Topic: Allied Health Professions (Updated August 2013)
Topic: Clinical Pastoral Education (January 2011)
Topic: Grand Rounds (December 2014)
Topic: Housing Costs (March 2013)
Topic: Libraries (February 2011)
Topic: Long-Term Care Administrator Internships (February 2011)
Topic: Nursing Schools (February 2011)
Topic: Physician Education/CME programs (February 2011)
Topic: Physician Residents/Student Time (February 2011)
Topic: Physician Time in Health Profession Education (June 2012)
Topic: Scholarships (2007)
Topic: Time Working with Health Professions Students (December 2014; Updated November 2015)
Topic: Tuition Assistance (February 2011)
Please Take Note: The information provided above does not constitute legal or tax advice. The material is provided for informational/educational purposes only. Please consult with counsel regarding your organization's particular circumstances.
Topic: Allied Health Professions
Question: What allied health professions training costs count/don't count as community benefit?
Recommendation: We recommend reporting the cost of training any health care professional group that needs training and experience in a health care organization in order to achieve a professional credential or to advance professional knowledge. In addition to medical and nursing students, this would include social services, therapy, dietary, pastoral care, health care administration and other professionals needed to provide health care such as students pursuing degrees in public health or health care administration. To be counted, the program should either be licensed by State law or accredited by the recognized national professional organization for the particular activity.
Do not report training offered exclusively for current staff, including degree-granting programs. Also, do not report the cost of training that could be substituted in other, non-health care settings, such as human resources, accounting, or engineering. Report costs related to post-graduate and doctoral candidates under Category D. Research.
(Updated August 2013)
Topic: Clinical Pastoral Education
Question: Should we report the cost to our organization to train chaplains?
Recommendation: We recommend reporting as community benefit the cost of the CPE program as long as the students are not required to work for your organization post training and you offset the cost of the CPE program with both the federal funds you receive and student fees. This cost should be reported in the category of Health Profession Education.
Please note that when students are "shadowing" chaplains on staff, count only the percentage of the chaplains' time that is spent outside of performing normal duties. For help in calculating this time, see "Nurses Time Mentoring Students."
Topic: Grand Rounds Question:
Our health system offers multi-disciplinary grand rounds which awards CEUs/CMEs to attendees. Physicians, providers and staff who are not employees of our organization are invited and welcome to attend. Do these grand rounds count as community benefit? If so, what should report? Recommendation:
Routine continuing education should not be reported as community benefit. This would be when the primary purpose is to provide education to your staff. If your organization is offering topics that outsiders might not get otherwise and your invitation involves true outreach to others, it could be reported. But keep in mind, if the primary purpose is for the education of your own staff, we recommend not reporting as community benefit.
Topic: Housing Costs
Question: We provide housing for nursing and other health professional education students in a rural community for clinical work at rural hospitals. Can the costs associated with providing housing for nursing and other health professional education students in a rural community be counted as community benefit under the Health Professions Education category?
Recommendation: We recommend that all costs associated with qualified health professions education, including housing for rotations, can be reported. For what qualifies as reportable health profession education, see definitions in IRS form 990 Schedule H instructions or CHA's A Guide for Planning and Reporting Community Benefit.
Question: We have an on-site library. The library's primary "customers" are the medical students; however anyone is able to use the library as a resource. Many individuals who are not affiliated with the hospital (example: nursing students from a nearby college) will use the library as a resource.
Because it is a requirement of the Graduate Medical Education program, I would imagine that it falls under the community benefit of provision of Graduate Medical Education. However, the fact that other people use the library — including individuals from outside of the Hospital, who are unaffiliated with the hospital — raises the question of whether we are providing a community benefit.
Recommendation: Advancing knowledge by having a library available and used by hospital staff and medical students provides clear community benefit. To be counted, the library should be available to the public. It is recommended that the expense of the library be counted in its entirety as Category B3. Other Health Professions Education. You should be careful to follow Medicare Cost Reporting principles in the accounting of Graduate Medical Education costs, including the library. Also use caution not to double count library costs if such costs already have been included in one or more GME cost centers or overhead allocations.
Topic: Long-Term Care Administrator Internships
Question: We provide "administrator" student internships in our long-term care facilities. We give them a stipend while they are working, and this year we have extended paying for their health care benefit. While some of these administrators-in-training (AIT) end-up coming to work for our organization, it is not a given that they will or that they will even be recruited. Our question is, if we are offering both a stipend and health benefits to these AITs, are we still able to count their relationship with us as a community benefit?
