Why Public Health Professionals Should Care about Hospital Community Health Needs Assessment

Community Health planning is addressed by the public sector at the state and local level and by the private sector at the state, local, or hybrid level. These different approaches are outlined in the table below. State Health Assessments (SHAs) and State Health Improvement Plans (SHIPs) are under the purview of the state health departments. Community Health Assessments (CHAs) and Community Health Improvement Plans (CHIPs) are conducted by local public health departments at a local, typically county, level. Community Health Needs Assessments (CHNA) are the responsibility of hospitals.  A CHNA may be a geographic hybrid in that it must address the service area of the hospital. If the hospital is a stand-alone hospital, its CHNA is likely to be local; if it is part of a regional or statewide system, its CHNA is likely to cover a larger geographic area.

This guidance is written for state health departments under the assumption they will coordinate and collaborate with local health departments as appropriate.

Community health planning requirements for hospitals and health departments share a common goal: to collaborate and prioritize their communities’ most significant health needs and implement strategies to address those needs. Hospitals and health departments can work together to address community health needs.

Hospital requirements are driven by the Affordable Care Act (ACA), which stipulates that to be recognized as a 501(c)(3) organization and maintain federal tax-exempt status, hospitals are required to conduct a CHNA and adopt a CHNA implementation strategy every three years. The IRS regulations make it clear that hospitals must work with either state or local health departments (LHDs). Hospitals may coordinate their CHNA process with a government public health department if it has the same “community” definition as the hospital. The ACA CHNA requirement coincided with the launch of the national voluntary public health department accreditation process by the Public Health Accreditation Board (PHAB). The completion of a CHA and CHIP are prerequisites for LHD accreditation applications and must be completed to demonstrate fulfillment of public health accreditation standards. Community health assessment and CHNAs collect the same kind of data.

Although collaboration is permitted, public health departments must conduct CHAs every five years (if pursuing/maintaining accreditation), but the IRS requires a hospital CHNA every three years. While the different timing requirements make it difficult to use the same community health planning process, the requirement for public health input provides an important opportunity for public health agencies to:

• Build relationships with local hospitals
• Educate hospitals about overlapping areas of interest
• Leverage hospital resources to support public health initiatives
• Pool resources to conduct comprehensive community health assessments that benefit multiple stakeholders and the community-at-large

National Association of County and City Health Officials. Statement of Policy: Community Health Needs Assessment. December, 2005.