Community benefits and schedule h: Needs assessment and what counts

“Community benefits” are health-related investments and activities, other than fully reimbursed medical care, that a hospital provides to its community. Community benefit obligations can arise in several legal contexts (e.g. condition of licensure, conversions, or health planning processes) but are most commonly associated with tax-exempt hospitals. Section 9007 of the Affordable Care Act (ACA) established new requirements and reporting standards nonprofit hospitals must satisfy for federal tax exemption. These provisions clarify and promote transparency of tax-exempt hospitals' efforts to meet federal community benefit responsibilities in four areas: community health needs assessment, financial assistance policies, limitations on hospital charges, and billing and debt collection requirements. The Internal Revenue Service has implemented the new requirements with guidance notices, a proposed rule, and through Schedule H (Form 990) and associated instructions. In Parts I and II of Schedule H, hospitals report their activities that benefit their communities. In Parts V and VI, they describe their required community health needs assessment, conducted to ensure that each hospital's community benefit initiatives are responsive to their communities' identified health needs and priorities. This presentation will address federal community health needs assessment requirements, financial assistance and other community benefits reportable in Part I of Schedule H, and activities that may be reported as “community health improvement services.” It will also address Schedule H's policy implications and its potential usefulness to public health decision-makers,practitioners, and policymakers.