Recommendation: The situation you describe sounds more like an employer/employee relationship than student/teaching. The recommendation is that this not be counted as community benefit.
Topic: Nursing Schools
Question: If a hospital operates a school of nursing and must subsidize it to keep it going, is this a community benefit?
Recommendation: If a hospital operates an accredited school of nursing and/or school for other allied health professions, all direct and indirect expenses, offset by any dedicated revenue (e.g., tuition or Medicare reimbursement), count as community benefit. This counts because it meets the community benefit objective, advancing knowledge. The What Counts Task Force recommends, however, that the hospital document that the school is being subsidized because there is a need to increase the supply of health professionals in the community and that graduates are not necessarily obligated to work for the hospital (thus the program provides more community benefit than organizational benefit). Include in the category "Health Professions Education."
Topic: Physician Education/CME Programs
Question: We are a medically underserved area and occasionally we provide CME programs to keep the doctors up-to-date. This benefits the community by providing knowledge to the physicians and also allows them access to this information locally rather than having to go out of town to get it.
Recommendation: Continuing Medical Education programs that are accredited and that are open to all physicians in the community, not only members of the medical staff, count as community benefit under B1, Physician/Medical Students. When reporting, offset costs by any fees collected by the program.
Topic: Physician Residents/Student Time
Question: How should I calculate the true cost of having residents/students?
Recommendation: We recommend that you follow the Schedule H Instructions which state that filing organizations are to use their most accurate costing method for community benefit. This method should be used to determine the direct and overhead costs of students, including faculty/attending time involved with supervising students (including interns and residents) and other related costs, such as the hospital's GME Office or equivalent. "Indirect costs" do not include the estimated cost of "indirect medical education." The cost amounts may be based on the Medicare Cost Report or another "more accurate" method that fully accounts for actual rather than "allowable" costs incurred. Indirect Medical Education revenue no longer is to be considered "direct offsetting revenue" to health professions education community benefit spending. Accordingly, there is no need to try to estimate Indirect Medical Education costs for purposes of Schedule H or for other community benefit reports.
Topic: Physician Time in Health Profession Education
Question: One of our physicians sits on the admissions committee of the local college of medicine. Can we report the expense of the physician's time as community benefit?
Recommendation: This expense may be reported as community benefit as long as that the physician's time is a cost borne by the hospital itself rather than by a practice plan or some other entity:
- Report in the category of health professions education if the activity meets the IRS definition of health professions education (for example, the physician serves as faculty). Review the instructions for the IRS Form 990, Schedule H for the types of costs that can be reported as health professions education.
- Report in the category of in-kind donation, if the activity does not meet the definition of health professions education.
However, consider keeping small costs off of the Schedule H.
Question: If scholarships include an agreement to 'work off' their scholarship at a particular hospital, can the scholarships be counted as community benefit?
Recommendation: The scholarships you describe seem to be designed to enhance the workforce at your organization. Therefore, we would not consider it community benefit and recommend not including the amount in the quantitative community benefit figures. You could report in the narrative section of your community benefit report how many scholarships you have given.
Topic: Time Working with Health Professions Students
Question: Should we count the time of nurses supervising or in other ways helping nursing students?
Recommendation: Hospitals can incur costs when nurses on the hospital's staff provide clinical supervision or other services for nursing students who are enrolled in an accredited education program. The teaching that occurs (e.g., didactic or classroom training) can pull nurses away from normal clinical duties, and lead to the need to increase staffing ratios. Include in the Category "Health Professions Education B2".
Question: Is there a recommended percentage of staff time spent mentoring students that can be reported as community benefit?
Recommendation: We recommend that, if possible, the organization should study what percentage of time staff spends away from their duties when mentoring students and use the findings to set a percentage. We recommend this approach because the percentage can vary based on type of hospital, hospital service (surgical vs. medical), and whether the student is clinical or non-clinical.
In any case, we do not recommend reporting more than 25% percent of a staff person's time if the person is mentoring a student. If an organization reports 100% of a staff person's time then it should justify this cost. Situations where 100% of staff time might be reported might include activities, such as classroom training, that take staff away from regularly scheduled activities.
Topic: Tuition Assistance
Question: If a hospital provides tuition reimbursement to students in return for a two- to three-year work commitment at the hospital and either the student leaves, not paying back the hospital for the tuition reimbursement, or if the hospital finds it does not need the graduate's service can the hospital count a portion of the tuition reimbursement as community benefit?
Recommendation: We recommend not counting tuition reimbursement or loan forgiveness when the original purpose was to recruit and retain professional staff members rather than to respond to a community need.