DHLF Lobbying Dues Disclosure for Cost Reports

October 8, 2018

TO:  Members, District Hospital Leadership Forum

FROM:  Sherreta Lane, DHLF Senior Vice President, Finance Policy

SUBJECT:  Medicare Cost Reports and DHLF Dues

Under the Medicare Provider Reimbursement Manual, Part 1, Section 2139, hospitals are required to make adjustments in their Medicare cost reports to eliminate the portion of association membership dues that is related to certain unallowable lobbying expenses as defined by Medicare.

As allowed by Medicare provisions, the District Hospital Leadership Forum (DHLF) uses the IRS definitions in calculating unallowable lobbying expenses. In general, these are defined as direct communications with certain members of state or federal government to influence state or federal legislation.

The following information is for the calendar year 2018. The portion of your total hospital association dues that are unallowable expenses for Medicare is 20.3 percent.  This percentage also applies for 990 reporting, if applicable.

In addition to the Medicare definition of lobbying, your dues support advocacy and representation of district/municipal hospitals by the DHLF in the broadest sense. Your dues invoice will reflect the estimated percentage for 2019.

Please share this information with the individual on staff responsible for completing the Medicare and Medi-Cal cost reports. Questions on the calculation of the lobbying portion of dues or other associated issues may be directed to me at or 916-673-2020. A copy of this information has been provided to the Medicare Administrative Contractor and the Department of Health Care Services.