Improving Care for Dual Eligibles: How States are Innovating ...
Hospital Community Benefit Spending: How to Increase Investments in Population Health Tuesday, January 10, 2017 12:30pm-2:00pm Eastern S u p p o r t e d b y t h e R o b e r t Wo o d J o h n s o n Fo u n d a t i o n 1 Webinar Agenda 12:30 pm Welcome and Introductions Trish Riley, Executive Director, NASHP 12:40 pm Overview of Community Benefits Spending Maureen Byrnes, MPA, Lead Research Scientist, Department of Health Policy and Management, Milken Institute School of Public
Health, George Washington University 1:00 pm Overview of Study Sara Rosenbaum, J.D., Harold and Jane Hirsh Professor, Department of Health Policy and Management, Milken Institute School of Public Health, George Washington University 1:20 pm Opportunities for States Cynthia Woodcock, MBA, Executive Director, The Hilltop Institute 1:40 pm Questions and Discussion 2 Aligning Federal Community Benefit Tax Policy with
Community-Wide Health Improvement Supported by Kresge Foundation and Robert Wood Johnson Foundation January 10, 2017 Role of Hospitals in Improving Community Drivers of change: Health A growing focus on social determinants of health. Health care reform. Expanding and refining the community obligations of tax-exempt hospitals. Rosenbaum, S. 2016. Hospitals as community hubs: Integrating community benefit spending, community health needs assessment, and community health improvement. Retrieved at https://www.brookings.edu/research/hospitals-as-community-hubs-integrating-community-benefitspending-community-health-needs-assessment-and-community-health-improvement/ Community Benefit
1956: IRS rules that hospitals can meet the community benefit test if they furnish charity care. 1969: IRS broadens community benefit definition to encompass hospital activities that benefit communities as a whole. 2009: IRS introduces the Form 990 Schedule H Worksheet The Numbers > 50% of all U.S. hospitals (> 2900) operate as nonprofit corporations. Between 2002 and 2011, national value of tax exemption estimated to nearly double, from $12.6 billion to 24.6 billion (federal and state income taxes, state and local property and sales taxes) IRS reported > $62 billion in community benefit spending in 2011 ACA Reforms to TaxExempt Policy
EMTALA compliance Financial assistance policy Limits on charges Bar against unreasonable collection efforts Community Health Needs Assessment (CHNA) requirements including transparent, publicinvolved planning, transparency, and implementation strategy No change to pre-existing community benefit definition Whats Missing? Three key factors inform the conversation and collaboration: A clear link between health planning and community benefit investment Transparency in community benefit investment choices
Incentives to spend on community-wide health improvement Community Benefit Web Resource Prototype developed by GW for Robert Wood Johnson Foundation. Full web resource scheduled to be available in 2017. Charity Care and Certain Other Community Benefits at Cost for Tax Year 2011: Number and Selected Financial Data by Type of Number of Net community Percent of Community Benefit* activities or Number of Total community Direct offsetting benefit total Type of Community Benefit
Total Community Benefits programs (1) persons served (2) benefit expense (3) revenue (4) expense (5) expensex (6) 553,999
6,581,459 2,034,871 42,998 1,991,957 0.31 Total charity care and means-tested government programs Charity care at cost Unreimbursed Medicaid Unreimbursed costs other means-tested government programs Total other benefitsv Community health
improvement services and community benefit operations Cash and in-kind contributions to community groups Note: Money amounts are in thousands of dollars. Detail may not add to totals due to rounding. New Research CHNAs emphasis on importance of upstream spending on social risk factors: 72 percent of hospitals identified obesity; 68 percent identified mental health; and 62 percent identified diabetes as the top health challenges of their communities. Current IRS Policy IRS separates community building (communitywide efforts) from community benefit spending while requiring separate justification for
community-wide health improvement efforts IRS does not require hospitals to report CHNAlinked CB spending or describe how CB spending responds to CHNA priorities IRS Policy Opportunities Broaden the definition of community benefit to clearly include community health improvement activities that encompass community-wide efforts, now classified as separate community building activities Revise Schedule H reporting to include hospital reporting on the Relationship between CHNAs, implementation strategies, and CB spending Advance best practices in community-wide health improvement through government-wide advisory committee that identifies evidence-based upstream spending initiatives that hold promise to improve
community health Suggested Reforms 1. Eliminate regulatory obstacles to upstream spending 2. Clearer link between CHNAs and community benefit spending 3. Transparency Hospital Community Benefit Policy: Opportunities for States January 10, 2017 Cynthia Woodcock National Academy for State Health Policy Presentation Overview Promoting community involvement in the Community Health Needs Assessment (CHNA) process Using regulatory tools to incentivize a focus on social and economic determinants of health
