Deadlines and Guidance for Community Health Needs Assessment Completion

July 24, 2012
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The Affordable Care Act (ACA), enacted March 23, 2010, added new requirements that hospital organizations must satisfy in order to qualify for exemption under Section 501(c)(3), as well as new reporting and excise taxes.  Hospital organizations with 501(c)(3) status are required to meet the following four requirements:
  • Adopt and implement written financial assistance and emergency medical care policies [501(r)(4)],
  • Limit charges for emergency or other medically necessary care [501(r)(5)],
  • Comply with new billing and collection restrictions [501(r)(6)], and
  • Conduct a community health needs assessment at least once every three years [501(r)(3)].  (This requirement is effective for tax years beginning after March 23, 2012.)
With the first community health needs assessments (CHNA) due in under one year for some organizations, planning should begin immediately.  With that in mind, there are some important notes that organizations should be aware of regarding compliance with the current guidelines.
IRS Notice 2011-52 addresses the CHNA requirements described in Section 501(r)(3) of the code.  While comments were requested regarding these new guidelines, there have not yet been any changes or updates to the existing guidelines.  Please note that if further guidance is issued from the IRS either after or during an organization’s current CHNA process, that organization would be given a window of six months to complete the assessment under the current guidelines, after which the organization would be required to comply with the updated IRS guidelines.
Wipfli can help you maintain compliance by guiding you through the process of conducting the CHNA.
On June 26, 2012, the IRS published proposed regulations covering the above-listed 501(r)(4) through 501(r)(6) requirements.  An upcoming Wipfli alert will be issued to cover these requirements.  
For more information on these requirements and how to comply, please contact Nicholas Smith at or your Wipfli relationship executive.

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