Untitled Texas Attorney General Opinion

Hon. Stewart W. Hellman Opinion No. V-925 CH.mlnal District Attorney SW The effect upon the tax exempt Terrent County status OS e charitable hospital Fort Worth, Texas of compensatingthe doctor in charge of enestheologg,path- ology or radiology on e See or profit-sharingbasis. Deer Mr. Hellman Your letter requesting our 0pFnLon reletlve to the cap- tioned matter reads as follows: "Request Is made for en opinion from your De- partment es to whether the compensationon a See basis or e profit-sharingbasis of doctors in specializedfields of hospital service when paid by charitable hospitals woulU forfeit the ad velor- em tax exemption for such institution. "By we of back grounU we refer to'section 2 of Article 8 of the Constltutlonof Texas author- " izlng the Legislatureby general law to exempt Srom taxation all buildings used exclusivelyand owned by institutionsof purely plbltc ch&rity; Article 7150(7), R.C.S., wherein the Legislature has exer- cised such authority; and the cases cited in your Opinion No. V-374 to the effect that in order to qualify Sor such tax exemptlon,theproperty must be owned by the organizationclaiming the exemp- tion end must be used exclusivelyby such organi- zation. "Larger hospitals have divlsl6ns of hospital service',usually composed of a Department OS Anesthe- ology, a Department of Pathology, end sometimes 8 Department OS Radiology. These hospital services are Surnlshed by the hospital under the direction of the doctor Fn charge of the respective department at the request of or on order of the attending physician. The hospitals make the charge for the anesthesia,the pathology end/or the radiology end the net proceeds therefrom go to the Surtherance of the charlteblework of the hospltel, the doctors In . - Hon. Stewart W. Hellmsn, page 2 v-925 charge of such departmentsbeing on salaries paid bg,the hospitals In most cases. "However,these three fields of hospltel ser- vice are specializedfields, and to obtain the finest doctors for this purpose and Improve the hospital service, It is usually necessary to employ doctors who have certatn hdgh standings in certain medical societies In their field. These societies for the Improvement of servfce and the maintenance of high ethics sometimes require, end always prefer, that its doctor members not serve on salaries but be compensatedby Sees. "Attorne General's Opinion No. O-3572, approved August 18, 1911, would cover the point that thi,em- ploym$nt of such doctors, either on a See or salary basis, would nbt violate the Medical Practice Act. Attorney General's Opinion No. V-374; det6d Septem- ber 12, 1947, covers the point that such a physician may use his own equipment and leave it in unused space in the hospital; without forfeiting the ad velorem tax exemption. But neither of the Opinions referred to covers the point as to whether the em- ployment of such doct0r on a See or profit-sharing basis vould forfeit the ad velorem tax exemption otherwiseenjoyed by charitable hospitals. "Therefore,the question on vhtch we would like to have your opinion fs whether charitable hospitals,otherwise entitled to ad velorenitax exem@lon under the Constitutionand Laws of Texas, would SorSelt such ad valorem tax exemptionby re- mneratlng the doctor heads of their departments of hospital service on (1) a See baais, or (2) a net profit-sharingbasis r- instead of on e-salary basis. The See basis mentioned would mean that the hospitalwould agree with the pathologistthat Insteadof his receiving .ssalary* he would receive a See of a certain amou,ntof money for each case ha&led, or each service rendered, whether or not the hoapltalwas successf'ul in collecting such See Srcm its patient. The profit-sharingbasis vould mean thet from the gross Sees collected by the hos- pital Srom work performed by the particular de- partmclot,the hospital would peg the expenses attribatebleto such department,end the net pro- ceeds or balance, vould be divided.on e percent- age basis with the Uoctor head of such department. . . Hon. Stewart W. Hellman, page 3 v-925 "In view of the fact that a specific portion of the hospital is customarilyassigned for the work of theqe hospital service departments,end in view of the fact that the doctor heeds of such de- partments usually have personal demand end dlrec- tlon over such departments,the local hospitals are hesitant to accede to the wishes of the doctors in changing their remunerationfrom that of e salaried employee, lest in doing so the hospital subject Itself to ad velorem taxes, whlchti turn would cause a substantialcurtailment in charity services provided." Section 2 of Article VIII of the Texas Constitutionau- thorizes the Legislature to exempt from taxation Institutionsof purely public charity. In pursuance to such authority the Legis- lature exempted the real,propertyof Institutionsof purely pub- lic charity. This 1egIslatlon'hesbeen codified as Section 7, Article 7150, V.C.S., end reeds ea follows: "All buildings belonging to institutionsof purely public charity, together with the lands be- longing to end occUpled by such Institutionsnot leased or otherwise used with e view to profit, un- less such rents