Encouraging hospital transparency and accountability Repeal and Replace: Implications for states -17- Regional and community partnerships can increase the effectiveness of the CHNA process Multi-facility collaborations and collaborations between hospitals and public health agencies are not only permitted but encouraged by the 2014 IRS final rules Collaborations help align hospital community benefits with public health planning and avoid duplication of effort
Potential partners: hospitals, physician groups, state and local public health and social services agencies, community stakeholders, health plans, private funders -18- States can encourage or require community involvement in the CHNA process Massachusetts: Attorney Generals guidelines encourage hospitals to seek input from community groups representative of the populations served Maryland: Requires hospitals to consider CHNAs developed by state/local health departments and encourages consultation with community groups
Texas: Requires hospitals to consider input from local health departments, public health districts, and community stakeholders Utah: Mandates annual consultation with county health officials by hospitals and nursing homes as part of the CHNA process -19- Some successful regional and community collaborations Integrating Community Health Improvement and Population Health: Childrens National Health System, Washington, DC
Mayors Healthy City Initiative: Baton Rouge, LA From Volume to Value: Carroll Hospital, MD Soccer for Success: Trinity Health -20- Some successful regional and community collaborations continued Enos Park Access to Care Collaborative: Springfield, IL
Communities that Care Coalition: Franklin County, MA Allies for Substance Abuse Prevention of Anderson County: Anderson County, TN -21- Some states use regulatory tools to encourage investment in social and economic determinants of health New York: Implementation strategies must focus on at least two of five state Prevention Agenda priorities California: Statute gives examples of community
benefit activities that address social and economic factors that shape health Maryland: Statute requires hospital implementation strategies to describe efforts to track and reduce health disparities -22- State reporting forms can include a focus on social and economic determinants of health New Hampshire: The states community benefit reporting form requires hospitals to indicate socioeconomic needs being addressed, such as poverty, unemployment, educational attainment, high school completion, vandalism/crime,
homelessness, air quality, and water quality -23- State reporting requirements can encourage transparency and accountability 31 states require hospitals to report on community benefits -24- Examples of state reporting requirements that encourage transparency and accountability California hospitals must complete a narrative section on community benefit activities
Vermont requires community benefit reports to be posted on both the hospitals website and the states website New York and Washington require hospitals to post implementation strategies on their websites Indiana and Maryland hospitals must report on the effectiveness of community benefit initiatives New Hampshire and Rhode Island require hospitals to report activities that they anticipate undertaking in the near future Maryland, Indiana, and Texas can impose civil penalties on hospitals
for overdue community benefit reports -25- How can states be more proactive in promoting targeted and collaborative hospital community benefits? Now that the CHNA process mandated by the Affordable Care Act (ACA) is established, states should focus on: More regional, multi-stakeholder collaboration Greater transparency
Implementation processes and challenges Evaluation to assess whether desired outcomes are being achieved More comprehensive reporting by hospitals that goes beyond Schedule H and can be used to monitor progress with state health reform initiatives -26- Repeal and Replace: Where does this leave states? Repeal of 9007 of the ACA would:
Eliminate the requirement for hospitals to conduct CHNAs every 3 years (as well as to adopt CHNA implementation strategies and conduct evaluations) Do away with reforms related to financial assistance policies, limitations on charges to patients who are eligible for financial assistance, and billing and collections practices States need to act now to develop their own legislative and regulatory replace strategies in the event Congress does not see this as a priority -27- About The Hilltop Institute The Hilltop Institute at the University of Maryland, Baltimore County (UMBC) is a nationally recognized research center dedicated to improving the health and
wellbeing of vulnerable populations. Hilltop conducts research, analysis, and evaluations on behalf of government agencies, foundations, and nonprofit organizations at the national, state, and local levels. www.hilltopinstitute.org -28- Contact Information Cynthia Woodcock Blair Inniss Executive Director Policy Analyst 410.455.6274 410.455.1441
[email protected][email protected] The Hilltop Institute University of Maryland, Baltimore County (UMBC) www.hilltopinstitute.org -29- Questions & Discussion Please type your questions into the chat box. 30 Thank you! Your opinion is important to us. After the webinar ends, you will be
redirected to a web page containing a short survey. Your answers to the survey will help us as we plan future NASHP webinars. 31
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