AHA, AAMC, and CHA want the IRS to extend the community health needs assessment deadline because of diverted resources during COVID-19 outbreaks.
The American Hospital Association, the Association of American Medical Colleges, and Catholic Health Association are calling on the Secretary of Treasury and the IRS to provide an extension to allow non-profit hospitals across the country to complete their community health needs assessments (CHNAs).
The CHNA is a survey of a hospital’s community that outlines the specific health and social needs that could have an overarching impact on community health. Healthcare organizations that claim non-profit status are required to complete a CHNA every three years in order to maintain that non-profit status. This year’s deadline for the CHNA is July 15.
However, the COVID-19 pandemic threw a wrench in that timeline, AHA, AAMC, and CHA asserted in a letter to Steven Mnuchin, Treasury Secretary, and Charles Rettig, the commissioner for the Internal Revenue Services (IRS).
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“Hospitals and health systems are deeply committed to improving the health and well-being of their community,” AHA, AAMC, and CHA wrote. “However, during these extraordinary times, COVID-19 is limiting the ability of hospitals to seek input from their communities, requiring the full attention of public health authorities and personnel, and affecting the priorities and attention of hospital boards.”
Completing a CHNA is a labor-intensive pursuit, one that requires collaboration between the hospital, community leaders, and individual members of the community itself. In order to glean accurate data for a CHNA, a hospital will often partner with a large community-based organization, like a civic center, to help connect the hospital with individual community members who can then help inform the CHNA.
Completing a CHNA also requires the help of public health officials.
What’s more, this task must be done within a short time frame in order to generate accurate and actionable results, AHA, AAMC, and CHA noted. For this year’s deadline, a hospital will have had to have started the CHNA process no earlier than April 1 with, again, a July 15 deadline.
This simply has not been feasible during the current medical climate, AHA, AAMC, and CHA said. The outbreak of the novel coronavirus has demanded hospital, community health, and public health resources that otherwise would have gone toward completing the CHNA.
“The limitations of the pandemic (e.g., limited public gatherings, stay at home orders) and the immense pressure on hospitals to focus intently on delivering COVID-19 testing and care to their communities prevent hospitals from soliciting the necessary input from the public, underserved communities (who are often experiencing the greatest burden from COVID-19), and public health authorities and from taking the time to compile the written report and present it to the board,” the signatories asserted.
Not completing the CHNA to IRS standards comes with a hefty price. AHA, AAMC, and CHA cited the $50,000 penalty tax that cannot be abated, but in the past the IRS has stripped healthcare organizations of their non-profit status due to failure to submit a CHNA, although this measure has been used extremely sparingly.
In 2017, the IRS revoked tax-exempt status from an unnamed, small rural hospital because it failed to conduct a CHNA, create a community health implementation plan, and make the assessment publicly available. However, this occurrence is exceptionally rare. In fact, it was broadly regarded as an IRS-first.
AHA, AAMC, and CHA are calling on the Treasury Department and IRS to provide an extension for any CHNA that was required to be conducted after April 1, 2020 until April 1, 2021, or for any CHNA that was required to be conducted six months after the national public health emergency has expired.
For example, HHS has extended the national public health emergency 90 days past its previous expiration date of July 25, 2020, meaning the emergency may expire in October. That would mean the signatories are requesting the Treasury Department and IRS to extend CHNA deadlines for any hospital slated to complete one up until April 30, 2021.
Such an extension would not only ensure a hospital was not completing a CHNA while presently managing an acute COVID-19 outbreak in its geographic region, but also allow it a period of recovery before allocating resources toward the CHNA, AHA, AAMC, and CHA said.
“During these extraordinary times, COVID-19 is limiting the ability of hospitals to seek input from their communities, requiring the full attention of public health authorities and personnel, and affecting the priorities and attention of hospital boards,” the signatories said.
Source: Patient Engagement Hit