Supporting Nonprofit Hospitals with
CHNA and Implementation of
Community Benefit
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Learning Objectives
Participants will have…
• Increased understanding of the IRS requirements and
recommendations for CHNAs
• Methods and guidance for assisting hospitals in defining
“community” for their CHNA and implementation plans
• New ideas and success stories for engaging public health
(including systemically) and other stakeholders with hospitals for
assessment and planning
• Capacity building activities and tools for moving hospitals from
Community Benefit activities to Effective Community Health
Interventions.
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Opportunities for Partnership
Local Health
Departments
(PHAB)
ACA = Affordable Care Act
Nonprofit
Hospitals
(ACA)
PHAB = Public Health Accreditation Board
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Affordable Care Act, Section 9007
Requirements for nonprofit hospitals:
 conduct a Community Health Needs Assessment (CHNA) at
least every 3 years;
 adopt implementation strategies to meet the community
health needs identified through the assessment;
 take into account input from persons who represent the
broad interests of the community served by the hospital
facility, including those with special knowledge of or
expertise in public health; and
 make the community health needs assessment and
implementation plan widely available to the public.
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IRS Guidance on Community Health Needs Assessment
• July 2011 - IRS Notice 2011-52
• April 2013 - Notice of Proposed Rule Making
(NPRM REG-106499-12) – Comments due July 5, 2013
Important clarifications/additions in new proposed rule:
• Hospital may define its community to include geographic areas
outside of those in which its patient populations reside.
• Hospitals may work collaboratively on CHNA
• A joint CHNA report may be issued if :
- Joint report adopted by each collaborating hospital.
- Collaborating hospitals define their community to be the same
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IRS Guidance on Community Health Needs Assessment
Important clarifications/additions in new proposed rule:
• Description of how hospital takes community input into account:
• Summarize input and how and over what time period such input
was provided.
• Provide names of organizations providing input and summarize
nature and extent of organization’s input.
• Describe the medically underserved, low-income, or minority
populations being represented by organizations or individuals
providing input.
• CHNA report must include description of the potential measures and
resources identified through the CHNA to address the significant health
needs.
• Implementation plan must include plan to evaluate impact
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IRS Guidance on Community Health Needs Assessment
Important clarifications/additions in new proposed rule:
• Implementation plan must include plan to evaluate impact
• Collaborating hospitals may adopt joint implementation strategy if:
• Clearly identifies the hospital facility’s particular role and
responsibilities in taking the actions described in the
implementation strategy and programs and resources the hospital
plans to commit
• Include a summary or other tool that helps the reader easily locate
those portions of the joint implementation strategy that relates to
the hospital facility.
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IRS Guidance on Community Health Needs Assessment
Important clarifications/additions in new proposed rule:
• Penalties:
• IRS can revoke the tax exemption of the hospital organization
depending on “relevant facts and circumstance” including
organization’s history of compliance, scope of the failure to comply,
and whether policies and safeguards were in place.
• Minor and inadvertent omissions and errors will not be considered
failure to meet requirements if the hospital facility corrects after
discovery.
• $50,000 excise tax for failure of a hospital to meet 501(r)(3)
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Local Health Depts
(PHAB)
•
Community Health Assessment (CHA)
every 5 years
Nonprofit Hospitals
(Affordable Care Act)
•
Community Health Needs Assessment
(CHNA) every 3 years
-
•
Engage Community Stakeholders
–
•
Engage Community Stakeholders
–
–
Document partnerships, primary data
collection, and community input
Must report community benefit activities
yearly on Form 990
public health experts
medically underserved, low-income and
minority populations
•
Variety of data sources to identify needs
•
Analytical methods applied to identify
needs
•
Identify Priority Issues using criteria
•
Identify Priority Issues using criteria
•
Description of assets and resources
•
Description of assets and resources
•
Community Health Improvement Plan
(CHIP) and implementation
•
Implementation Strategies for
Community Benefit
•
Documents available to the public
•
Must be widely available to the public
Thanks to KHI and KY PHI
for sharing their crosswalk!
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Other Opportunities for Partnership
Required Assessments:
• Federally Qualified Health Centers (FQHCs):
HRSA requires: “Needs Assessment: Health center
demonstrates and documents the needs of its target
population, updating its service area, when appropriate.”
(Section 330(k)(2) and Section 330(k)(3)(J) of the PHS Act)
• Community Reinvestment Act (CRA): Performance Context
Other groups doing community health assessment and planning:
• United Way, local/regional planning departments, community
foundations, community based organizations, etc.
