By Atyya Chaudhry
Senior Program Manager
Health Reform Implementation, AMCHP
Keeping communities healthy and strong is one goal of the Patient Protection and Affordable Care Act (ACA). The various reforms and provisions – such as increasing access to affordable healthcare, expanding home visiting programs and providing support for breastfeeding – collectively work to improve the health and well-being of the individuals and families that form communities.
One ACA provision focused on community engagement is the requirement for 501(c)(3) nonprofit hospital organizations to conduct community health needs assessments in order to maintain their tax-exempt status. This provision requires nonprofit hospitals to partner with public and community health programs to conduct community health needs assessments (CHNA) and develop strategies to address the identified needs. This provision enhances community engagement and community collaborations to make health improvements.
The CHNA is completed every three years. Nonprofit hospitals are required to document their CHNA process in a report, which must contain the following information:1
Definition of a community. Hospitals have the flexibility to define their communities. The definition is not permitted to purposefully exclude minorities, low-income and medically underserved populations.
Assessment of community needs. Hospitals are required to assess and prioritize the health needs of the community. Hospitals have flexibility in applying criteria to assess and prioritize these needs and are required to take community input into account in prioritizing those needs.
Broad representation of community interests. Hospitals are required to solicit input from the following:
- Individuals with expert knowledge in public health
- Federal, state, local, tribal or regional health departments or agencies with knowledge/expertise in health needs of the community
- Leaders, members or representatives of medically underserved, low-income and minority populations in the community
Proper documentation of the CHNA. Aside from the elements above, the report must include:
- An explanation of the how the community was determined
- A description of the methodology used to conduct CHNA
- A description of how the broad interests of the community were taken into account
- A prioritized description of community health needs and the criteria applied to determine the significance of the needs
- A description of resources to potentially address the needs identified through CHNA
Collaboration on reports. A hospital facility is allowed to conduct a CHNA in collaboration with other organizations, which can include public health or other departments at the state or local level. A facility that collaborates with a governmental public health department in conducting the CHNA may produce a joint CHNA report.
Public availability of CHNA report. A hospital facility must post the report on the facility’s or hospital organization’s website.
In addition, a hospital facility is required to identify an implementation strategy for each significant health need identified in the CHNA. The implementation strategy must:
• Describe how the facility will address the significant health need, potential impact of the actions and evaluation of the impact. Hospital facilities are permitted to collaborate with other organizations on implementation strategies.
• Identify the health needs that the hospital does not aim to address and explain why.
The CHNA process is a clear example of the ACA’s commitment to improving healthcare starting with the community. Given the flexibility of the CHNA process and the requirement to engage health officials, there is an opportunity for collaboration and coordination with Title V programs in the needs assessment and implementation strategies. An example of how a Title V program in Kansas engaged with this process can be found here.