Question: Our hospitals are screening in-patients for tobacco use and offering a consultation for stopping tobacco use, during the hospital stay. This is not part of the typical inpatient care but is over and above the standard of care. It is not a required service, is not included in the cost of care and it is not reimbursed. It is related to a public health issue and would address the community health need of tobacco use.
Recommendation: We recommend this should count as a community health improvement service for Form 990 Schedule H purposes, assuming that cessation of tobacco use has been identified as a community health need (e.g., through a CHNA, by a public health agency, by a community group). For Schedule H purposes, a service provided to a patient during the patient's hospital stay may qualify as a community health improvement service, so long as it's meeting an identified community need and the hospital does not generate any inpatient or outpatient revenue from that service. So it would be important to clearly distinguish this service, in the hospital's books and records and in its communications with patients, from services the patient is paying for and/or the hospital is being reimbursed for.
Please keep in mind that the IRS instructions for reporting community health improvement services on the Schedule H say that the primary purpose of reported activities should be to address a community need, so to report any expenses, the primary purpose of the website should be to provide health information. This is a high standard.
(September 2021)