Community Benefit

Changing Target Populations of Current Community Benefit Programs

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: "At this time, my hospital is considering changing the target populations of current CB programs from the community at-large to the Accountable Care Organization (ACO) and medical groups. As we explore these ideas, I would like to know any negative outcomes for our community benefit programs and their financial impacts."

Recommendation: We do not recommend that a hospital define its population, for community benefit purposes, as persons served by its ACO because the ACO may exclude persons who are uninsured. IRS proposed rules for community health needs assessments prohibits defining the community in a way that excludes vulnerable populations.

(June 2014)