Form 990 (2010) Tax-Year-Specific Checklist
Year Uniqueness (2010)
The 2010 Form 990 reflects the mature, redesigned form (effective 2008+) with tightened filing thresholds: gross receipts for 990-EZ filing are lowered to $200,000 (from $500,000), and total assets are reduced to $500,000 (from $1.25 million); the Form 990-N threshold is raised to $50,000 (from $25,000). Hospital organizations must complete the entire Schedule H, not just Part V. Part XI (Reconciliation of Net Assets) has expanded to require detailed net asset reconciliation. Schedule O (Supplemental Information) is now mandatory for all filers.
Year-Specific Programs Applying to 2010 Form 990
No EIP, ACA, TCJA, or ARPA provisions apply to the 2010 Form 990. The form itself contains no requirements for stimulus reconciliation or energy credits. Filing thresholds and hospital reporting requirements are the material 2010 updates.
Ten-Step 2010 Form 990 Filing Checklist
Step 1: Determine Filing Requirement
Verify gross receipts and total assets at year-end. If gross receipts ≥$200,000 OR total assets ≥$500,000, file Form 990 (not 990-EZ). If $50,000 ≤ gross receipts < $200,000 AND total assets < $500,000, may file 990-EZ. If gross receipts < $50,000, file Form 990-N e-postcard.
Step 2: Gather Revenue and Expense Documentation
Collect: (a) all Form 1098-T, 1098-C, W-2G, and charitable contribution substantiation; (b) program service revenue documentation by activity code; (c) investment income statements; (d) unrelated business income records; (e) grant and assistance ledgers; (f) functional expense allocations by program/management/fundraising.
Step 3: Compile Compensation Records
Identify all current officers, directors, and trustees (regardless of compensation); up to 20 key employees with reportable compensation >$150,000; and the five highest-compensated employees with reportable compensation >$100,000. List all former officers, directors, trustees, key employees, and top-5 compensated individuals who received more than $100,000 (or more than $10,000 for former directors/trustees) in the year. Gather Form W-2, Box 5, and Form 1099-MISC, Box 7, for each person.
Step 4: Compile Part X Balance Sheet Data
Prepare beginning-of-year and end-of-year asset and liability schedules, including cash, pledges/grants receivable, inventory, investments, land/buildings/equipment, other assets, accounts payable, grants payable, deferred revenue, and other liabilities. Reconcile the ending balances with the opening balances from the prior year's return.
Step 5: Complete Schedule Determination (Part IV)
Answer all 38 checklist questions to trigger which of 16 schedules must be completed: Schedule A (501(c)(3) public charity status), Schedule B (contributors ≥$5,000), Schedule C (lobbying), Schedule D (supplemental financial statements), Schedule E (schools), Schedule F (foreign activities ≥$10,000), Schedule G (fundraising ≥$15,000), Schedule H (hospital operators), Schedule I (grants to U.S. entities ≥$5,000), Schedule J (compensation policies), Schedule K (tax-exempt bonds), Schedule L (interested-person transactions), Schedule M (noncash gifts), Schedule N (asset liquidations), Schedule O (mandatory supplementary), and Schedule R (related organizations).
Step 6: Complete Hospital Schedule H if Applicable
If the organization operated ≥1 hospital facility (licensed/registered as a hospital under state law), complete and attach the full Schedule H, including Part V (Facility Information), not just portions. Attach the most recent audited financial statements to Schedule H if the organization’s tax year commenced after March 23, 2010.
Step 7: Reconcile Revenue and Expenses (Parts VIII–IX)
Part VIII reports total revenue (lines 8–12); Part IX allocates by function (columns A–D for program service, management, fundraising, and other). Line 12 must reconcile to Part I, line 8. Compensation on Part IX, line 5, must include all salary, benefits, pension contributions, and insurance, not wages only.
Step 8: Complete Governance Section (Part VI)
Answer all governance questions: composition of governing body, member/chapter status, conflicts of interest policy (line 12a), whistleblower policy (line 13), document retention policy (line 14), process for setting compensation (line 15). Answer “Yes” or “No”; explain all “Yes” responses and all “No” responses to lines 8a, 8b, or 10b in Schedule O.
Step 9: Prepare Schedule O and Explanations
Schedule O is mandatory for all filers. Include explanations for any Part VI “Yes” responses, all governance/policy “No” answers, and any complex transactions (e.g., unrelated business, related-party dealings, significant program changes). Ensure that Schedule O cross-references responses to Part IV, Part V, and Part VI.
Step 10: Sign, Assemble, and File as Paper Return
Obtain signatures of the authorized officer and paid preparer (if applicable) on Part II (Page 1). Certify under penalty of perjury. Assemble in sequence: Form 990 core (11 pages), Schedule O (mandatory), all other required schedules, and audited financial statements (for hospitals with a tax year beginning after March 23, 2010). File with IRS using 2010 Form 990 instructions; do not e-file. See the IRS Where to File page for the 2010 Form 990 mailing address for your entity type and location.
Line-Change Analysis for 2010 Form 990
Part VII (Compensation)
Prior Year (2007 & earlier): Officers and highest-compensated employees listed separately; key employees not distinctly segregated.
2010 Redesign: Part VII now requires mutually exclusive categories—officers, directors, trustees (all, regardless of compensation), key employees (up to 20, defined as persons with specific authority and reportable compensation >$150,000 from organization and related), and five highest-compensated employees (>$100,000, not also officers/directors/trustees/key employees). Additions: Section B now requires the listing of up to five highest-compensated independent contractors paid more than $100,000. Form 990 instructions now clarify columns for reportable compensation (W-2 Box 5, 1099-MISC Box 7) and other compensation estimates.
Part XI (Reconciliation of Net Assets)
Prior Year: No standalone reconciliation section.
2010 Addition: New Part XI requires reconciliation of beginning and ending net assets or fund balances, incorporating total revenue (from Part I, line 8), total expenses (from Part I, line 18), other changes in net assets (lines 5–9), and resulting end-of-year net assets (line 10), which must match Part X, line 22 (total net assets).
Schedule H (Hospitals)
Prior Year (2008-2009): Hospital organizations could complete Part V of Schedule H only; the full schedule was phased in over time.
2010 Requirement: If the organization checks “Yes” to Form 990, Part IV, line 20a (operates ≥1 hospital facility), it must complete the entire Schedule H (all parts), including charity care, community benefit, billing practices, and facility information. Audit requirements have also been added: hospital organizations with a tax year beginning after March 23, 2010, must attach audited financial statements.
Form 990 Limitations Specific to 2010
Organizations with one or more hospitals must complete Schedule H in full; organizations without hospital facilities are prohibited from filing it. Part VII of the compensation table applies only to 501(c) organizations, as defined in IRC §501; nonexempt entities and foreign organizations are not in scope. Form 990-N is not available to organizations with annual gross receipts of $50,000 or more; they must file Form 990-EZ or Form 990 based on the asset threshold. Schedule O is mandatory and cannot be omitted, regardless of whether the organization has responses to Part IV, V, or VI questions that require explanation.
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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.
