remains incomplete by the specified completion deadline ► Is given to the individual at least 30 days before the completion deadline Implementing Section 501(r): best practices andPage 47 pitfalls on the road to compliance

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Sec. 501(r)(6) — billing and collection (cont.)► If FAP is completed by the completion deadline: ► FAP will be considered completed and timely submitted ► Hospital facility will have made “reasonable efforts to determine whether the individual is FAP-eligible” if it meets the requirements for complete FAP applications Implementing Section 501(r): best practices andPage 48 pitfalls on the road to compliance

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Sec. 501(r)(6) — billing and collection (cont.)► If FAP is not completed by the completion deadline and hospital facility has met the requirements for an incomplete FAP application: ► Hospital facility will have made “reasonable efforts to determine whether the individual is FAP-eligible” if it meets the requirements for complete FAP applications Implementing Section 501(r): best practices andPage 49 pitfalls on the road to compliance

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Sec. 501(r)(6) — billing and collection (cont.)► Complete FAP application ► If a complete FAP application is submitted during the application period: ► Hospital facility will have made “reasonable efforts to determine whether the individual is FAP-eligible” if it: ► Suspends any ECAs ► Determines (and documents) whether the individual is FAP-eligible ► Notifies the individual in writing of the eligibility determination, the assistance available, if any, and the basis for this determination Implementing Section 501(r): best practices andPage 50 pitfalls on the road to compliance

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Sec. 501(r)(6) — billing and collection (cont.)► If the individual is determined to be FAP-eligible, the hospital facility: ► Gives the individual a billing statement showing the amount owed, explanation of how it was determined and explanation of the AGB ► Refunds any payments made in excess of amount owed as an FAP-eligible individual ► Takes reasonable measures to reverse any ECAs taken to collect the debt Implementing Section 501(r): best practices andPage 51 pitfalls on the road to compliance

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Sec. 501(r)(6) — billing and collection (cont.)► Special rules: ► Anti-abuse rule for complete FAP applications ► Presumptive eligibility permitted ► Suspending ECAs during a pending FAP application ► Waiver not included in reasonable efforts ► Agreements with debt collectors ► Placement of notices and communications Implementing Section 501(r): best practices andPage 52 pitfalls on the road to compliance

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Sec. 501(r)(6) — billing and collection (cont.)► Anti-abuse rule for complete FAP applications ► A hospital facility will not have made “reasonable efforts to determine whether an individual is FAP-eligible” if its determination that the individual is not FAP-eligible is based on information: ► That the facility has reason to believe is unreliable or incorrect ► Obtained from an individual under duress or through coercive practices Implementing Section 501(r): best practices andPage 53 pitfalls on the road to compliance

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Sec. 501(r)(6) — billing and collection (cont.)► Presumptive eligibility permitted ► A hospital facility will have made “reasonable efforts to determine whether an individual is FAP-eligible” if: ► It determines that the individual is eligible for the most generous assistance (including free care) available under the FAP based on: ► Information other than that provided by the individual in a complete FAP application ► The determination that the hospital facility meets the requirements for actions involving a complete FAP application Implementing Section 501(r): best practices andPage 54 pitfalls on the road to compliance

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Sec. 501(r)(6) — billing and collection (cont.)► Suspending ECAs during a pending FAP Application ► If a complete or incomplete application is submitted during the application period, the hospital facility will have made “reasonable efforts to determine whether the individual is FAP- eligible” if, after receiving the application, it: ► Does not initiate or pursue any ECAs until either: ► The hospital facility has met the requirements for actions involving a complete application ► The application is incomplete and the completion deadline has passed without completion of the FAP application Implementing Section 501(r): best practices andPage 55 pitfalls on the road to compliance

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Sec. 501(r)(6) — billing and collection (cont.)► Waiver is not included in reasonable efforts ► Obtaining a signed waiver that an individual does not wish to apply for FAP assistance or receive FAP application information will not meet the requirement to make “reasonable efforts to determine whether the individual is FAP-eligible” before engaging in ECAs. Implementing Section 501(r): best practices andPage 56 pitfalls on the road to compliance

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Sec. 501(r)(6) — billing and collection (cont.)► Agreements with debt collectors ► If a hospital facility refers or sells a debt to a debt collector during the application period, it will have made “reasonable efforts to determine whether the individual is FAP-eligible” if it obtains (and enforces) a legally binding written agreement that the debt collector: ► As to debts referred during the notification period, will not engage in ECAs until the hospital facility has documented that it has met the reasonable efforts requirements ► As to an application submitted during the application period, the third party will suspend any ECAs Implementing Section 501(r): best practices andPage 57 pitfalls on the road to compliance

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Sec. 501(r)(6) — billing and collection (cont.) ► As to an application submitted during the application period and the hospital facility having determined the individual is FAP-eligible, the debt collector will: ► Adhere to procedures specified in the agreement that ensure the individual will not pay any more than required as an FAP-eligible individual ► Take all reasonable measures to reverse any ECAs already taken ► If the debt collector refers or sells these debts to another party during the application period, it will obtain a written agreement from the other party that includes all these requirements. Implementing Section 501(r): best practices andPage 58 pitfalls on the road to compliance

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Sec. 501(r)(6) — billing and collection (cont.)► Placement of notices and communications ► A hospital facility may print any required written notice or communication (including a plain-language summary of the FAP) on a billing statement or along with other descriptive or explanatory matter if the required information is conspicuously placed and large enough to be clearly readable. Implementing Section 501(r): best practices andPage 59 pitfalls on the road to compliance

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Questions Implementing Section 501(r): best practices andPage 60 pitfalls on the road to compliance