An Internal Revenue Service (“IRS”) official on October 4, 2011 said multiple hospitals in one community can work together when performing their community health needs assessments (CHNAs) as long as they develop individual final assessments and implementation plans for each facility.
One of the questions raised in the comments to the IRS’s notice of proposed rulemaking, Notice 2011-52, was whether hospitals working together on a CHNA must each identify separate needs within the community. The IRS official stated that the CHNA guidance requires tax-exempt hospitals to document the health needs of their community in a separate written report for each facility. But that is not the same thing as requiring that the reports to differ in their findings.
Tax-exempt hospitals beginning in 2012 are required to conduct a CHNAs once every three years for the community they serve, including getting input from people who represent the broad interests of the community. Following the completion of the CHNA, they must adopt an implementation strategy to meet the needs identified in the assessment.