3.3.9.3 Health Care

TYPES OF FACILITIES FINANCED – Facilities for private hospitals and other health care facilities may be financed with tax exempt qualified 501(c)(3) bonds if the borrower is an organization exempt from taxation under Section 501(c)(3) of the Internal Revenue Code of 1986, as amended (a “501(c)(3) organization”), and if the financed facilities are owned by the 501(c)(3) organization and used for its exempt purposes, not for an unrelated trade or business activity.

ISSUERS – Health care conduit financing issuers include charter cities, JPAs, and the California Health Facilities Financing Authority.

SPECIAL CONSIDERATIONS – Conduit financings for private health care facilities present issues distinct from those presented by debt issuances for health care facilities owned and operated by a governmental enterprise such as a hospital district (payable from operating or tax revenues) or health care facilities owned and operated by a general purpose government entity (like a county hospital payable out of the general revenues of the government entity).