June 2 Schedule H Webinar — Archive Now Available
On June 2, CHA and VHA Inc. hosted a webinar on the IRS Form 990, Schedule H, for tax year 2013, Everything You Wanted to Know about the IRS Form 990H but were Afraid to Ask. Over 400 attendees heard Stephen Clarke, who oversaw the creation, rollout and yearly update of the Schedule H while serving as a tax law specialist at the IRS, share his insights on:
- Revised reporting requirements for restricted grants and other Schedule H changes for tax year 2013.
- Reporting of some community building activities as community benefit on Schedule H.
- How the IRS reviews tax-exempt hospital Schedule H forms.
CHA members can access the webinar archive online at the CHA Knowledge Center (log in required). Once at the Knowledge Center use keyword "990" to search for the archive. Others can purchase the archive by visiting the CHA Store.
HHS Clarifies Position on Premium Support from Third Parties
In a letter to CHA dated May 21, 2014, the Department of Health and Human Services stated that payments would not be prohibited from private, not-for-profit foundations to qualified health plans on behalf of individuals who enroll in coverage for the exchange health plans under the Affordable Care Act. HHS stated that such payments must be made on behalf of recipients based upon defined criteria regarding financial status and should not consider the enrollee's health status, and should cover the entire policy year.
Sen. Grassley Asks IRS about Status of Nonprofit Hospital Rules and Reviews
On April 4, 2014, Sen. Chuck Grassley of Iowa sent a letter to John Koskinen, IRS Commissioner requesting the IRS to account for the status of several important oversight measures for nonprofit hospitals enacted in 2010 as part of the Affordable Care Act (ACA). Sen. Grassley specifically asks about the status of (1) a Memorandum of Understanding (MOU) between the IRS and HHS, recommended in 2012 by the Treasury Inspector General for Tax Administration, but not finalized; (2) the annual reports to Congress regarding nonprofit hospitals; and (3) regulations implementing the provisions of ACA for nonprofit hospitals. He also requested information regarding the IRS' reviews of the community benefit activities of nonprofit hospitals, including how many hospitals had been reviewed and the results of the reviews.
On April 9, 2014, Commissioner Koskinen provided a detailed response to Sen. Grassley's requests, noting that the IRS "continues to work towards finalization of the proposed regulations" and that "finalization of these regulations constitutes an item on the IRS Priority Guidance Plan for the year ending June 30, 2014."
What Counts Update
Restricted Grants
CHA's What Counts task force has received several questions about the change in the 2013 IRS Form 990 Schedule H Instructions that now requires restricted grants or contributions to be included in offsetting revenue.
The task force recommends that organizations follow generally accepted accounting principles on what constitutes a restricted grant. According to FASB Accounting Standards Codification (ASC) 958-605-25 Not-for-Profit Entities Revenue Recognition a donor-imposed restriction "specifies a use that is more specific than broad limits resulting from the nature of the organization, the environment in which it operates, and the purposes specified in its articles of incorporation or bylaws or comparable documents… A restriction on an organization's use of the assets contributed results either from a donor's explicit stipulation or from circumstances surrounding the receipt of the contribution that make clear the donor's implicit restriction on use."
Accounting principles also direct that the revenue should offset expenses when the restrictions are met (as opposed to when the donation is received) and the revenue is recognized in the income statement.
CHA, AHA and other hospital organizations met with IRS officials in June and urged them to change this instruction. We will keep you informed of any updates.
Changing Target Populations of Current Community Benefit Programs
The task force received a question about whether a hospital could change the target populations of its current community benefit programs from the community at-large to its ACO and medical groups.
The task force recommends that a hospital should not define its population, for community benefit purposes, as persons served by its Accountable Care Organization (ACO) because this could lead the ACO to exclude persons who are uninsured. IRS proposed rules for CHNAs prohibits defining the community in a way that excludes vulnerable populations.
National Forum on Hospitals, Health Systems and Population Health: Partnerships to Build a Culture of Health
The Robert Wood Johnson Foundation is sponsoring a national conference on population health this fall in Washington, DC. The conference will examine how health care organizations can implement population health strategies that create a community-wide "culture of health."
Existing community benefit program are an important asset in an organization's population health approach. Consider submitting a proposal to share how your organization's community benefit efforts are being integrated into its efforts to improve the health of patients and the broader community. View the conference website for more information.
Hilltop Institute Releases Issue Brief on Social and Economic Factors that Shape Health
This brief describes hospital reported programs that target specific social and economic factors, regulatory tools that could be used to facilitate hospital investment in activities that address social and economic determinants and recommendations for state and local policy makers. View a PDF of the brief.
HEARTS — Healthy Environments and Response to Trauma in Schools
Investing in What Works for America's Communities recently featured a story about HEARTS — Healthy Environments and Response to Trauma in Schools — a highly effective program developed by the University of California — San Francisco and the San Francisco Unified School District aimed at creating school environments that are more trauma-sensitive and supportive of the needs of traumatized children. HEARTS' co-founder Joyce Dorado views chronic trauma as a public health issue, because it causes toxic stress that can harm children's brains by changing the brain's structure and functioning. The story highlights the need for all sectors of a community — police, housing, employment, transportation, medical services, economic development — to work together to implement trauma-informed practices.
Summer MAPP Training Opportunity
The National Association of County & City Health Officials (NACCHO) is offering an introductory training class on its MAPP process on July 7 and 8 in Atlanta, Ga. MAPP is a community-owned strategic planning process informed by comprehensive assessments for improving the public's health.
Participants will learn the nuts and bolts of the MAPP process, hear stories from MAPP users, and gain concrete skills for engaging community organizations, partners and community members in your MAPP process.
Download a flyer with registration details.
Requesting Input from the Field
Over the next few months CHA will be revising the following community benefit publications:
- A Guide for Planning and Reporting Community Benefit
- Assessing and Addressing Community Health Needs
- Evaluating Community Benefit Programs
If you would like to be involved in the revision process or have suggested changes to make these resources more useful, please contact Julie Trocchio.
Upcoming CHA Programs
Community Benefit Pre-Assembly Program
June 22 — Chicago
The 2014 Community Benefit Pre-Assembly Conference will be held immediately before the Catholic Health Assembly on June 22, at the Chicago Marriott Downtown Magnificent Mile. This year's program will feature an update on regulations related to community health needs assessments, an introduction to community health improvement resources from the County Health Roadmap's Action Center and examples of Catholic health care organizations that are focusing on two important issues in community health improvement: health disparities and outcomes-based community benefit programming. Register today!
Community Benefit 101: The Nuts and Bolts of Planning and Reporting Community Benefit
Sept. 30 – Oct. 1 — St. Louis
Taught by experienced community benefit leaders, this one-and-a-half day conference presents a practical framework for assessing community needs and planning, evaluating and reporting on community benefit programs. While designed for new community benefit professionals, veteran community benefit staff have shared that it is a good refresher course to update them on current practices, inspire future activities and connect with others in nonprofit health care doing this work.
Visit the CHA website to learn more and register.