The Community Health Needs Assessment: Are You Ready?
The CHNA requirements are effective for tax years beginning after March 23, 2012. The initial “three-year window” commences with tax years beginning after this date. For example, a June 30 year-end hospital must complete and release its completed CHNA and written implementation strategy prior to June 30, 2013.
The Internal Revenue Service (“IRS”) plans to impose penalties of $50,000 on hospitals that fail to meet the requirements for any taxable year. Additional penalties may also apply, related to the requirements to attach the CHNA to the hospital’s annual Form 990. Failure to attach the report could result in penalties for filing an incomplete return.
What should be included?
Pursuant to IRS Notice 2011-52, the written report of the CHNA must include the following information:
1. Description of the community served by the hospital facility and how it was determined.
2. Description of the process and methods used to conduct the assessment, including:
- Sources and dates of the data.
- Other information used.
- Analytical methods applied to identify community health needs.
- Information gaps that impact the ability to assess the health needs.
3. Identity of organizations with which the hospital collaborated for the study.
4. Identity and qualifications of third parties that assisted in the CHNA.
5. Description of how the hospital utilized input from people who represent the broad
interests of the community, including:
- Description of when and how the organization consulted with these people (meetings, focus groups, interviews, surveys, etc.).
- For organizations consulted, identity of organization, and name and title of at least one individual in the organization who was consulted.
- Name, title, affiliation, and description of expertise of anyone having special knowledge or expertise in public health.
- Identity of individuals consulted who are leaders or representatives of medically underserved, low-income, and minority populations and populations with chronic disease needs. (Note: The CHNA must include input from people with special knowledge or expertise in public health; health departments or agencies; and from leaders/representatives of medically underserved, low-income, and minority populations, and populations with chronic disease needs.)
6. Prioritized description of all community health needs identified through the CHNA as well
as a description of the process and criteria used in prioritizing such health needs.
7. Description of existing healthcare facilities and other resources within the community
available to meet the community health needs identified through the CHNA.
The CHNA should be made widely available to the public, both as hard copies and on the hospital’s website (or a link to a website where it can be accessed).
In addition to the CHNA report, the organization must also adopt an implementation strategy to meet the community needs identified. The written plan should:
- Describe how the facility plans to meet the identified health need.
- Identify the health need as one the hospital facility does not intend to meet and explain why.
Though the hospital does not need to make the implementation strategy widely available to the public, it is required to attach a copy of the strategy to Form 990.
Some organizations have prepared or released community benefit reports in the past; however, based on recent guidance, most hospitals are finding previous reports do not meet the requirements of a CHNA as defined by the IRS. It is important to review previous reports in light of the new guidance and begin identifying what revisions and expansions are required.
The Community Health Needs Assessment: Are you really ready? We can help!
Please contact Debbie Ernsberger or Terry Haefner at (800) 270-9629.
WE ARE REQUIRED BY IRS CIRCULAR 230 TO INFORM YOU THAT THE FOLLOWING DISCUSSION WAS NOT INTENDED OR WRITTEN TO BE USED, AND IT CANNOT BE USED, NOR RELIED UPON, BY ANY TAXPAYER FOR THE PURPOSE OF AVOIDING ANY PENALTIES THAT MAY BE IMPOSED UNDER FEDERAL TAX LAW. THE ADVICE WAS WRITTEN TO SUPPORT THE PROMOTION OR MARKETING OF THE TRANSACTIONS OR MATTERS ADDRESSED IN THE DISCUSSION. EACH TAXPAYER SHOULD SEEK ADVICE BASED ON ITS PARTICULAR CIRCUMSTANCES FROM AN INDEPENDENT TAX ADVISOR.