As part of the CHNA requirement, hospitals must document the findings in a written report. This checklist contains the six required elements1 that must be included in the report and tips for avoiding trouble spots.
1. Define the community served, and describe how the community served was determined.
While defining the community served is a straightforward requirement, hospitals often overlook the section of the report where they must describe how they determined the community to be served. Hospitals typically determine their community served by reviewing data such as:
- Demographics, including age, ethnicity, and socioeconomic status
- ZIP codes in their service area
- Discharge data
- Community trends
Reminder: Documenting how the defined community was determined is just as important as defining the community served.
2. Describe the process and methods used to conduct the CHNA.
Hospitals are required to describe all types of data and information used in the assessment and all methods used to collect and analyze that data and information. Common methods used to collect data include:
- Focus groups
- Interviews with key stakeholders
- Other primary and secondary sources
Reminder: In the report, don’t forget to include parties with whom the hospital collaborated or contracted for assistance in conducting the CHNA.
3. Describe how the hospital solicited and took into account input from persons who represent the broad interests of the community served.
The IRS designed this area of the report to help hospitals better understand the needs of the low-income, minority, and medically underserved populations in their community. Hospitals are required to specify not only the origin of the information obtained and the population it represents but also how the input was obtained, including the nature and extent of the input.
Consider a hospital that operates in a community with a significant Hispanic population. The CHNA report should specify what steps the hospital took to obtain input from members of that population or organizations or individuals who serve that population. For example, did the hospital reach out to a community center or other community organizations that specifically serve the needs of the Hispanic community? And, in doing so, what did the hospital learn about the specific health needs of that population?
Reminder: Be sure to accurately describe the process used by the hospital to gather information from various community groups rather than simply listing the fact that it reached out to those groups.
4. Include a prioritized description of the community’s significant health needs, and describe how the hospital prioritized those health needs.
Examples of some of the significant health needs outlined on many hospitals’ CHNA reports include obesity, diabetes, access to care, and transportation. Often, the CHNA report itself includes little discussion about how the health needs were prioritized.
In the report, hospitals are required to describe the methods used and factors considered to prioritize the community’s significant health needs. This may be accomplished via a scientific method or through discussion among leadership and other hospital stakeholders (or with the help of a third-party consultant) about various relevant factors, including the severity of the health need, the urgency of the health need, and the importance the community places on addressing the health need.
Reminder: Although hospital leaders and staff have the flexibility to choose how best to prioritize the significant health needs of their own community, they have to be transparent in that process by clearly describing it in the CHNA report.
5. Describe the resources potentially available to address the significant health needs identified.
In this section of the CHNA report, hospitals must identify and describe existing healthcare facilities and resources that are available to meet the health needs of their community. The intention behind this section of the report is to encourage hospitals to be mindful of the service offerings in their area. Completing this section helps them determine if they can fulfill a need in the community that isn’t already being addressed by the organization itself or by another organization, while avoiding duplicating services in the community.
For example, if a hospital identifies cancer as one of the top health needs in the community served, but a neighboring organization recently has built a new cancer center, the hospital likely would not want to build another cancer center if that would be a duplication of services that already are available.
Reminder: Completing this section of the report serves a dual purpose for hospitals, as it could spark ideas for new service lines and guide business decisions that best harness existing resources already offered in the community.
6. Evaluate the impact of any actions that the hospital took since its last CHNA.
Because many hospitals are on only their second CHNA report cycle, this section of the report is somewhat new. As they complete a CHNA every three years, hospitals must look back at previous reports and evaluate the top health needs listed, what actions they took to address those needs, and whether the actions made an impact.
A best practice is to make sure the actions taken to address community health needs are measurable. For example, rather than listing that the hospital is going to “reduce cancer in the community,” it might commit to “conducting 50 percent more cancer screenings than in the previous period,” which is a more measurable goal.
Reminder: When listing community health needs and how the hospital will address them, set up a measurable metric so the organization can successfully evaluate whether any actions taken since the last CHNA have made an impact on the community.
As hospitals fall into the rhythm of completing community health needs assessments every three years to comply with Section 501(r), it’s a good practice to continually review the required elements that must be included in a CHNA report. Hospital management and staff from across the organization must work together – with each other and with consultants the organization hires to complete a CHNA – when drafting reports to confirm that the information they contain is accurate and consistent with federal reporting requirements.
1 Federal Register, Vol. 79, No. 250, Dec. 31, 2014, pp. 78966 and 79002, https://www.gpo.gov/fdsys/pkg/FR-2014-12-31/pdf/2014-30525.pdf