CHNA is a Federal Requirement for Tax-exempt Hospitals

1. Kansas Health MattersTools and Resources forCommunity Health Needs AssessmentsCAH State Network Council MeetingDecember 8, 2011Cindy SamuelsonKansas Hospital Association

2. CHNA is a Federal Requirement for Tax-exempt Hospitals • At least once every three years; first one must be completed by end of tax year beginning after March 23, 2012. • Include input from persons who represent the broad interest of the community. • Include input from persons having public health knowledge or expertise. • Make assessment widely available to the public. • Adopt a written implementation strategy to address identified community needs. • Failure to comply results in excise tax penalty of $50,000 per year. Patient Protection and Affordable Care Act (Health Care Reform Law March, 2010)

3. Notice 2011-52 Regarding the Community Health Needs Assessment Requirements for Tax-exempt HospitalsKHA Comments in Sept. 2011 “In order for communities to obtain meaningful information through the CHNA, we are requesting that the final rule provide sufficient flexibility to allow 501(c)3 hospitals ample opportunity to meet the identified needs of their communities.”

4. Notice 2011-52Regarding the Community Health Needs Assessment Requirements for Tax-exempt Hospitals Hospitals will have two produce two (2) documents: 1. Community Health Needs Assessment Written Report 2. Implementation Strategy

5. CHNA Written Report Implementation Strategy • Approved by Board of Directors • Attached to 990 • 990 has to be widely available to the public • Widely available to the public • On hospital Web site • Give to anyone who asks

6. Form 990Schedule HPart V

7. Notice 2011-52 – not final yetCHNA Written Report Treasury and the IRS intend to require a hospital organization to document a CHNA for a hospital facility in a written report that includes the following information: 1. A description of the community served by the hospital facility and how it was determined.

8. CHNA Written Report 2. A description of the process and methods used to conduct the assessment, including: • a description of the sources and dates of the data and other information used in the assessment; • the analytical methods applied to identify community health needs; • a description of any information gaps that impact the hospital’s ability to assess the health needs of the community;

9. CHNA Written Report 3. A description of how the hospital took into account input from persons who represent the broad interests of the community, including: • a description of when and how the hospital consulted with these persons (meetings, focus groups, interviews, surveys, written correspondence, etc.); • if the hospital takes into account input from an organization, the written report should identify the organization and provide the name and title of at least one individual who was consulted.

10. CHNA Written Report • In addition, the report must identify any individual providing input who has special knowledge of or expertise in public health by name, title, and affiliation and provide a brief description of the individual’s special knowledge or expertise. • The report also must identify any individual providing input who is a “leader” or “representative” of [medically underserved, low income, and minority populations with chronic disease needs whom are served by the hospital] by name and describe the nature of the individual’s leadership or representative role.

11. CHNA Written Report 4. A prioritized description of all of the community health needs identified through the CHNA, as well as a description of the process and criteria used in prioritizing such health needs. 5. A description of the existing health care facilities and other resources within the community available to meet the community health needs identified through the CHNA.

12. CHNA Written Report NOTE: If a hospital organization collaborates with other organizations in conducting a CHNA, the report should identify all of the organizations with which the hospital organization collaborated. If a hospital organization contracts with one or more third parties to assist it in conducting a CHNA, the report should also disclose the identity and qualifications of such third parties.

13. Notice 2011-52 – not final yet Treasury and the IRS intend to require a hospital organization to specifically address each of the community health needs identifiedthrough a CHNA for a hospital facility in an implementation strategy, rather than in the written report documenting the hospital facility’s CHNA.

14. Implementation Strategy A written plan that addresses each of the community health needs identified through a CHNA. An implementation strategy will address a health need identified through a CHNA for a particular hospital facility if the written plan either: (1) describes how the hospital facility plans to meet the health need; or (2) identifies the health need as one the hospital facility does not intend to meet and explains why the hospital facility does not intend to meet the health need.

15. Resources and Tools on Kansas Health Matters www.KansasHealthMatters.org

21. Counties – Regions – State • 56 Core Indicators from KanPICH • 30 Social determinants from HCI • More Indicators possible • Tie in to Community Toolbox • Tie in to Kansas Information for Communities • Tie to local 211 resources

22. Resources and links organized by categories to achieve Community Health Needs Assessment • Preparing for CHNA • Data Collection and Analysis • Engagement and Prioritization • Development of Community Action Plan • Plan Implementation and Monitoring • “Ask an Expert” module to handle inquiries

23. Cost • System development with Kansas-specific content: $75,000 • Annual license, maintenance and support fees: $90,000 • Initial funding: • Kansas Health Foundation • CDC infrastructure grant • Would cover through end of 2012

24. Sustainability • Users and stakeholders will have to come up with $90,000 a year: • Local Health Departments • KDHE • Hospitals • KHA • KHF • Others…? • Potential number of users, supporters is large (>100 hospitals, 100 LHDs, etc.)

25. Project Timeline Initiate Contract Soft Launch Data Population & Facilitator Training Team Launch Public Launch Early June Jan. 1, 2012--Dec. 31, 2012 Oct.1, 2011 Dec.1, 2011 • Kansas Health Matters Webinars • Recorded version available on KHA Web site • 2:00 - 3:30 p.m. — December 13, 2011 • Additional training coming through KRHOP and Kansas Health Foundation

27. Questions? Cindy Samuelson csamuelson@kha-net.org Kansas Hospital Association (785) 233-7436