Form 990 (2015): Tax-Year-Specific Checklist for Exempt Organizations
Year and Form Context
Form 990 (2015) requires organizations exempt under sections 501(c), 527, or 4947(a)(1) with gross receipts of at least $200,000 or total assets of at least $500,000 to report complete mission, governance, and financial detail. For 2015, the Affordable Care Act community health needs assessment requirements apply to hospital facilities, and the form includes Schedule O as mandatory for all filers. No stimulus reconciliation, TCJA provisions, or ARPA adjustments apply to this year.
Year-Specific Applicability to Form 990 (2015)
Hospitals operating under section 501(c)(3) must meet section 501(r) requirements and file Form 990, Schedule H to report community benefit activities and financial assistance policies. Organizations with controlled entities under section 512(b)(13) must file Form 990 (not Form 990-EZ) if any transfer of funds occurred between the controlling and controlled organization during the tax year. Unrelated business taxable income of $1,000 or more requires completion of Form 990-T and reporting on Form 990, Part V.
Ten-Step Checklist for Form 990 (2015)
Step 1: Determine Filing Requirement and Correct Form
Verify gross receipts are $200,000 or more, or total assets are $500,000 or more, at year-end 2015. If gross receipts are normally $50,000 or less, you may file Form 990-N (e-Postcard) instead; if between $50,000 and $200,000 in receipts and under $500,000 in assets, file Form 990-EZ (if eligible); otherwise, complete full Form 990. Organizations with $25,000 or more in gross receipts (if a section 527 political organization), or controlling organizations with controlled entities, must file Form 990 regardless of size thresholds.
Step 2: Gather and Verify Accounting Period Documentation
Confirm whether the organization uses a calendar year (January 1–December 31) or fiscal year ending on any date, as there is no restriction against December as a fiscal year-end date. Identify the exact beginning and ending dates of the 2015 tax year, as required for Item A in the Form 990 heading. If the accounting period changed during 2015, prepare a “Change of Accounting Period” notation and consider whether Form 1128 must be filed.
Step 3: Collect Financial Records and Prepare Balance Sheet Information
Gather bank statements, investment statements, accounts receivable aging, loan documents, and depreciation schedules. Complete Part X (Balance Sheet) with beginning and end-of-year totals for cash, receivables, land/buildings/equipment, investments, and other assets and liabilities. Ensure Part X, line 10 (land, buildings, equipment) is reconciled with depreciation records if completing Schedule D, Part VI.
Step 4: Compile Revenue and Functional Expense Detail
Prepare Part VIII (Statement of Revenue) with contributions, grants, program service revenue, investment income, and other revenue by type and source. Categorize all expenses in Part IX by function: grants, benefits, salaries, occupancy, travel, and other, segregating program services from management and general and fundraising expenses. Ensure that the total revenue reported in Part VIII line 12 and the total expenses reported in Part IX line 25 match the corresponding summary lines 12 and 18 in Part I.
Step 5: List Officers, Directors, Trustees, Key Employees, and Highest Compensated Persons
Complete Part VII, Section A with the name, title, and compensation for all current officers, directors, and trustees regardless of compensation amount; all current key employees with reportable compensation over $150,000; and the five highest compensated employees with reportable compensation of at least $100,000 from the organization and related organizations. Include former officers, directors, trustees, or key employees who received more than $100,000 from the organization and any related organization.
Step 6: Answer Governance Questions in Part VI
Disclose in Part VI the number of voting members of the governing body (line 1a) and the number who are independent (line 1b). Answer all questions regarding family relationships among board members, delegation of management duties, written conflict-of-interest policy, whistleblower policy, document retention policy, and compensation review processes using comparability data and independent review. Provide narrative explanations in Schedule O for Part VI, lines 11b and 19.
Step 7: Complete Part IV (Checklist of Required Schedules)
Answer all yes/no questions in Part IV to determine which additional schedules must be completed. For example, answer “yes” to line 15 if more than $5,000 in grants to foreign organizations (triggering Schedule F), line 17 if more than $15,000 in professional fundraising expenses (triggering Schedule G), or line 20a if the organization operates hospital facilities (triggering Schedule H). Mark all “yes” responses to ensure the corresponding schedules are prepared and attached.
