Denial of Property Tax Exemption for Illinois Hospital Affirmed by Illinois Supreme Court

On March 18, 2010, the Illinois Supreme Court (Court), in the case of Provena Covenant Medical Center v. Department of Revenue, ruled that Provena Covenant Medical Center (PCMC) did not provide enough free care to qualify for a charitable property tax exemption. Additionally, the Court found that there was insufficient information regarding Provena Hospitals (Provena) in the administrative record, which contributed in part to a finding that Provena was not a “charitable institution.” Notably, the decision issued by the Court was a plurality decision, and thus, because there was not a majority, the opinion is not directly binding on other institutions or organizations. Nevertheless, the criteria relied upon by the Court will likely make it more difficult for private, not-for-profit hospitals in Illinois to obtain and maintain property tax exemption.

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