WASHINGTON — Two medical groups have asked the Internal Revenue Service to allow hospitals to be flexible when conducting the community health needs assessments required under the health care reform law.
The Association of American Medical Colleges and the New York Academy of Medicine both weighed in with separate letters on the new nonprofit hospital requirement, which was part of the Patient Protection and Affordable Care Act, in comment letters sent to the IRS.
Specifically, the law requires every nonprofit hospital to conduct a community health needs assessment every three years with broad input from the community and to report the findings on its Form 990, the annual information return that charitable organizations must submit to the IRS. Hospitals face a $50,000 excise tax if they fail to meet the requirement.
But Dr. Joanne Conray, chief health care officer of the Association of American Medical Colleges, told the IRS that hospitals should be allowed to determine the best way to gather community health information, define the scope of the assessment, and consider what type of expertise is needed to complete the studies.
The AAMC said the IRS should also accept as an assessment a written document developed by the hospital that describes the process used to collect the information and make the determinations, the community served and its health needs, how it included input from community members and public health experts, and its strategy to address the identified needs.
In addition, the group told the IRS it should recognize that a hospital could have legitimate reasons for not meeting certain health needs in the community. While the law states that hospitals must describe how they are addressing identified needs, a pediatric hospital or cancer center should not be expected to meet all of a community’s health needs, the AAMC’s letter said.
The IRS should clarify that a needs assessment will be considered “adopted” for tax purposes once it has been approved by a hospital organization’s governing body or committee, the group said.
The AAMC’s comments were dated July 21 but released publicly this week.
Meanwhile, Jo Ivey Boufford, president of the New York Academy of Medicine, said hospitals should be required or “explicitly encouraged” to conduct the assessments in partnership with local public health agencies and community partners. Hospitals are currently permitted to partner with these groups, she noted in her letter.
Boufford pointed out that public health agencies and community organizations typically have data and studies that would prove helpful in the assessment process and that information sharing would help prevent redundant data collection and planning. The NYAM’s comments were dated July 20.