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New Hospital Community Benefit Requirements: Who Will They Benefit? August 22, 2011

Posted by tomwolff in : Uncategorized , 1 comment so far

I was recently invited to present at a Centers for Disease Control and Prevention (CDC) meeting in Atlanta regarding new requirements in the recently passed Affordable Health Care Act and also in new IRS regulations concerning Hospital Community Benefits.

Yes, the IRS is regulating hospital community benefits!

Sounds boring? Think again. This is a real opportunity for communities to partner with local hospitals on key community issues.

What are Community Benefits? Non profit hospitals earn their non-profit status by demonstrating that they have met community health needs that have been determined by a community health needs assessment. This can be a meaningful community collaboration process or it can be window dressing. So, new regulations by HHS and the IRS are trying to ensure that the process has meaning.

A number of years back I was involved in a process of voluntary community benefit guidelines for hospitals and HMOs being piloted by then Massachusetts Attorney General Scott Harshbarger. Through the trials and tribulations of that process we all learned many lessons that can be brought to bear on this present effort. My role, as the founder of  Healthy Communities Massachusetts, in this earlier process was to organize the community side of the equation – local groups that mobilized to hold their community hospitals accountable.

What we discovered was that a few hospitals took the community benefits process seriously and did a great job of partnering with their local communities and developing effective, responsive and relevant community programs. However, most hospitals tried to do the minimum. Their Community Benefits Committees did not represent those most affected by the issues from the grassroots in their community but rather represented the “usual suspects” like local community non-profits, many of whom already held contracts with the hospital.

It was a major effort just to get many of the hospitals to submit their annual reports that described their required community assessments and their community benefit activities in the community. Most fascinating was that when we looked at the reports in many cases we saw almost no correlation between the community assessments and what the hospitals actually did. Their community needs assessment process may have determined that their community need was X and yet they provided Y because Y was more in tune with their mission and plan. Clearly this voluntary process needed more bite to be effective.

So fast forward to 2011, and we see potentially much the same scenario. At this excellent conference, we heard of outstanding examples of hospitals doing a great job of community benefits. I think of the work of Dory Escobar at St Joseph’s Health System in Sonoma County California. Dory is the Director of Healthy Communities and is a community organizer and her work represents those values. Her organizational framework has three areas: Advocacy Initiatives, Healthy Communities Programs and Community Health Programs. (See www.stjosephhealth.org).

We also heard of valuable tools from Julie Willems Van Dijk (U.Wisconsin) like a county system of health rankings. The Rankings are based on a model of population health that emphasizes the many factors that, if improved, can help make communities healthier places to live, learn, work and play. Building on the work of America’s Health Rankings the University of Wisconsin Population Health Institute has used this model to rank the health of Wisconsin counties every year since 2003. Rankings are now available for all counties in the country www.countyhealthranking.org.

Check it out for your county.

When I had my ten minute chance to present -(http://nnphi.org/CMSuploads/Panel%207%20-%20Wolff.pdf ) –

I urged hospitals to engage in true collaboration with those most affected by the issue in the community – with true collaboration described as relationships where we enhance the capacity of each other. I also suggested that community engagement go beyond the needs assessment stage of the process. Rather community partners need to share decision making throughout the community benefit process including setting priorities, implementation, and evaluation. I used the work of the Center for Health Equity and Social Justice at the Boston Public Health Commission as a model of this approach (see https://www.tomwolff.com/collaborative-solutions-newsletter-summer-10.htm).

So what happens from here on out?

These new regulations are an occasion for all of us to engage with our local hospitals. We must ask what they will be doing to meet these new requirements and tell them how we would like to partner with them in the process of creating their community needs assessment and then continue to work with them on the implementation of their community benefit programs that will meet the identified needs.

My good colleagues at the Community Tool Box (http://ctb.ku.edu) at the University of Kansas have been contracted by the CDC to develop “Recommended Practices for Enhancing Community Health Improvement”. This will be a very comprehensive tool kit based on the wonderful resources of the Community Tool Box for the community needs assessment process.  I will try to keep you informed as to when these resources will go public.

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