The 411 on Community Health Needs Assessments

By: Amanda Barna

As a result of Section 9007 of the Affordable Care Act, all non-profit hospitals are required to conduct a comprehensive Community Health Needs Assessment (CHNA) every three years. In addition, in order to meet the CHNA requirements, the hospital must adopt an “implementation strategy” to meet the community health needs identified through the CHNA.

The goal of a Community Health Needs Assessment is to improve community health and wellness by connecting research, resources and people all while complying to IRS guidelines. Most CHNAs include both primary and secondary data. Primary data can be collected using an approach designed to collect community feedback such as surveys and focus groups. In some instances, it is important to oversample key demographic groups such as low income or minorities. A well-executed CHNA allows hospitals and healthcare organizations to identify priority community health needs as well as identify existing gaps in services that should be addressed, strengthen relationships with community partners to improve local health care delivery, and share information collected from the assessment with the public.


How often are hospitals required to complete a CHNA? Every three years with the first 3-year cycle ending at the end of 2013 for most hospitals.

What should the CHNA report include? The CHNA Report should include a description of the following: (1) the community served by the hospital, (2) the process, data, and methods used to conduct the assessment, (3) how the hospital used community feedback, (4) the community health needs identified through the CHNA, in priority order and (5) the existing health care facilities and other resources within the community available to meet the community health needs identified in the CHNA.

What if the Hospital has multiple facilities? Hospitals with more than one hospital facility are required to document a separate CHNA and Implementation Plan for each facility.

What is the Implementation Strategy? The IRS defines the Implementation Strategy as, "a written plan that addresses each of the community health needs identified through a CHNA."

When is the CHNA considered "conducted"? The CHNA is considered conducted in the year in which the results are made available to the public. The Implementation Strategy is considered ‘adopted’ on the date the implementation strategy is approved by an authorized governing body of the hospital organization.

What does the hospital have to submit to the IRS? While the Hospital is not required to submit the entire CHNA report to the IRS, it must attach to its Form 990 the most recently adopted Implementation Strategy.

What happens if the hospital does not complete the CHNA? Hospitals that do not meet the CHNA requirements will be imposed a $50,000 excise tax.

Community Health Needs Assessment Resources:

  1. IRS Notice 2011-52: Notice and Request for Comments Regarding the Community Health Needs Assessment Requirements for Tax-Exempt Hospitals
  2. Community Benefit Issue Brief
  3. Best Practices for Community Health Needs Assessment and Implementation Strategy Development: A Review of Scientific Methods, Current Practices, and Future Potential
  4. Behavioral Risk Factor Surveillance System (BRFSS) Questionnaires
  5. A completed CHNA: 2011 Stark County CHNA (conducted by CMOR)