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Implementing the Affordable Care Act—Community Health Needs Assessments

posted on Thu, Mar 31 2016 9:12 am by Network for Public Health Law

In this Q&A excerpted from an article that appeared in the January 2016 issue of the American Health Lawyers Association newsletter Hospitals and Health Systems RX, Gene Matthews, Director of the Network’s Southeastern Region Office, talks about community health needs assessment (CHNA) efforts in North Carolina, and the challenges faced by hospitals, local health departments and community partners.

Do you see a direction in which the CHNA guidance is evolving as revealed in the more recent IRS and Treasury Department regulations and issuances?

The more recent IRS and Treasury Department regulations and issuances are clearly making the CHNA and Implementation Strategy requirements a continual, iterative process rather than simply a once-every-three-years event. The federal agency comments in the Final Rule clearly intend to establish a continual feedback loop on CHNA reports.

For example, the 2014 Instructions for Schedule H (Form 990) require in each year that the hospital explain how the facility “is addressing the significant needs identified in its most recent CHNA and any such needs that are not being addressed together with the reasons why such needs are not being addressed.”

What factors helped North Carolina develop a state-wide collaboration between hospitals and health departments to focus the next cycle of CHNA on a common implementation strategy theme of healthy weight?

Initially a joint initiative was launched in 2007 by the leadership of the North Carolina Hospital Association and the North Carolina Division of Public Health focusing on common issues. Over time it became known as the North Carolina Community Health Improvement Collaborative (NC-CHIC). It expanded to include local health department (LHD) leaders, academic institutions, and community partners. It also increasingly focused on CHNA implementation for nonprofit hospitals.

For more than a decade, North Carolina has had by statute, a mandatory LHD accreditation program that requires all LHDs to periodically conduct community health assessments. By the time the ACA requirements started to go into effect in 2012 for nonprofit hospitals to conduct CHNAs, any hospital in North Carolina could readily obtain a community health assessment for a county electronically from the state health department website. This asset helped jump-start collaborations among hospitals and LHDs focusing on joint health assessments.

As the NC-CHIC efforts matured, it has been able to build a consensus to provide leadership and resources for local hospital and LHD collaborations to include other community partners in common implementation strategies directed toward a state-wide healthy weight campaign.

What are the most common challenges facing hospitals, LHDs, and community partners as this CHNA process moves forward?

First, CHNAs can improve their geographical alignment to accurately reflect the area that the hospital serves and to include the medically underserved populations within that jurisdiction.

Second, the Implementation Strategies need to eliminate the current skewing of priority needs that focus too much on clinical care. More attention has to be focused on upstream health determinants of healthy behaviors, social and economic factors, and the physical environment.

Third, efforts must continue to align hospital community benefits expenditures with the priority needs identified through this CHNA process.


More resources on community health needs assessments can be found here.

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 post does not constitute legal advice or legal representation. For legal advice, readers should consult an attorney in their state.

Support for the Network is provided by the Robert Wood Johnson Foundation (RWJF). The views expressed in this post do not necessarily represent the views of, and should not be attributed to, RWJF.

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