November 2018 Community Benefit Update

We would like to share the following community benefit news and resources with you. Please visit for access to all of CHA's updates and resources on community benefit.

New Resource for Comments on Proposed "Public Charge" Rule
The Administration has proposed an expansion of the definition of "public charge" when determining the eligibility of legal immigrants to apply for lawful permanent residency (LPR). Under the proposed rule, enrollment in the Medicaid program (and potentially the CHIP program) would prevent legal immigrants from attaining LPR, and force many to choose between vital health care coverage and the ability to adjust immigration status. The rule also includes other vital assistance programs such as nutrition and housing as public charge determinations, as well as setting income level determinations that favor the wealthy over low-income applicants. CHA strongly opposes this rule and will be submitting comments prior to the Dec. 10 deadline. We also are providing a new analysis from Manatt Health for use in preparing comments, with extensive data on the effect of the proposed rule on health care programs and the implications for hospitals. Please urge the Department of Homeland Security not to finalize this harmful rule and ask your members of Congress to weigh in as well. More information is available on e-Advocacy.

Update on IRS Review of Hospital 501(r) Compliance
The Affordable Care Act requires the Internal Revenue Service (IRS) to review all tax-exempt hospitals every three years for compliance with 501(r) requirements. These reviews are done through an examination of public documents so hospitals do not necessarily know they are being audited. Common issues that have arisen in these reviews are:

  • Not having the community health needs assessment (CHNA) conspicuously posted on the website
  • Lack of documentation that the board or authorized committee approved the CHNA or implementation strategy
  • Absent or incomplete financial assistance policies and missing list of providers covered by the financial assistance policy
  • Some auditors have told hospitals that the implementation strategy should be posted on their website, even though this is not a requirement. IRS rules call for attaching implementation strategies to Form 990, Schedule H

Visit the CHA website for a summary of 501(r) requirements.

House Ways and Means Committee Investigation into Maternal Care in Hospitals
On Oct. 10, 2018, the House Ways and Means Committee launched an investigation into the rising death rates among mothers during and after childbirth. The committee has sent letters to 15 of the nation's largest health systems requesting information on how hospitals are addressing rising maternal mortality and severe maternal morbidity in this country. Some of the information requested includes whether hospitals are providing community benefits related to maternal health and if maternal health is assessed in community health needs assessments. More information can be found on the committee's webpage.

New Community Health Worker Resources
The American Hospital Association (AHA) and National Urban League recently released a compendium of resources to help hospitals and health systems implement successful and sustainable community health worker programs (CHW). CHW programs allow hospitals and health systems to address the needs of high-risk or at-risk populations, the social determinants of health, readmissions and emergency department over usage. Resources include program implementation considerations; sample job tools and templates used by CHWs; and case studies from organizations that have implemented successful CHW programs.

One case study highlights Bon Secours Baltimore Health System's leadership of the West Baltimore Primary Care Access Collaborative, a partnership of more than a dozen institutions working together to strengthen the health care system, improve access and reduce persistent and profound health disparities in West Baltimore.

New Blog Series on Innovative Financing Solutions to Improve Health
The Urban Institute's Pay for Success Initiative and the Brookings Institute have launched a blog series titled "Uniting funding streams for health and social innovation." The series highlights the research of experts in health care financing focused on creative approaches.

New Campaign Addresses Chronic Student Absenteeism
Healthy Schools Campaign and Attendance Works are calling on partners nationwide to sign on to the Here + Healthy campaign to raise awareness about the connection between chronic absenteeism and health and proven solutions to this problem. Chronic absenteeism detracts from learning and is a proven early warning sign of academic risk and school dropout. This fall, states will release their new school report cards under the Every Student Succeeds Act and for the first time, chronic absence rates will be included on all state and local report cards. These report cards provide an opportunity to bring stakeholders together to address the causes of chronic absenteeism. For more information and resources, visit

Resources to Help Communities Partner with Hospitals on CHNAs
As many hospitals gear up for a third round of CHNAs and consider community outreach and partnership, the Center for Consumer Engagement and Health Innovation at Community Catalyst has created two new resources that offer important lessons for anyone using community benefit to improve community health:

Building Local Capacity to Engage Hospitals: Lessons and Learnings from Three Communities

Hospital Community Benefit Dashboard: Advancing Health Equity and Community Engagement

In Case You Missed It — New Resources from CHA
Visit the CHA website to learn more about the following new resources:

Upcoming CHA Events
Dec. 18, 2018, from 2 - 3 p.m. ET — Community Benefit and Finance/Tax Staff: Cultivating Relationships for Accurate Reporting.
This webinar, based on a new resource developed by CHA and Vizient, will discuss effective strategies for enhancing the relationship between community benefit and finance staff. It will also describe what finance and tax staff need to know about community benefit reporting, including: accounting principles underlying the IRS Form 990, Schedule H instructions; how to account for each of the community benefit categories; and common errors in over and under reporting. Registration is free for CHA and Vizient members.

Community Benefit in the News
View recent articles from Catholic Health World and Health Progress featuring community benefit news and programs from the across the ministry.