IRS Final Rules for Tax-Exempt Hospitals: The Work Ahead
2015 is shaping up to be a pivotal year for non-profit hospital community benefit. Since the IRS final rules came out in December 2014, the Hospital Accountability Project (HAP) team has been closely tracking developments in the non-profit hospital sector and in communities across the nation to understand the activity generated by the final rules. Things are moving quickly in communities across the nation, and we continue to track and share information. While the questions and needs vary across communities, we are seeing some trends in the conversation.
Community Benefit and CHNAs
It seems like everyone wants to know about “best practices” for meaningful engagement in Community Health Needs Assessments (CHNAs). As we continue working to create new tools and resources to support you in your efforts to create your own best practices, we’ve put together materials, that outline some basic facts and terms about community engagement.
We are also working with some of our partners to understand what happened during the first round of CHNAs in 2012 and 2013 and what you think should be done differently in the next round of 2015 and 2016 CHNAs .
Much attention is being paid to the role of about hospitals in population health including the obstacles and opportunities, especially as payment systems around the nation change from quantity to quality. This fact sheet will give you some information and key questions to think about as you plan to partner with your local hospital. We are also creating additional tools and resources to help our community partners build relationships with their local non-profit hospitals, as hospitals transition to the final rules this year.
A common point of confusion with engaging non-profit hospitals is determining which decision-maker at the hospital should be contacted about these issues. We saw that issue arise first-hand during our pilot site work last year, as well as in some of our other national work. Even once that person is identified, additional questions arise about how to prepare for those meetings. Finding common language and bridging cultures can be challenging for both the hospital and the community, as community members struggle to find the resources necessary to engage in community benefit work and as hospital staff navigate institutional barriers and begin to appreciate the benefits of these partnerships. As a downpayment toward addressing those challenges, this fact sheet may help you understand the opportunities for and benefits of engagement. Our pilot site work over the coming months will help to develop some tools and resources that will help with those challenges.
Financial Assistance Policies (FAPs) and Billing and Collections
Medical debt and financial assistance are being heavily covered by the media of late, and we know that many are concerned about it in their locale. We frequently receive questions about the overlap (or lack thereof) of state financial assistance laws and the federal rules specific to these issue areas. Our partners at the Hilltop Institute have a great interactive state comparison table that can help you find out what your state community benefit laws are and compare yours to other states.
Our community partners often tell us that hospitals aren’t really paying attention or changing their behavior related to financial assistance/charity care, as there are still numerous loopholes in the final rules in this area. As hospitals spend 2015 getting their FAPs in order, we are tracking what we’re hearing and will be delving more deeply into this. We encourage you to help us monitor what is happening in your community and we would love to reach out to some of you to take part in efforts to develop some tools and resources that will help encourage hospitals to follow the spirit of the law.
Next Steps
We continue to monitor, track and plan how we can help community groups and hospitals work better together. We will host additional learning community calls/webinars and develop resources to will help you make change with your local hospital. If you have not done so already, please sign up for our email list (and be sure to indicate you are interested in Free Care & Community Benefits) so that you don’t miss out on these opportunities.
Hospital community benefit promises a lot of change in the near future, and it is important that opportunities are leveraged to improve your community’s health. Be sure to check out our community benefit resources and learn more about the Hospital Accountability Project by visiting our webpage.