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Community Health Needs Assessment Requirements for Tax-Exempt Hospitals November 2011
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What Are The IRS Requirements?
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Hospitals Required to Comply All hospitals recognized as a 501(c)(3), including governmental hospitals. MHA has requested a method for governmental hospitals to submit the required information.
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Multihospital Organizations If more than one hospital is operated by an organization, each hospital is required to complete a CHNA and adopt an implementation strategy, including separate documentation. MHA encouraged the IRS to allow a consolidated CHNA to be submitted with separated CHNAs and strategies within.
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Timing and Frequency of CHNAs The CHNA must be conducted once every three years, beginning in the hospital’s first taxable year after March 23, 2012. To be considered conducted, the written report must also be made widely available to the public.
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8 Steps To Conducting A CHNA Step One: Define the Community Step Two: Identify Partners Step Three: Gather Secondary Data Step Four: Develop and Conduct Primary Data Assessment Step Five: Aggregate Primary and Secondary Data Step Six: Identify and Prioritize Community Health Issues Step Seven: Develop and Implement a Strategy to Address the Priority Health Issues Step Eight: Disseminate the CHNA Report
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Using The CHNA Results – Implementation Hospitals are required to: Identify, prioritize and address health issues identified in the CHNA Explain why certain identified health issues may not be addressed Implementation is step 7 in the CHNA process – more information will follow
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Dissemination of CHNA Results Hospitals are required to: Post the written report on the hospital’s website or another appropriate website Provide individuals with instructions on how they may download or receive a printed copy Dissemination is step 8 in the CHNA process – more information will follow
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Documenting the CHNA Process
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Documentation Components Description of the: Community Process and methods used How broader interests were considered Prioritized community health needs List of existing health care resources List of identified gaps
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Questions?
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The Community Health Needs Assessment Process Where to begin… What are the steps?
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Population- based model for improving health outcomes CHNA questions and data Categories for analysis and priorities Implementation Plan Strategies and process measures Outcome measures
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Step One: Define the Community The community definition must include Geographical service area Population served Specialty services provided At-risk populations Unique community characteristics Federal designation for medically underserved Other hospitals in same “community”
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Step One: Community (cont’d) MHA encouraged the IRS to allow hospitals flexibility in the definition of community while including the medically underserved, low-income and chronically ill populations.
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The CHNA must include information from: Those with special knowledge or public health expertise* The broad community including low-income, minority, medically underserved, those with chronic disease, unique sub-groups Step Two: Identify Partners Do not conduct the CHNA alone, others need and want this information * The IRS has not defined the qualifications of “persons with special knowledge of or expertise in public health. MHA has commented this should remain flexible.
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Step Two: Partners (cont’d) Consider the following CHNA partners: Local public health agency Health care consumer advocates Nonprofit organizations Academic institutions Government officials Business community, Chamber of Commerce Ministerial alliances Support groups
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Step Three: Gather Secondary Data Hospitals are strongly encouraged to gather data from other reliable local, state and national resources. These data should provide the foundation for the quantitative information. What do the data indicate are the health care issues in your community?
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Step Three: Secondary Sources Consider the following CHNA Sources MHA preventive hospital and health behavior reports: www.mhanet.com www.mhanet.com Missouri Department of Health and Senior Services – Missouri Information for Community Assessment: www.health.mo.gov www.health.mo.gov Federal government agencies – http://www.healthypeople.gov/2020/default.aspx http://www.healthypeople.gov/2020/default.aspx National Foundations – www.countyhealthrankings.org www.countyhealthrankings.org – http://www.statehealthfacts.kff.org/ http://www.statehealthfacts.kff.org/
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Future CHNA Steps Step Four: develop and conduct primary data assessment Step Five: aggregate primary and secondary data Step Six: identify and prioritize community health issues Step Seven: develop and implement a strategy to address the priority health issues Step Eight: disseminate the CHNA report
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One Strategy: Commit to Three Stakeholders/partners Secondary data sources Formats for primary survey At-risk population groups Routes to disseminate findings Priorities to address Strategies for each priority Three indicators per priority Three year plan
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Consequences and Benefits of Compliance
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Benefits of Compliance Strong communities need strong hospitals and strong health partnerships that work to address: the behaviors and prevalence of chronic diseases obesity through good nutrition and active lives community safety through increased preparedness and resiliency deteriorating mental health infrastructure the needs of vulnerable populations
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Failure To Comply A $50,000 excise tax will be imposed for each taxable year in any three-year period. Multihospital systems will be subject to the excise tax if it does not meet the requirements for all of its hospitals separately.
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Questions?
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Future Webinars and Conference Conducting and Documenting the CHNA 2:30 – 4 p.m., Wed., January 25 or 10:30 – noon, Thurs., February 9 Analyzing and Prioritizing CHNA Data 2:30 – 4 p.m., Wed., March 7 or 9 – 10:30 a.m., Thurs., March 8 Practical Strategies for Addressing Obesity 9 a.m. – 3:30 p.m., Tues., June 19, Lake of the Ozarks
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Leslie Porth, MPH, R.N. Vice President of Health Planning 573-893-3700 x 1305 lporth@mail.mhanet.com Staff Contact Mary Becker Senior Vice President of Strategic Initiatives 573-893-3700 x 1303 mbecker@mail.mhanet.com
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