Human Trafficking Education and Response

Question: We would like to confirm whether the following activities related to our Human Trafficking (HT) Education & Response Program should be counted as community benefit:

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    • Associate time spent learning about HT and receiving training on our HT response and assessment protocol
    • Associate time (not grant-funded) spent conducting these education/training activities
    • Expenses for any materials (not grant-funded) used for these education/training activities
    • Associate time spent conducting HT assessments w/ patients identified as potential victims and follow-up work w/ such patients (e.g., coordinating w/ shelters, referring to other resources, visiting inpatients w/ "Fresh Start" bags of donated items, etc.)

Should such activities be considered standard of care? Since the activities are focused primarily on our patients (although the benefits could extend to non-patients), would it be considered too limited/not community-based?

Recommendation: We recommend that the unreimbursed costs all of the activities you describe be reported as community benefit - community health improvement. The need for the activities, if not in your CHNA, can be determined by calls from federal and state governments and many non-governmental organizations asking health care organizations to educate their staff and to work in their communities to end modern day slavery.

 (March 2022)

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.