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CASE STUDY:

Background. Historically, hospitals developed near-term and long-range strategies as a free- standing exercise - focused on what was best for the facility. The board and c-suite staff went to lush retreats for a three-day planning event. The statistical budget was a key starting point because it was used to project revenue trends - all based on what the participants felt would well-position the hospital and sustain its standing as the "healthcare provider of choice in the area". The organization's not-for-profit (NFP) status presumed that the scope of services was aligned with the health needs of the service area - albeit void of supporting evidence. This community care assumption was anchored in Section 501(c)(3) of the IRS Code that exempted organizations from income tax requirements because they "operated exclusively for religious, charitable, scientific, or educational purposes". Thus, Catholic hospitals were exempt as religious organizations. Secular hospitals were tax exempt because of the charitable assumption. It was assumed that a religious and charitable health facility ipso facto benefited the community it served. The landmark Darling v. Charleston (1965) case challenged hospital's charitable immunity standing. This was followed in 1969 an enhanced community benefit standard requiring the elements that we reviewed in the Community Benefit Assignment. With passage of the Patient Protection & Affordable Care Act (1950), Section 501(r)(3) of the IRS Code required NVP hospitals "to conduct a Community Health Needs Assessment (CHNA) every three years and adopt an implementation strategy to mee the community health needs identified through the CHNA" (Community Health Needs Assessment for Charitable Hospitals, 2013). The following table is an overview of the IRS requirements for a CHNA1. Requirement General Definition Defining the Community Served Include the relevant facts and circumstances in defining the community it serves. This includes: a) The geographic area served by the hospital facility, b) Target populations served, such as children, women, or the aged, and c) Principal functions, such as a focus on a particular specialty area or targeted disease. Assessing Community Health Needs A hospital facility must identify the significant health needs of the community. It must also prioritize those health needs, as well as identify resources potentially available to address them. Resources can include organizations, facilities, and programs in the community, including those of the hospital facility, potentially available to address those health needs. Input Representing the Broad Interests of the Community A hospital must both solicit and take into account input received from all of the following sources in identifying and prioritizing significant health needs and in identifying resources potentially available to address those health needs: a) At least one state, local, tribal, or regional governmental public health department (or equivalent department or agency), or a State Office of Rural Health described in Section 338J of the Public Health Services Act, with knowledge, information, or expertise relevant to the health needs of the community. b) Members of medically underserved, low- income, and minority populations in the community served by the hospital facility, or individuals or organizations serving or 2 representing the interests of these populations. c) Written comments received on the hospital facility's most recently conducted CHNA and most recently adopted implementation strategy. Additional Sources of Input In addition to soliciting input from the three required sources, a hospital facility may solicit and consider input received from a broad range of persons located in or serving its community. This includes, but not limited to: Health care consumers and consumer advocates Nonprofit and community-based organizations Academic experts Local government officials Local school districts Health care providers and community health centers Health insurance and managed care organizations, Private businesses, and Labor and workforce representatives. Documentation of CHNA A hospital facility must document its CHNA in a report that is adopted by an authorized body of the hospital facility. The CHNA report must include the following items: a) a definition of the community served by the hospital facility and a description of how the community was determined. b) A description of the process and methods used to conduct the CHNA. c) A description of how the hospital facility solicited and considered input received from persons who represent the broad interests of the community it serves. d) A prioritized description of the significant health needs of the community identified through the CHNA. This includes a description of the process and criteria used in identifying certain health needs as significant and prioritizing those significant health needs. e) A description of resources potentially available to address the significant health needs identified through the CHNA. f) An evaluation of the impact of any actions that were taken to address the significant health needs identified in the immediately preceding CHNA, CHNA Report: Widely Available A hospital facility must make its CHNA report widely available to the public. This must be done by making the CHNA report widely available on a Web site and by making a paper copy of the CHNA report available for public inspection upon request and without charge at the hospital facility. Prior CHNA reports must remain widely available to the public, both on a Web site and in paper, until the hospital facility has made two subsequent CHNA reports widely available to the public. Implementation Strategy A hospital facility's implementation strategy must be a written plan that, for each significant health need identified, either: a) Describes how the hospital facility plans to address the health need, or b) Identifies the health need as one the hospital facility does not intend to address and explains why it does not intend to address the health need. 3 Although an implementation strategy must consider all the significant health needs identified through a hospital facility's CHNA, the implementation strategy is not limited to considering only those health needs and may describe activities to address health needs that the hospital facility identifies in other ways. It is clear from the requirements in the table that assessing and addressing a community's priority health needs is a driver of hospital strategy and operating plans, especially since a $50,000 is leveled for non-compliance. Also, as a driver of strategy and planning, the CHNA is linked to community benefit determination and the organization's budgeted operating expenses. Assignment. This assignment is a two-fold exercise focused on Marion General's posted CHNA. Step 1 involves reviewing the hospitals CHNA - doing so by keeping the requirements in mind in the process. The overarching question is "Has MGH conducted detailed CHNA?". As a second step, we will review the CHNA posted by our local hospital, SouthEast Health, using it as a type of benchmark. These two steps will enable us to discuss comparative strengths and weaknesses of these two appro aches to the CHNA IRS requirement.

2. Identify the Strengths and Weaknesses in SouthEast Health's posted CNHA.