Community Health Needs Assessment

Question:  As the experts on community needs assessments, under the IRS rules, each hospital has to complete a community needs assessment. However, are there times when a group in a given community could do one needs assessment and develop a hospital-specific plan to address community needs? Or does the state conduct a statewide health needs assessment, and the hospital uses that as their needs assessment and then develops a plan to address what the state has identified?

Recommendation:  Hospitals in meeting IRC Section 501(r)(3) may conduct joint community health needs assessments (CHNA). “A hospital facility is permitted to conduct its CHNA in collaboration with other organizations and facilities. This includes related and unrelated hospital organizations and facilities, for-profit and government hospitals, governmental departments, and nonprofit organizations.”

We encourage and see many hospitals collaboratively conducting their CHNAs. This coordination has increased alignment across local hospitals, government, community-based organizations, and communities in identifying significant health needs and improved coordination in addressing needs through implementation plans. The IRC Section 501(r)(3) has specific requirements related to jointly conducted CHNAs and Implementation Strategies (IS).

  • We do not recommend that a hospital adopt a CHNA as their own that they did not participate in.
  • We recommend that prior assessments and assessments conducted by other organizations be used as data sources when conducting CHNAs.

We encourage hospitals to collaborate with local and state organizations in addressing their communities’ needs. There are many opportunities for state-wide alignment in understanding community health needs and implementation strategies..

(November 2023)

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.