Module 2: IRS Guidance for Conducting a CHNA   

The Patient Protection and Affordable Care Act (PPACA) enacted March 23, 2010 added new requirements that not-for-profit hospital organizations must satisfy in order to retain designation as a 501 (c) (3) organization. Each hospital organization is required to meet four general requirements on a facility-by-facility basis

  • Establish written financial assistance and emergency medical care policies
  • Limit amounts charged for emergency or other medically necessary care to individuals eligible for assistance under the hospital's financial assistance policy
  • Make reasonable efforts to determine whether an individual is eligible for assistance under the hospital’s financial assistance policy before engaging in extraordinary collection actions against the individual, and
  • Conduct a community health needs assessment (CHNA) and adopt an implementation strategy at least once every three years

The fourth requirement focuses on the conduct of a triennial CHNA. Guidelines on the conduct of the CHNA are provided by the Internal Revenue Service (IRS), the agency responsible for regulating and enforcing the requirement. Click here to see those requirements

Hospital organizations use Schedule H to provide information on the activities and policies of, and community benefit provided by, its hospital facilities and other non-hospital health care facilities that it operated during the tax year. This includes facilities operated either directly or indirectly through disregarded entities or joint ventures. Schedule H (Form 990) and Instructions for Schedule H are provided at this IRS site.