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Frequently Asked Questions
Does the 990H provide a complete picture of hospital community benefit contributions?
The 990H does not provide a complete picture of how tax-exempt hospitals fulfill their charitable obligations. Hospitals may undertake other activities and/or make resource allocations that are not captured in their 990H reporting, due to no oversight in documentation, an internal decision not to report the activity(ies), and/or a judgement that the total of expenditures currently reported meet expected financial thresholds aligned with tax-exempt obligations, and additional documentation is unnecessary. There are, for example, a growing number of hospitals and health systems which allocate a portion of their investment portfolio in the form of low (1-2%) or no interest loans to support community development investments such as affordable housing, grocery stores, and small business development in low income communities. They do not report these important contributions to build health and well-being in their communities as part of their 990H documentation.
The Community Benefit Insight (CBI) tool should be viewed as a starting point for thoughtful inquiry and engagement of nonprofit hospitals into how to support the optimal allocation of charitable resources to improve health and well-being in local communities. Inquiries should also be conducted with the contributions of both public and private sector stakeholders in the health, social services, and community development arenas, with a focus on alignment of resources in communities where health inequities are concentrated.
The hospital I'm interested in is part of a health system. What does that mean for its community benefit reporting?
Oftentimes, a hospital belonging to a multi-facility system will report to the IRS as part of a group, filing their 990 with other hospitals in the system. Depending on how geographically expansive the system, they may even report within subgroups based on proximity or prior system affiliations. It is important to note when hospitals report in aggregate, the figures do not reflect particular community benefit activities for that specific hospital.
How can I learn more about what is being done with community benefit resources for a particular hospital?
Tax-exempt hospitals are required to perform a Community Health Needs Assessment (CHNA) at least once every three years. They must then adopt an Implementation Strategy to meet the community health needs identified in the CHNA by the end of the taxable year in which the CHNA was conducted.
In general, the CHNA must: include the process and methods used to conduct the CHNA, define their community served, assess community health needs, include input from persons who represent the broad interest of the community served, and be made widely available to the public.
In general, the Implementation Strategy must: describe how the hospital plans to address a significant health need and describe why the hospital is not addressing a significant health need.