ACA Preparedness: How to Conduct a Community Health Needs Assessment
Non-profit hospitals have to do it every three years to comply with the requirements of the federal Patient Protection and Affordable Care Act (ACA), but probably any hospital or clinic would benefit by conducting a Community Health Needs Assessment (CHNA).
That’s the verdict of Community Hospital Consulting (CHC), a Plano, Texas-based firm. Its presentation, Meeting New ACA Requirements for Conducting a Community Health Needs Assessment - Your CHNA Toolkit, on June 19 at the meeting of the Healthcare Financial Management Association in Orlando, Florida, outlines the background of the assessment procedure, the attendant regulations (as they currently stand), and examples of what a CHNA looks like in practice.
According to Cindy Matthews, CHC executive vice president for strategy, the new requirements for non-profit hospitals are as follows:
• Conduct a CHNA every three years• Establish written financial assistance and emergency medical care policies
• Limit amounts charged for emergency or other medically necessary care to individuals eligible for assistance under the hospital's financial assistance policy
• Make reasonable efforts to determine whether an individual is eligible for financial assistance before engaging in extraordinary collection actions against the individual
Of these, the CHNA is probably the most complex—and the most applicable to medical care facilities other than non-profit hospitals, Matthews says. She and David Domingue, FACHE, the company’s vice president of business development, have recently presented the CHNA toolkit to various groups, and to potential clients. A modified version is available on the company’s website, www.communityhospitalcorp.com. “We feel that a CHNA is a great thing to do no matter what kind of hospital is involved, but the ACA has made it a requirement for non-profit hospitals, every three years,” Matthews says. “The presentation talks about those regulations and how the IRS looks at a non-profit hospital’s compliance with them.” A Six-step Process Matthews explains that while the ACA was passed in March 2010, the CHNA regulations were only published this past April and are still in a review period to be completed in October. “There might be minor modifications based on public comment, but I imagine that they’ll stay pretty consistent,” Matthews adds. “The IRS came out a year before with some guidelines, and based on public comments based on those guidelines, the regulations were adjusted slightly.” A typical CHNA entails a six-step process, Matthews says. The sequence is to: • establish parameters and scope of the market served
• collect and analyze data
• obtain community input
• document and communicate results
• prioritize community needs in an implementation strategy, and
• develop objectives, action plans, and metrics.
Scope, Data, Input For some hospitals, the parameters and scope could include a specific target population, or a specific function served. Data to be collected might include the demographics of the study area, population growth, economic factors, health status of the study area, and the most common diseases of the area. Community input could come from state, local, tribal, or regional governmental public health departments, as well as members of the medically underserved community, or individuals or organizations serving or representing the interests of those populations. The hospital also might consult major employers, insurance companies, other health-related entities, local schools, and minority/low income organizations. Documentation would include methodology, description of collaboration with other organizations, area demographics, health status of the study area, descriptions of other health services available in the community, and any information gaps. This process allows a hospital to prioritize community needs, Matthews says, based on depth and breadth of those needs, the availability of other resources in the community, and the hospital’s abilities to meet those needs. A Written Plan The next step is to adopt an implementation strategy: a written plan that addresses each of the significant community health needs identified. The hospital should describe its plans to meet those needs, or identify needs that the hospital doesn’t intend to meet. The implementation strategy must be tailored to the hospital’s specific programs, resources, and priorities. Then, the hospital should develop objectives, action plans, and metrics for each objective, as well as an annual budget for its activities. These items are not required as part of the CHNA process as defined by the IRS, but Matthews feels they add value and assist in accountability. In addition, a non-profit hospital must publish the CHNA on its website and make paper copies available, and must have an ongoing feedback mechanism in place. Community Hospital Consulting cites a CHNA performed on behalf of Baptist Hospitals of Southeast Texas as an example of what such a study looks like in practice. Baptist Hospitals serves high-unemployment communities in Jefferson and Orange counties, Texas, where cardiovascular and sexually transmitted diseases are common, and mortality rates from diabetes, cancer, and complications of obesity are well above the state average. An increasing percentage of the local population is uninsured. The study revealed a need for community-based wellness programs and exercise facilities, as well as more awareness of healthy lifestyle choices. From Plan to Action After analyzing the results, representatives from each hospital agreed to address the following issues in its plan of action: • Access to primary care and specialist services
• High mortality rates for prominent diseases
• Access to mental health services
• Fragmented continuum of care
• Health disparities among specific populations
• Unhealthy lifestyles and behaviors in the community
• Poor air quality
“Any hospital, whether non-profit or for-profit, has this opportunity to document and quantify, capturing data through the CHNA vehicle,” Domingue says. When CHC conducts a CHNA, it assembles a team that includes community relations people and the hospital’s executive team. It works with the hospital to identify people in the community with public health knowledge from whom data can be collected. The final step entails sitting down with the leadership team and walking through the data. The hospital then prioritizes the needs and develops an implementation plan. “The plan includes not just internal initiatives, but a list of community activities the hospital needs to be involved in,” Domingue says. “Most non-profit charitable hospitals already do great work in this direction, but a thorough CHNA might cause them, or any other health care operation, to refocus their aims.”
Joseph Dobrian is a contributing writer for HealthCXO.com.