Community Health Needs Assessments
Posted Friday, September 30, 2011 by .
Posted by Scott Good
Section 9007(a) of the Affordable Care Act (March 2010) requires that all non-profit hospitals complete a CHNA every three years. The purpose of the CHNA is to identify and prioritize community needs and, in doing so, support financial reporting and the selection of the hospitals' community outreach activities.
I am generally not the biggest supporter of health reporting regulations. However, the community assessment noted above provides a better measuring stick by which hospitals can evaluate their outreach activities. More importantly, they will have a tool (mandated, as it is) that will compel them to clarify the needs of their communities and prioritize hospital activities to address them.
Some states already require some form of CHNA. New Hampshire, for example, does an outstanding job (kudos to Terry Knowles in the NH, DOJ, Charitable Organizations Office). Other states, too, do excellent work. But here's the rub ...
Additional providers of CHNA services. The Feds are requiring that the CHNAs address only healthcare needs. Many hospitals combine their CHNA efforts with other nearby not-for-profit organizations to use the services of more general community support organizations such as the United Way (of which I am a strong supporter). These types of organizations identify broader community needs that impact the often diverse collection of organizations for whom they conduct the CHNA - some of which are health / healthcare based, many are not. The result is that hospitals, therefore, may need to supplement the work done with the help of general community support organizations (which is more expensive), do the work themselves (which is more expensive), or combine efforts with other hospitals and contract the services of a third party (which may make sense).
New techniques for prioritization. Many states' CHNA regulations have asked for a prioritized list of needs. However, the new regulations appear to up the ante by having hospitals say HOW they will meet needs and WHY they will not address community needs on their priority lists. The result is that a "simple show of hands at a focus group" is no longer helpful to determine real priorities that (1) exist in the community, and, (2) fall within the hospital's scope of services. BOTH pieces are needed to prioritize. Crescendo has developed an efficient and effective way to do this for community needs assessments.
Linkage. The New regulations also require the CHNA to be part of the IRS 990H reporting. Over the years, I have heard much "wailing and gnashing of teeth" from hospitals CFO's when they see that their community benefits or charitable giving numbers do not much similar but slightly different government reporting mechanisms. Although the new CHNA requirements seem like more bureaucracy, this change could really help streamline some reporting functions -- IFF (i.e., if and only if) the CHNA is conducted properly.
I'm a big fan of health system assessments of this type. The new regulations for the Community Health Needs Assessments will be a good thing once everyone gets used to doing them. They do not have to be hugely expensive, time consuming, or cause undue wailing and gnashing of teeth. If you have any additional questions, give me a call; we've been doing them for many years!