Topic List

Topic: Addressing Hospital Industry Hazards and Injuries (August 2009)
Topic: Advanced Directives (October 2008; Updated November 2015)
Topic: Community Awareness/Education (June 2012)
Topic: Community Health Resource Center (February 2011)
Topic: Competition to Increase Awareness of Mental Illness (August 2009)
Topic: Health Fairs/Screenings (2007; November 2015)
Topic: Hospital Website Provides Public Health Information (August 2009)
Topic: Is it Marketing? (April 2009)
Topic: Lactation Services
Topic: Media Outreach Programs (Updated June 2012; November 2015)
Topic: Prenatal Classes (May 2010)
Topic: Program T-shirts and Accessories (December 2014)
Topic: Support Groups (November 2015)

Please Take Note: The information provided below does not constitute legal or tax advice. The material is provided for informational/educational purposes only. Please consult with counsel regarding your organization's particular circumstances.

Topic: Addressing Hospital Industry Hazards and Injuries

Question: The Risk Management Department of our hospital recently hosted its first Workers' Compensation Healthcare Forum for clinical and administrative representatives from 30 hospitals throughout the state. Our goal was to help raise awareness of the types of injuries and hazards that are common within our industry. Should this be reported as community benefit? It improves health beyond our organization.

Recommendation: We recommend that this activity not be reported as community benefit because the activity is primarily related to a cost of doing business, not a community need.

Topic: Advanced Directives

Question: We provide education on Living Wills, Durable Power of Attorney and Notary Public. Is this a community benefit and will we be able to count any education/information that is given to the public and inpatients and their families?

Recommendation: We recommend reporting the cost of providing education on advanced directives such as living wills and durable powers of attorney when provided for the community, not exclusively for the organization's patients. Therefore we recommend:

• Community education on advanced directive provided in response to identified community need.
• Community education that goes above and beyond what others (including for-profit) organizations provide.

Do Not Count:

• Education on advanced directives provided in fulfillment of statutory requirements.
• Education that is equivalent to what most health care organizations (including for-profits) provide.

(Updated November 2015)

Topic: Community Awareness/Education

Question: Members of our hematology team often go to a school to sit with teachers and staff to discuss a child who has been diagnosed with a certain form of cancer in order to help everyone meet the child's needs and to answer questions from the school. This is being considered Community Awareness/Education concerning cancer.

Recommendation: We recommend this not be reported as a community health improvement service, because, as you remarked, it is related to an individual patient's care. But we think it reflects outstanding care on the part of the hospital.

(June 2012)

Topic: Community Health Resource Center

Question: Our hospital runs a community health resource center. The center provides free resources to the community, including a space for patients to research health issues from books, videos, and Internet. The space is also used for free "Ask An Expert" events, and will be available this year as a place for students to study and do research. It is staffed by a part-time employee and volunteers who provide health information via phone, in person, and email. A small part of the space is used for retail items and some marketing materials.

How much of the costs to run the resources center can be counted as a community benefit? Can we include the employee's wages?

Recommendation: We recommend reporting this activity under category A1. Community Health Education as long as you can document it is related to a community health need. We recommend estimating the percentage of time/space that constitutes marketing and retail. If the percentage of total cost that supports marketing and retail is less than half (because IRS instructions related to defining community benefit say that the primary purpose of the activity should be to address community need) then apply the percentage of cost that supports the community benefit aspects of the center to the all costs (space costs/employee wages) to determine what can be counted as community benefit.

(February 2011)

Topic: Competition to Increase Awareness of Mental Illness

Question: Our hospital sponsors an academic and art competition designed to decrease the stigma of mental illness. The competition encourages students to gain knowledge about psychiatric diseases and develop a more tolerant and realistic perspective toward people with severe psychiatric problems. The competition also aims to promote students' interest in careers in mental health care. An award of $1,000 is given to the best overall submission, $500 to the first place projects in the art and academic categories, and ten $100 awards to runners-up. The awards are given during a designated "research" day at a local school where students, parents and teachers can learn about advancements in mental health.

