On April 21, 2017, the Ohio Department of Health (ODH) sent a notice of CHNA reporting requirements to Ohio tax-exempt hospitals. By July 1, 2017, each tax-exempt hospital, defined as a nonprofit or government-owned hospital, that is exempt from income tax under section 501(c)(3) of the Internal Revenue Code and that under federal law is a hospital organization required to meet CHNA requirements, must submit its most recent CHNA, Implementation Strategy, and Schedule H and attachments from IRS Form 990. A web address was provided for online submission of these documents. In addition, each tax-exempt hospital is asked to complete a survey on the ODH website regarding collaboration with local health departments, priority areas, outcomes and monitoring being addressed in the most recent Implementation Strategy. While communities are not required to collaborate and are not required to align to the State Health Improvement Plan until January 1, 2020, ODH has requested the information now to assess the current status of alignment in the state.

As noted in ODH’s Improving Population Health Planning In Ohio: Guidance For Aligning State And Local Efforts, “[c]ollaboration is an essential element in improving population health at the state and community level.” To this end, ODH encourages working together across all sectors to reduce duplication and to assist all community partners in conducting health assessments in an effective and efficient manner. ODH believes that collaborative efforts allow partners to complete a single plan that engages all community partners in the process. To assist with these efforts, ODH has issued guidance for collaboration, alignment and processes for community assessments and plans.

ODH guidance on collaboration

Local health departments and tax-exempt hospitals are strongly encouraged to collaborate with a broad range of community partners to identify local health priorities and implement strategies that will contribute to improving the health status of the community. Collaboration should occur at the county level, at a minimum, to conduct a community health assessment to be shared among all partners. Local health departments and tax-exempt hospitals should be the lead partners in the process with suggested participation from the following:

  • Federally qualified health centers (FQHC)
  • Rural health clinics
  • Healthcare providers
  • Alcohol Drug and Mental Health Boards (ADAMH)
  • Health plans
  • Schools
  • Employers
  • Governmental and nongovernmental agencies
  • Businesses

ODH guidance on alignment

The State Health Assessment and State Health Improvement Plan (SHA/SHIP) provides information on Ohio’s health priorities and can be used in assessing a local community’s health priorities. The SHA/SHIP outcome indicators, evidence-based strategies and framework can be used as a foundation for community assessments and plans.

The Mobilizing for Action through Planning and Partnerships (MAPP) framework is used for the SHA/SHIP. This framework can be used to meet the needs of both the local health departments and hospitals’ federal community health needs assessment and implementation strategy requirements. The SHA/SHIP conceptual framework, the “pathway to health value,” can also be used for the local assessment and planning processes.

ODH will identify key data metrics/indicators that can be shared at the county level. The SHA/SHIP metrics will be the starting point of where additional data may be provided. Each community partner should identify its data needs, priorities, strategies, outcome measures and populations it targets. Once commonalities are identified, then a community plan can be built.

Local health departments and tax-exempt hospitals (defined above) are encouraged to select at least two priority topic areas from the SHIP to address in the community health improvement plan (CHIP)/hospital implementation strategy. This new guidance does not require each entity to select two priorities; rather, the priorities should be selected as part of the collaborative process and guided by the data.

Guidance further suggests that for each of the priority topic selected, you should choose at least one priority outcome indicator, at least one strategy to implement and one related indicator to measure impact. ODH further suggests that, for a stronger plan, local health departments and tax-exempt hospitals should consider selecting at least one strategy to implement and one related indicator to measure impact from each of the following cross-cutting factors:

  • Social determinants of health
  • Public health system, prevention and health behaviors
  • Health care system and access

ODH reporting requirements

Plans and assessments

ORC 3701.981 was enacted in July 2016 to address transparency and accessibility. This section requires that, not later than July 1, 2017, each board of health and tax-exempt hospital (defined above) submit to ODH any existing assessments (hospital community health needs assessment and board of health community health assessment) and plans (hospital implementation strategy and board of health plan for improving community health).

Beginning January 1, 2020, each board of health and tax-exempt hospital must complete assessments and plans in alignment on a three-year interval established by ODH.

No later than October 1, 2020, each board of health and tax-exempt hospital must submit assessments and plans covering years 2020 through 2022 to the ODH.

Beginning October 1, 2023, and every three years thereafter, each board of health and tax-exempt hospital must submit subsequent assessments and plans to the ODH.

ODH is required to provide guidance regarding submitting assessments and plans and an online repository.

IRS form 990, Schedule H

No later than July 1, 2017 and annually thereafter, each tax-exempt hospital (defined above) must submit information to ODH.

If the tax-exempt hospital is not a government-owned hospital, the hospital must submit a copy of the hospital’s schedule H (Form 990) for the preceding fiscal year, including attachments and reporting on financial assistance and means-tested government programs and community building activities in Parts I and II of Schedule H. Subsequent annual Schedule H filings must be submitted no later than 30 days after filing with the IRS.

If the tax-exempt hospital is a government-owned hospital, the hospital must submit information that is equivalent to the information that is submitted by a hospital that is not government-owned.

ODH is required to provide an online repository for submission of this information.

The Author

Christine Kenney
Director of Regulatory Services
614.227.4865
ckenney@incomplianceconsulting.com