Community Health Needs Assessments (CHNA) are excellent opportunities for local health departments to enter into or bolster partnerships with nonprofit hospitals and Federally Qualified Health Centers. In the Quad Cities (Davenport and Bettendorf, Iowa; Rock Island and Moline, Illinois), this relationship is flourishing, in part due to an IRS requirement stemming from the Affordable Care Act (ACA).
The Quad Cities bridge the Mississippi River and, although the state line separates them, they share many public health and health systems interests and concerns. Within the scope of Scott County Health Department (SCHD) in Iowa and Rock Island County Health Department (RICHD) in Illinois there are two non-profit health systems, Genesis Health System and Trinity Regional Health System. These Local health departments are required to perform a CHNA every five years. Additionally Schedule H of IRS Form 990 requires that non-profit hospitals perform and report the results of CHNAs conducted within the current or prior two tax years.
After the final meeting of the SCHD CHNA committee in September 2010, the directors of SCHD and RICHD proposed a collaboration with the health systems to produce joint CHNAs and maintain a repository of current data that could be utilized by each agency. The Quad City Health Initiative, an organization including representatives of local health departments, health systems and providers, insurers, social service agencies, educators, businesses, media, law enforcement, foundations and governments, agreed to organize and facilitate the process.
The effort commenced before it was clear whether hospitals could take full advantage of the collaboration. But in July of 2011, in response to comments from non-profit hospitals expressing a desire to collaborate with local public health agencies, IRS Notice 2011-52 indicated that “Treasury and the IRS intend to allow a hospital organization to base a CHNA on information collected by other organizations, such as a public health agency… Treasury and the IRS also intend to allow a hospital organization to conduct a CHNA in collaboration with other organizations, including… local health departments,” clearing the way for a fully integrated process.
The Quad Cities CHNA will be released In February 2012. Community partners who are called upon to provide input for the assessments have found the joint process less demanding of time and resources. The collaboration is currently expanding, with the addition of Community Health Care, Inc., the Quad Cities’ Federally Qualified Health Center, as a partner.
As we move forward with the implementation of the ACA, collaboration with Accountable Care Organizations (groups of doctors, hospitals, and other health care agencies that work together to coordinate the quality of health care) on population health issues will be even more important in order to advance and ensure sustainable public health programs in the community.
If you are interested in learning more about collaborative efforts among health care partners in the Quad Cities, you may visit the QCHI website. A copy of the joint CHNA will be available after publication.
This information was developed by Edward R. Rivers, director of the Scott County Health Department in collaboration with the Network for Public Health Law.
The Network for Public Health Law provides information and technical assistance on issues related to public health. The legal information and assistance provided in this document does not constitute legal advice or legal representation. For legal advice, readers should consult a lawyer in their state.