The American Hospital Association's September 2025 community benefit report, the source of the often-cited "$100 billion" figure, is based on IRS Form 990 Schedule H data submitted by 340B hospitals themselves.
Hospitals report the data. The AHA collects it. The AHA, which represents and advocates for hospitals, then publishes a report highlighting the community benefits those hospitals say they provide.
What is often overlooked is that the underlying numbers are not independently verified. There is no federal auditor reviewing how each hospital categorized its spending, and there is no consistent enforcement mechanism to ensure expenses are classified the same way from one hospital to the next. Hospitals report the information, and the AHA reports what hospitals reported.
There is also no single federal definition of "community benefit" that requires uniform reporting. Two hospitals serving similar patients can, and often do, categorize similar expenses differently. The IRS provides guidance on what hospitals may report, but it does not require every hospital to classify expenses the same way.
As a result, the AHA's $100 billion figure is an aggregate of self-reported data that may be categorized differently from hospital to hospital. The number reflects what hospitals reported, not a standardized accounting of community benefit spending.