Should we report the costs associated with this competition as community benefit? If so, which category would it fall under?

Recommendation: We recommend you report this program as community benefit under A1, Community Health Education, as long as the program was started because your organization had identified a need for education about mental health. While there is a career-related purpose, it appears that its primary purpose is for educating the community about mental illness.

Topic: Health Fairs/Screenings

Question: When and how much of health screenings should be counted as community benefit?

Recommendation: We recommend reporting health screenings as community benefit under the following circumstances:

• When there is an identified need indicating that the screening could improve health care of the population being screened, and
• When appropriate follow-up is provided, including referrals to health care providers who are accessible and available for additional testing and/or treatment, and
• When follow up is provided for persons who are low-income and/or uninsured, and
• When referrals include providers not affiliated with the organization (if they exist). There are instances when the organization (along with its affiliated providers) conducting the screenings is the only provider able to offer accessible and available follow up care. This is often the case when the organization is the safety net provider in a low-income area.

We recommend not reporting health screenings as community benefit under the following circumstances:

• When the purpose is to promote the image of the organization or to get referrals for the organization or for providers affiliated with the organization and/or
• When the location of the screening suggests that primarily upper income and insured persons will be screened, such as at an upscale mall in an affluent area.

We recommend that if screenings are conducted as part of a health fair, costs should be reported in Category A1. Community Health Education. If conducted as a stand-alone event, count in Category A2. Community-based Clinical Services.

We recommend that evaluation of screening programs go beyond tracking attendance and should include assessment of whether needed follow-up care is obtained and whether health outcomes are improved.

Question: We conduct health screenings held one time during the year at various employers (manufacturing facilities, coal, etc.) in a rural area with a demonstrated need. Target population: rural blue collar workers. The health screenings target rural blue collar workers for CVD, diabetes, stroke risk, obesity, etc. Do employer-based screenings count as a community benefit?

Recommendation: We recommend looking at the purpose of the employer based screening. If it was primarily to generate good will with employers or to get referrals to the hospitals, it would not be considered community benefit, but rather marketing. However, if you conduct the screenings in order to prevent and get early treatment for health problems you have reasons to believe exist in the workplaces (you have identified a community health need), it should be reported under Community Based Clinical Services A2.

Question: We conduct health screenings held one time during the year at various employers (manufacturing facilities, coal, etc.) in a rural area with a demonstrated need. Target population: rural blue collar workers. The health screenings target rural blue collar workers for CVD, diabetes, stroke risk, obesity, etc. Do employer-based screenings count as a community benefit?

Recommendation: We recommend looking at the purpose of the employer based screening. If it was primarily to generate good will with employers, or to get referrals to the hospitals, it would not be considered community benefit, but rather marketing. However, if you conduct the screenings in order to prevent and get early treatment for health problems you have reasons to believe exist in the workplaces, it should be reported because it is addressing a community need and meeting the community benefit objective of enhancing the health of the population.

Topic: Hospital Website Provides Public Health Information

Question: Our website provides the overall community with public health information. Does the time and costs associated with improving the website that is not related to marketing or recruitment of patients count as a community benefit expense?

Recommendation: In our experience, hospital websites are primarily used to give the public information about the organization rather than public health information. It is more likely the public will go to other sites for public health information. However, we recommend reporting the cost of providing web-based information on public health issues in the following circumstances:

• If you have a designated public health education section on your website that addresses health problems in your community (for example, obesity is a problem in your community and you address the issue on the website),
• If the primary reason you are providing information on your website is to address public health education needs (as opposed to generating good will for the hospital), and
• If you are able to separate costs for public health education from costs associated with your website's business functions.

Please keep in mind that the IRS instructions for reporting community health improvement services on the Schedule H say that the primary purpose of reported activities should be to address a community need, so to report any expenses, the primary purpose of the website should be to provide health information. This is a high standard.

Topic: Is it Marketing?

