Community Benefit

January 2014 Community Benefit Update

Form 990 Schedule H Instructions
The Internal Revenue Service (IRS) has published instructions for completing the 2013 Form 990, Schedule H. Of note, the instructions reverse the agency's earlier stance on reporting community benefit grant revenue. Previously, grant revenue for community benefit did not have to be offset in calculating total expense. In the final instructions, this revenue would be offset. CHA and other hospital organizations have commented to the IRS that this change should not be made. The instructions also ask hospitals to indicate they are in compliance with Affordable Care Act 501(r) requirements on emergency medical care if they have policies in place that require compliance with the Emergency Medical Treatment and Active Labor Act (EMTALA) and that prohibit "debt collection activities from occurring in the emergency department or in other hospital venues where such activities could interfere with the treatment of emergency medical conditions without discrimination." CHA and other hospital organizations have urged that compliance with EMTALA is sufficient and meets the intent of the law. Hospital organizations have asked for a meeting with IRS officials regarding these changes to note these concerns.

IRS Guidance for Charitable Hospitals
On Dec. 30, the IRS published two notices providing guidance on the roles and responsibilities of charitable hospitals. The first notice includes a proposed revenue procedure providing a process for charitable hospitals that fail to satisfy the requirements under section 501(r) of the Internal Revenue Code — which provides their charitable, tax-exempt designation — to follow in order to correct and disclose those failures. Comments are being accepted on this notice until March 14, 2014. The second notice confirms reliance on proposed regulations already released under section 501(r) regarding charitable hospitals' responsibilities. This notice states that tax-exempt hospital organizations can rely on proposed regulations under 501(r) contained in notices of proposed rulemaking published on June 26, 2012, and April 5, 2013, pending the publication of final regulations or other applicable guidance. Visit the CHA website to view these proposed rules.

RWJF Commission Calls for Greater Investment in Early Childhood Development Programs
The nonpartisan Robert Wood Johnson Foundation (RWJF) Commission to Build a Healthier America is urging leaders across the United States to shift funding priorities to emphasize three areas essential to improving the nation's health: increasing access to early childhood development programs; revitalizing low-income neighborhoods; and broadening the mission of health care providers beyond medical treatment. The Commission has determined that these areas have the greatest potential for improving the health of the population, especially for low-income families, and offer the greatest opportunities for collaboration.

The Commission's recommendations are contained in the report Time to Act: Investing in the Health of Our Children and Communities. The report also highlights promising examples of cross-sector collaborations, innovation and success throughout the country. For more information about the Commission and for a copy of the report, go to www.rwjf.org/commission.

Upcoming CHA Programs

Community Benefit Pre-Assembly Program — June 22, 2014
The 2014 community benefit Pre-Assembly conference will be held immediately before the Catholic Health Assembly on June 22, 2014, at the Chicago Marriott Downtown. This year's program will feature an official from the IRS (invited) who will give 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, 2014, in St. Louis
Save the date for CHA's annual CB 101 program. This one-and-a-half day conference, designed for new community benefit professionals, presents a practical framework for assessing community needs and planning, evaluating and reporting on community benefit programs.