II. Methodology
a. CHNA Scope and Purpose
The new federal Patient Protection and Affordable Care Act requires that each registered
501(c)3 hospital conduct a Community Health Needs Assessment (CHNA) at least once every
three years and adopt a strategy to meet community health needs. Any hospital who has filed
a 990 is required to conduct a CHNA. IRS Notice 2011-52 was released in late fall of 2011 to
give notice and request comments.
JOB #1: Meet/Report IRS 990 Required Documentation
1. a description of the community served by the facility and how the community was
determined;
2. a description of the process and methods used to conduct the CHNA;
3. the identity of any and all organizations with which the organization collaborated and
third parties that it engaged to assist with the CHNA;
4. 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;
5. 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
6. a description of the existing health care facilities and other resources within the
community available to meet the needs identified through the CHNA.
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: Government agencies with
current information relevant to the health needs of the community and
representatives or members in the community that are medically underserved, lowincome, minority populations, and populations with chronic disease needs. 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.).
JOB #2: Making a CHNA Widely Available to the Public
The Notice provides that a CHNA will be considered to be “conducted” in the taxable year that
the written report of the CHNA findings is made widely available to the public. The Notice also
indicates that the IRS intends to pattern its rules for making a CHNA “widely available to
the public” after the rules currently in effect for Form 990. Accordingly, an organization would
make a facility’s written report widely available by posting the final report on its website
either in the form of (1) the report itself, in a readily accessible format, or (2) a link to another
organization’s website, along with instructions for accessing the report on that website. The
Notice clarifies that an organization must pos BF?R4??f?"V6?f6??G?V?F??F?RFFR??v??6???G27V'6WVV?B4??f?"F?Bf6??G??2?7FVB?p??