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Where to find more information on CHNA and Community Benefit
• Catholic Health Association
www.chausa.org
• Hilltop Institute
www.hilltopinstitute.org/hcbp.cfm
• Association for Community Health Improvement
Advancing the State of the Art in Community Benefit
www.communityhlth.org/
• IRS Guidance
www.irs.gov/pub/irs-drop/n-11-52.pdf
www.gpo.gov/fdsys/pkg/FR-2013-04-05/pdf/2013-07959.pdf
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Will County, Illinois
Will County is part of the Chicago Metropolitan Area,
located south of Cook County in northeastern Illinois. The
county has become increasingly suburban, with the
population increasing 35% between 2000 and 2010 (2010
pop: 677,560)
In 2008, the Will County Health Department,
United Way & Presence St. Joseph’s hospital
came together
to partner on a MAPP process
(shared planning, funding, ownership)
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Will County, Illinois
• Lead community health staff from health department and one
hospital attended MAPP (Mobilizing for Action through Planning
and Partnerships) training together
• They became co-coordinators of the project
• Formed a 20-member executive committee including a range
of community partners
• Now, four nonprofit hospitals and the health department are
equal partners, and provide funding for MAPP, with the United
Way acting as fiscal agent
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Will County, Illinois
Key learnings
• All partners benefit from a coordinated, collaborative
approach; Easier to engage more community partners
• The Will County partnership has found it important to
formalize participation on the executive committee with
letters of commitment
• Other counties in Illinois see this success and are adapting this
model
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Challenges/Barriers to initiating these partnerships
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Different motivations
Resource intensive on the front end
Aligning assessments’ frequency and time cycle
Ownership of data
Choosing and interpreting indicators
Overlapping jurisdictions
Scope of assessment can vary
Different reporting needs and audiences
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Communicating the Benefits of Hospital-Health Department
Collaborations on Assessment, Planning and Implementation
Understand the strategic and mission motivators for different partners!
Collective action results in more collective impact
Economies of scale
Improved system efficiencies and less redundancies
One comprehensive assessment can meet several types of requirements
No one entity can fully address issues identified by assessments
Funders reward effective partnerships
For health care, changes in payment/reimbursement will drive more
focus on population health; community benefit needs to be tied into
hospitals’ overall strategy
• Need to continue to develop a shared vision for working on social
determinants of health
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Challenges for a coordinated systems approach
• Paradigm Shift – moving toward population health
interventions and addressing social determinants of health
• Defining Community
• Engaging hospitals and community partners for effective
collaboration and sustainable community health
improvement
• Maximizing levels of partnership and engagement through
regional and systems approaches
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Need for Paradigm Shift
• Hospitals’ community benefit has been mostly charity care and
uncompensated care
As of 2009,
• 72% of community benefit $$ used to help pay for care for
the uninsured or underinsured (charity care, uncompensated
care, means-tested payer discounted care and Medicare
shortfalls)
• only 5% of community benefit $$ went to community health
improvement and community building activities
• Local Health Departments often also find it difficult to move
toward addressing population health and social determinants of
health
Source:
Trust for America’s Health, A Healthier America
2013 - analysis of AHA/Ernst & Young data report
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Roles for PHIs
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- Project Management, consulting, and capacity building
for CHA/CHIP/Implementation
for community engagement
- Facilitate collaborative processes
- Create linkages between partners and help develop a shared vision
- Policy development, analysis, and implementation
• - local, regional, state, federal
- Thought leadership on strategic approaches to integrating
population health in CHNA/community benefit and broader
implementation of the Affordable Care Act
- Convene stakeholders for systems approaches
- Evaluate processes, systems, and impact
• - develop and/or implement metrics and methods
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Panel Discussion
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Wrap Up
Key Takeaways
• PHIs have an important role to play both as consultant/technical
assistance provider but also in building systems and relationships for
partnership
• Need to communicate the value to each partner in a way that speaks to
their motivations, mission, strategy
• There is a wealth of experience and expertise within our network of PHIs
and we should continue to find ways to share
• Different places and contexts call for different approaches. As we
continue to confront and overcome challenges, it is essential that we
share lessons learned in the field.
• There are many untapped opportunities, and we should be open to
thinking outside the box.
• Other reflections?
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Contact Information
Jess Lynch
Illinois Public Health Institute
Jessica.Lynch@iphionline.org
312-850-4744
Reena Chudgar
NACCHO
rchudgar@naccho.org
Kevin Barnett
Public Health Institute
kpb@pacbell.net
Sarah Hurd
Kansas Health Institute
shurd@khi.org
Steve Ridini
sridini@hria.org
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