CHNA: Community Health Needs Assessment Rules

A Community Health Needs Assessment (CHNA) is the assessment of community health needs that 501(c)(3) hospitals must complete at least every three years (IRS). The rule is Internal Revenue Code section 501(r)(3), and it applies to each hospital facility separately. Each facility must also adopt a written implementation strategy for the significant needs it identifies.

Who must do one

Section 501(r) applies to 501(c)(3) organizations that operate one or more hospital facilities (IRS). A hospital facility is one that a state requires to be licensed, registered or similarly recognized as a hospital.

A hospital organization that fails the CHNA requirement owes a $50,000 excise tax for that taxable year (26 U.S.C. 4959). Hospital organizations report on their facilities on Form 990, Schedule H (IRS).

Core contents of the CHNA report

The written report must include (IRS):

1. A definition of the community served and how it was determined.
2. The process and methods used.
3. How input from people representing the community's broad interests was taken into account.
4. The prioritized significant health needs.
5. Resources potentially available to address those needs.
6. An evaluation of the impact of actions taken since the prior CHNA.

Input must come from at least one state, local, tribal or regional governmental public health department (IRS). It must also come from members of medically underserved, low-income and minority populations, or groups representing them. The facility must also consider written comments on its most recent CHNA and implementation strategy (IRS).

An authorized body of the facility must adopt the report (IRS). It must stay on a public website until two later CHNA reports are posted (26 CFR 1.501(r)-3).

Defining the community

A facility may define its community by geography, target populations and principal functions (26 CFR 1.501(r)-3). It may not exclude medically underserved, low-income or minority residents of the areas it draws patients from. The exception is groups outside its target populations and not affected by its principal functions.

Medically underserved populations include people at risk of inadequate care. Causes include being uninsured or underinsured, and geographic, language, financial or other barriers (26 CFR 1.501(r)-3).

CHNA vs community health assessment (CHA)

Sources: IRS; CDC; CDC drivers. CDC notes that CHIPs are typically updated every three to five years.

Using access-gap data in a CHNA

1. Define the community on a map with ZCTAs, tracts or counties, and document how you chose them.
2. Show where medically underserved residents live, including those facing geographic barriers such as long drive times.
3. Add HPSA and MUA/P designations as evidence of provider shortages.
4. Record each data source and its limits, such as ACS margins of error.
5. Consider a joint report with the local health department; the rules allow one when all partners define the community the same way.

GeoChat AI is a free mapping platform that lists community health needs assessments among its use cases. See the CHNA access-gap mapping guide for a full workflow.