IRS Notice 2011-52 Overview
Applicability of CHNA Requirements to “Hospital Organizations”
The CHNA requirements apply to “hospital organizations,” which are defined in Section 501(r) to
include (1) organizations that operate one or more state-licensed hospital facilities, and (2) any other
organization that the Treasury Secretary determines is providing hospital care as its principal function
or basis for exemption.
Under Section 501(r), a hospital organization is required to conduct a CHNA for each of its hospital facilities
once every three taxable years. The CHNA must take into account input from persons representing the
community served by the hospital facility and must be made widely available to the public. The CHNA
requirements are effective for taxable years beginning after March 23, 2012 . As a result, a hospital
organization with a June 30 fiscal year end must conduct an initial CHNA for each of its hospital facilities by
June 30, 2013, either during the fiscal year ending June 30, 2013 or during either of the two previous fiscal
years.
Determining the Community Served
A CHNA must identify and assess the health needs of the community served by the hospital facility.
Although the Notice suggests that geographic location should be the primary basis for defining the
community served, it provides that the organization may also take into account the target populations
served by the facility (e.g., children, women, or the aged) and/or the facility’s principal functions (e.g.,
specialty area or targeted disease). A hospital organization, however, will not be permitted to
define the community served in a way that would effectively circumvent the CHNA requirements (e.g.,
by excluding medically underserved populations, low-income persons, minority groups, or those
with chronic disease needs).
Persons Representing the Community Served
Section 501(r) provides that a CHNA must take into account input from persons who represent the
broad interests of the community served by the hospital facility, including individuals with special
knowledge of or expertise in public health. Under the Notice, the persons consulted must also
include: (1) government agencies with current information relevant to the health needs of the
community and (2) representatives or members of medically underserved, low-income, and minority
populations, and populations with chronic disease needs, in the community. In addition, a hospital
organization may seek input from other individuals and organizations located in or serving the hospital
facility’s defined community (e.g., health care consumer advocates, academic experts, private
businesses, health insurance and managed care organizations, etc.).
Required Documentation The Notice provides that a hospital organization will be required
to separately document the CHNA for each of its hospital facilities in a written report that includes
the following information: ???a description of the community served by the facility and how the
community was determined; ???a description of the process and methods used to conduct the
CHNA; ???the identity of any and all organizations with which the organization collaborated and third
parties that it engaged to assist with the CHNA; ???a description of how the organization considered
the input of persons representing the community (e.g., through meetings, focus groups, interviews,
etc.), who those persons are, and their qualifications; ???a prioritized description of all of the
community needs identified by the CHNA and an explanation of the process and criteria used in
prioritizing such needs; and ???a description of the existing health care facilities and other resources
within the community available to meet the needs identified through the CHNA.
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