Wednesday, March 15, 2023
Wyland With More Insight on Community Health Needs Assessments
Michael provided us with some good information in response to our post this week about Wellstar and Community Health Needs Assessments:
"I wrote about two hospitals voluntarily giving up tax exemption as a consequence of the ACA's CHNA requirement. One article is here and the other here. In both cases, the hospitals enjoyed exemption two ways - as a governmental entity and as a 501(c)(3). I remind my clients that the CHNA requirement is virtually unique in nonprofit hospital federal regulation. First, the regulator is the IRS, not HHS. The reason? The CHNA is designed to evaluate how charitable your hospital is; it's not designed to evaluate how good a hospital you are. This often brings hospital leaders, both board members and executives, up short. The real tragedy of CHNAs is that very few hospitals administer them as Sen. Grassley intended. Rather than asking the community what it needs and influencing the nonprofit hospital to provide it, the CHNA has become a marketing exercise for the nonprofit hospital to promote its own community health initiatives. Meanwhile, the CDC would love to get into the act of evaluating and influencing regulation of nonprofit hospitals using CHNAs. I had one CDC staffer tell me, for example, that (in his opinion) every CHNA should have a smoking cessation goal in its action plan. Otherwise, it's deficient and insufficient. Yes, but aren't the CHNA's action plan priorities each nonprofit hospital's decision based on its communities' expressed health priorities? For more about this than you ever wished to know, see: Avoiding Misconceptions in Filing Community Health Needs Assessments.
darryll jones
https://lawprofessors.typepad.com/nonprofit/2023/03/wyland-with-more-insight-on-community-health-needs-assessments.html
Oops! The hyperlink in the last sentence of the post goes to the wrong article. The correct link is: https://nonprofitquarterly.org/avoiding-misconceptions-in-filing-community-health-needs-assessments/
Posted by: Michael L. Wyland | Mar 16, 2023 9:41:24 AM