Question: Screening for social needs will be required for all adult patients ages 18-64 beginning January 2024. What costs related to screening and referrals may be reported as community benefit?

Recommendation: We recommend that expenses related to screening of social needs and referrals for identified social needs be reported as community benefit.

The IRS instructions for community health improvement services (reported on Schedule H, Part I, line 7e) include language that activities not be reported as community health improvement services if they are required for licensure or accreditation. However, this restriction is in the context of excluding programs that are "more beneficial to the organization than to the community." In this situation, it is our opinion that these services of screening for and identifying social needs, then connecting patients with social needs to community resources, are responding to an identified community health need and enhance public health, are more beneficial to the community than to the organization, and therefore likely meet the definition of community health improvement services reportable on Schedule H, Part I, line 7e.

It should be noted that there are some other activities required of our organizations by law that are also reportable as community benefit on Schedule H. These include offering financial assistance/charity care consistent with the hospital's financial assistance policy and conducting community health needs assessments, both of which are required by Section 501(r) of the Internal Revenue Code.

Additional recommendations:
We recommend reporting the expense of screening for health-related social needs and follow-up referrals as community benefit under Category A3: Health Care Support Services when all of the following are met:

• Community health need has been established (for example, housing and food security issues are present in community),
• Activities are above and beyond the standard practice of discharge planning, and
• The organization operates the program in collaboration with other providers and agencies.

If these criteria are met, the following expenses could be reported:

• Staff time for the development of policies, procedures, and agreements with referral partners,
• Staff training
• Staff time for screening and referral activities, beyond standard activities,
• Technology used to facilitate screening, record findings, and make and manage referrals (excluding routine medical records).

(Be careful not to double-count with community benefit operations or any other reported community benefit expenses.)

Do not report screening for health-related social needs and follow-up referrals when:

• The activity is part of standard discharge planning,
• The activity is provided primarily to financially benefit the health care organization, such as to avoid re-hospitalization penalties, earn reimbursement incentives, or reduce Medicaid or financial assistance losses,
• The activity is limited to a subgroup of patients for which the organization bears financial risk, such as those that are part of the health care organization’s ACO/population health management program, or
• The program excludes uninsured or Medicaid-covered persons. 

(Updated December 2023)

Question: Our system is going to be purchasing a Community Referral Platform and we’re looking at UniteUs and FindHelp. The purchase is being initiated from a couple different areas. Our County Health Department is recommending all area hospitals purchase a Platform to help us all work together to meet the needs of our county residents. Our population health and quality departments are also looking at the Platform. The population would be patients and the community at large. Can we report the cost of the platform as community benefit?

Recommendation: We recommend reporting the cost of the platform as community benefit. Below is what we have in our guide. From CHA's Guide to Planning and Reporting Community Benefit, Appendix G), "Report:

• Costs to screen and refer low-income persons for needs associated with social determinants of health when community health need has been established (for example, housing and food insecurity issues are present in community) and the activities are above and beyond the standard practice of patient registration or discharge planning.
• The cost of screening and referral tools (e.g., incremental costs to add screening and referral capabilities to electronic health records systems or the cost of stand-alone screening and referral platforms).

(Updated December 2023)

Question: Last year the California Legislature passed SB-1152 — Hospital Patient Discharge Process: Homeless Patients. This law took effect on Jan. 1, 2019, and requires hospitals to implement a set of requirements regarding discharge planning for their homeless patients. We are inquiring as to whether fulfilling the requirements (meals, clothing, transportation, etc.) can be counted as community benefit or should it be considered the cost of doing business since it is now required bylaw?

Recommendation: We recommend that the expense of the items and services be reported as community benefit. We realize that the IRS instructions include language that activities not be reported if they are required for licensure or accreditation. However, this restriction is in the context of excluding programs that are "more beneficial to the organization than to the community." In this situation, it is our opinion that these services to homeless persons are responding to a community health need, enhancing public health and relieving the burden of government to improve health, therefore meeting the definition of reportable community benefits.

It should also be noted that there are some other activities required of hospitals by law that are also reportable as community benefit. These include offering financial assistance/charity care and conducting community health needs assessments.

(Updated March 2019)

Question: When should we report as community health improvement those non billed services (not covered by financial assistance or Medicaid) provided post discharge for our low-income patients?

Recommendation:  We recommend that programs and services that assist low-income persons be reported as community health improvement if the primary purpose of the activity is to provide or improve access to needed services and/or to improve their health, so long as other criteria for community benefit are met. (See Chapter 2, A Guide for Planning and Reporting Community Benefit, for example, do not report if the activity benefits the organization more than the community or if the primary purpose is to prevent readmissions to avoid penalties). Take care not to double count, that is, assure that the cost is not already reported as financial assistance (charity care), Medicaid shortfall, or as part of a subsidized health service. For example, do not report as community health improvement any clinic services that are billed and treated as financial assistance. 

Examples of services that could be reported in category A3, Community Health Improvement/Health Care Support Services:

• Taxi vouchers and other transportation for patients who otherwise could not afford to access the service.
• Services that support the well-being of low-income patients, such as wigs and other supplies for low-income cancer patients.
• Follow-up and case management services that help patients connect with primary care and other needed services, beyond routine discharge planning.

Examples of services not to report:

• Services that are part of routine care of all patients.
• Follow-up care that is part of discharge planning or is primarily designed to avoid readmissions penalties or in other ways financially benefit the organization.
• Taxi vouchers and other transportation with a primary purpose to increase revenue for the hospital, such as transporting insured seniors from a community retirement center.

Question:  While activities a hospital provides for its patients are not usually reported as community benefit, what about care management to prevent hospitalization and following discharge from acute care? We are establishing a Care Transitions department to strictly monitor our older adult discharged patients (65 and older) and wanted to confirm if the expenses for this department/program can be considered community benefit. Nurse coordinators and health coaches will be assigned to make sure these patients discharged to their homes or assisted living facilities are taking their medications as advised as well as following their doctor's orders so they are not readmitted back to the ER for the same conditions.

Some examples of care management services are:

• Diabetes self-management classes offered without a fee so people (uninsured and insured) will participate.
• Hospitals paying the salaries of nurses to act as a 'health coach' for both uninsured and insured chronic care patients at hospital owned physician practices. They say that patients will not participate if they have to pay for the health coach and currently payer sources don't cover health coaches.
• Hospital paying for hospital employed nurses to monitor Coumadin levels for patients referred by physician practices.

Recommendation:  We recommend reporting the following as community benefit:

Report as A3. Health Care Support Services chronic disease/care management services (such as peer counseling, health coaching and educational programs) that meet all of the following criteria:

• Responds to an identified community need,
• Is directed to persons who are vulnerable, disadvantaged and face barriers to accessing such health care services, and
• Goes beyond standards for discharge planning.

We recommend not reporting as community benefit:

• Chronic disease/care management services routinely provided to all of the hospital organization's patients (including patients of a hospital-owned physician practice). Chronic disease/care management services when the primary purpose of the program is to benefit the hospital organization, either as marketing or to avoid re-hospitalization penalties.

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