Step 8: Prepare Supplemental Information in Schedule O
Complete Schedule O (mandatory for all Form 990 filers) with all required narrative explanations for Part VI, lines 11b and 19 relating to governance and compliance. Describe all program services reported in Part III that have expenses of more than the organization’s total, or describe any program services not fully detailed elsewhere on the form. If the organization answered “yes” to any question in Part V (tax compliance), provide detailed explanations in Schedule O if required by the specific question.
Step 9: Complete All Required and Conditional Schedules and Attachments
Prepare Schedule A (Public Charity Status and Public Support) if the organization is described in section 501(c)(3) or is a 4947(a)(1) trust. Prepare Schedule D (Supplemental Financial Statements) if responding “yes” to any Part IV question triggering Schedules D, Parts I–XII. Prepare Schedule R (Related Organizations) to list all related organizations (subsidiaries, joint ventures, parent organizations). Prepare Schedule L (Transactions with Interested Persons) if reportable transactions with officers, directors, trustees, key employees, or their family members occurred. Prepare Form 990-T (Unrelated Business Taxable Income Return) if unrelated business gross income exceeded $1,000 and attach it to Form 990.
Step 10: Sign, Date, and Verify Completeness Before Submission
Ensure the officer whose name appears in Item F (principal officer) signs Part II (Signature Block) under penalties of perjury, with the date and title; include preparer information if a paid preparer completed the return. Verify that Schedule O is attached; that all schedules indicated by “yes” responses in Part IV are included; that Part I summary (lines 8–22) reconciles to underlying parts (VIII, IX, X, XI); and that total assets (Part X, line 16) equals total liabilities (line 26) plus net assets (line 22). Do not include social security numbers on the return, as it will be publicly available.
Line Changes and Schedule Updates in 2015 Form 990
Schedule A (Public Charity Status): Parts IV and V Added
Prior instruction focused on basic public charity determination and the 33⅓ percent support test. The 2015 instruction expanded Schedule A to include Part IV for Supporting Organization Compliance and Part V for Type III Non-Functionally Integrated Requirements, in line with the final regulations under section 509(a)(3).
Schedule H (Hospital Requirements): Part V Enhanced
Prior instructions requested hospital identity information. The 2015 instruction added Section A (names and EINs of subordinate hospitals for group returns). It expanded Section B with additional compliance questions and checkboxes, reflecting the final Section 501(r) regulations released on December 29, 2014, regarding community health needs assessments, financial assistance policies, and billing practices.
Schedule L (Transactions with Interested Persons): Harmonized Definitions
Prior instructions defined “interested person” separately for each part. The 2015 instruction harmonized the definition of “interested person” across Parts II–IV. It centralized the definition of “reasonable efforts” in the introduction, thereby reducing confusion, minimizing the reporting burden, and increasing consistency.
Form-Specific Limitations Applicable to Form 990 (2015)
Organizations filing Form 990 must complete all Parts I through XII; Form 990-EZ filers are exempt from certain parts but cannot itemize details on schedules. Section 4947(a)(1) nonexempt charitable trusts must complete all sections and schedules required for section 501(c)(3) organizations, including Schedule A. Private foundations must file Form 990-PF (not Form 990), as must organizations treated as private foundations under section 509(a).
Key Thresholds Specified in 2015 Instructions
The gross receipts threshold for the Form 990 requirement is $200,000 or more. Total assets threshold: $500,000 or more at year-end. Gross receipts threshold for Form 990-N (e-Postcard) eligibility: normally $50,000 or less. Schedule D trigger for grants: more than $5,000 to foreign organizations (line 15) or domestic organizations (line 21). Schedule G trigger for fundraising: more than $15,000 in professional fundraising expenses (line 17). Schedule M trigger for non-cash contributions: more than $25,000 received during the year (line 29).
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This checklist is for educational purposes only and does not constitute tax or legal advice. Always review official IRS instructions and consult a qualified professional for guidance.