and profits end all moneys end credits are appropriatedby tiuchInstitutions solely to sustain such institutionsend for the benefit of the sick and disabled members end their Semllles end the burial of the same, or for the maintenance of persons when unable to provide for themselves,whether such persons ere members of such instltiitlonsor not. An institution of purely plb- llc charity under this article Is one which dls- penses its aid to Its members end others in slck- ness or distress, or et death, without regard to poverty or riches of the recipient, also when the funds, property and assets bf such institutions %re placed end bound by Its laws to relieve, aid end administer In any way to the relief of Its members when In want, sickness end distress, end provide homes for Its helpless end dependent mem- bers end to educate end maintain the orphans of its deceased members or other personsO" In Sante Rose InSlrmary v. Clts of San Antonio, 259 S.W. 926 (Tex.~Comm. 0 App. 2 "The constitutionalrequlrement'lstwofold; the property must be owned by the organizationclaiming the exemption; it llklst be exclusivelyused by the or- Hon. Stewart W. Hellman, page 4 v-925 genlzatlon, es distinguishedfrom a partial use by It, and a partial use by others, whether the others pay rent or not." Other cases applying this same rule are Cltr of Houston v. Scot- f$sh:;;; . 96 Asso;:;tlon a 696,111 5 S.W. Tex.519 19111887): 230 S W~* g78 !191 2 )' - As stated by the Court of Civil A peals In Harkham HosDltal v. Clts of Lonuvlew, 191 S.W. 26 %95 (Tex. s~pp. 945, error ref,): "It appears from the holding by 'theSupreme Courtin the City of Houston v. Scottish Rite Assn., supre, Red V. Johnson,,53 Tex. 284, 288, end Benev-~ oIent & Protective Order of Elks v.iCity of Houston, Tex. Clv:~App., 44 S.W. 26 488, that the relation-' ship of landlord and tenant or the paymbnt of rents, either or both are necessarilyrequisites to destroy the exemption granted a purely charitable lnstltu- tlon from taxes, . a . . The Baurt,in City of Corms Christ1 v. FredRoberts Wemorlal Hospital, 195 3.X. 2d 429 (Tex. Civ. App. 19%6 error ref. n.ti.e;),held that .ahospital vas not being opera&d or u&d exclusivelyfor public charity vhere the hospital entered Into a contract by the terms of which a man end his wife agreed t6 operate the hospital, taking such earnings of the hospital over and above $300 each month es a salary. The court based Its holding on the ground that the contract created the relationship of landlord efidtenant with ~theresult that the charitable cor- poration Itself was not actually operstlng the hospital. In Cltr of Lonuvlev'v.Markham-HcReeMetiorialHoirtittil, 137 Tex. 178 152 S.W. 26 1112 (1941) th S 11 I Saots’-vex-@ before the c&t. Two doctors paid tie h&pTte?$%O per month rent es part payment for office space. The doctors acted as house physiciansto tske care of emergency ca8ea and gave free treet- *@It to charity patlente. Despite the fact that the presence of a do&or at all times was necessary to the proper operation OS : the hoapltal,the court held that the renting of office spaoe vas a comme+cle&end prloate transactionwhich resulted In a losa oS the tax exenptlon. In prkham HosDltal v. City of Lonuvlew, supre, the caurt held t&at the hospital was~deprlvedof Its exemption irom taxationby reason of the fact that-the hos$ltal emplbyed a leb- oratory technicianwho performed laboratory teeta for patients. In the hospital es requested by the ph$slclens,but who also we8 pzE;e;zto carry on e private business using the hospital . . Hon. Stewart W. HeLlmen, page 5 v-925 We are assuming that the reel property Is owned by the charitable institution or lnstltutlonein questfon. In addition to being owned by the charitable lnstltutton,the ~propertymet be exclusivelyused by it. IS by compensating the doctors for their services by Sees or by,contractlngto pay them by a per- centage of the income creates a landlord and tenant~rel.atlon- ship or constitutes a renting or leasing of the premises, then the exemption would be lost. On the other hand, i$ the relatlon- ship of employer and employee still exists, then the use of the property by the doctors will constitute the use by the,lnstltu- tlon. It Is a rather common practice In these modern times to recompense employees by eLther a Sired salary, Sees, or on en ln- come-sharingbasis, or by two or all of said methods. It is therefore our opinion that the mere payment by e charitable hospital of a doctor in charge of anestheology;peth- ologg, or radiology by Sees.or on an Income-sherlngbeels, in- stead of e fixed salary, does not destroy the re&etlonshlp of employer end employee end the institutionwould not by reason thereof lose Its tax exempt character. A charitable hospital will not lose Its tsx exempt status by compensatingIts doctors in charge of anestheology,pathology, or radiology on a See or Income-sharingbasis instead of a fixed salary9 es the relationship of employer and employee will not th6reby be destroyed. Tex. Con&. Art. VIII, Sec. 2; Art. 7150, Sec. 7, V.C.S. Yours very truly, ATTORNEYGENERAL OF TEXAS By's/ W.V. Geppkt W.V. Geppert WVG/mwb/vc APPRovgD s/Joe R. Greenhill FIRST ASS@TANT ATTORNEy GENE&AL