Community Benefit

Nurse Navigators

Please Take Note: The information provided 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.

Question:  Should we report our Emergency Department Navigator program? The ED Navigator meets with patients after medical screening to help them obtain a regular source of primary care. The goal of the program is to assist the low-income, medically indigent population in obtaining and using a Primary Care Provider (PCP) for primary care, and not the ED. The Navigator will identify any barriers patients may have had which prevented them from accessing services with a PCP and assist them in making their follow-up appointment with a PCP. "Primary and Preventive Health Care Services" were identified as a priority in our needs assessment.

Recommendation: We recommend reporting the ED Navigator program as community benefit (A3, Community Health Improvement/Health Care Support Services) if the primary purpose of the program is to provide or improve access to needed services and/or to improve the health of low-income persons, so long as other criteria for community benefit are met. (See Chapter 2, A Guide for Planning and Reporting Community Benefit, for example, do not report the activity if it benefits the organization more than the community or if the primary purpose is to prevent readmissions to avoid penalties).

Do not report as community benefit if the purpose is to send referrals to the hospital organization's primary care physicians or if referrals are made only to the organization's physicians - unless they are the only physicians in the community. 

Take care not to double count, that is, assure that the program cost is not already reported as financial assistance (charity care), Medicaid shortfall, or as part of a subsidized health service.  If the programs or services are subject to a financial assistance policy, they should not be separately reported.

Navigator programs that are offered in the ED and other service areas that are offered to all patients are considered a part of routine care and should not be reported as community benefit.

(November 2015)


Question: We have a cancer nurse navigator program in which patients are identified from community screenings and testing at the health care organization. Some patients, but not all, are low-income, uninsured and have no physician. Nurses help these cancer patients find community resources as well as clinical resources. The navigator program does not refer exclusively to the organization's physicians and services. Cancer was identified as a community health need in our community health needs assessment.

Recommendation: We recommend that this program be reported as community benefit in Category A3. Health Care Support Services, because it addresses a community health need and is open to the broader community. It serves a population beyond the hospital's patient population. We also considered whether such a program could be reported if it was conducted by a sole community hospital where all cancer patients were patients of the hospital or can only be referred to the hospital's physicians because it is a sole provider. In this situation we recommend that costs of the program could be reported as community benefit if the program activities were beyond expected or standard discharge planning.

(November 2013)