Question: We have a Diabetes Education program and our educator sees in-patients and out-patients. One of the extra services she offers is a class — four 2.5 hour sessions. (Patients have to be referred by a physician.) I'm concerned that because it is offered through our Diabetes Education program, maybe it should not be counted. As the PR Manager at our Hospital, I find myself stumbling often over the question: Is this program/activity offered primarily for marketing or public relations?

Recommendation: It is always helpful to document the original intent of programs that you think should count as community benefit. Was the program established to achieve one or more specific community benefit objectives? Or, was it established to increase referrals to the hospital? Was it established to respond to the emerging standard of care? Your diabetes education class seems to be an extension of care to patients of the hospital. In fact, the classes seem to be part of their treatment plan.

Therefore, we recommend the classes should not be counted as community benefit. However, you can always report programs such as these in a narrative report.

Topic: Lactation Services

Question: Our maternity clinic offers lactation services to new mothers who have been discharged from our hospital. The patient base is comprised of a pretty even split between low income and upper income women. Currently, the clinic is billing for lactation appointments. After a cost/benefit analysis was completed it was discovered that the reimbursement is incredibly low (for example a $1,500 appt. was reimbursed $69). The clinic would like to stop charging for the appointments and offer the service free of charge to the patients and then count the staff time spent with each individual as a community benefit. Should this be reported as community benefit?

Recommendation: We believe offering lactation services is a service to your patients, since there is clear evidence that breastfeeding contributes to the health of both mothers and babies. However, because this service is offered only to patients in your maternity program, we do not recommend reporting it as community benefit. It seems to be an extension of your excellent maternity care. If lactation services were offered to the broader community, including mothers who did not receive maternity care at your facility and included outreach to low income families, then we would recommend reporting it as community benefit.

Topic: Media Outreach Programs

Question: We use TV, radio and the press to reach the metro area on the causes and prevention of childhood obesity. Because we are in a major metro area the number of people reached per the various media outlets is over two million people. If this activity can be counted, can (or should) we use the two million plus people served when reporting community benefit under Category A1. Community Health Education?

Recommendation: Reporting "persons served" is an optional item in the CHA, IRS and Community Benefit Inventory for Social Accountability (CBISA) reporting frameworks.

If reporting, count as the number of persons served only those who actually respond to the media coverage. This could be the number who call for more information or the number who attend a session that is referenced in the media content. We recommend taking a very conservative approach to counting persons served through general media coverage. It may be better to report these activities in the narrative report only. Regarding whether the activity itself can be counted, the case is strongest if the programming lets people know about community-wide prevention/treatment resources rather than only about your hospital.

A Guide for Planning and Reporting Community Benefit gives examples of how to count programs/activities and persons served.

(Updated November 2015)

Question: We use TV, radio and the press to reach the metro area on the causes and prevention of childhood obesity. Because we are in a major metro area the number of people reached per the various media outlets is over two million people. If this activity can be counted, can (or should) we use the two million plus people served when reporting community benefit under Category A1. Community Health Education?

Recommendation: Reporting "persons served" is an optional item in the CHA, IRS and Community Benefit Inventory for Social Accountability (CBISA) reporting frameworks.

If reporting, count as the number of persons served only those who actually respond to the media coverage. This could be the number who call for more information or the number who attend a session that is referenced in the media content. We recommend taking a very conservative approach to counting persons served through general media coverage. It may be better to report these activities in the narrative report only. Regarding whether the activity itself can be counted, the case is strongest if the programming lets people know about community-wide prevention/treatment resources rather than only about your hospital.

Page 135 in A Guide for Planning and Reporting Community Benefit gives examples of how to count programs/activities and persons served.

Topic: Program T-shirts and Accessories

Question: Our health system provides resources to schools (focusing on limited resource schools) that 1) provide health education to students, staff and families about nutrition and activity and 2) motivates them to participate in a "5210 Challenge".  Our community has identified the need to promote 'raising healthy children' with a specific goal of 'Advancing the safety, well-being, resilience and healthy development of children and youth.'

5210 emphasizes healthy eating, increased physical activity, decreased screen time and eliminating sugar-sweetened beverages. So, providing the program, we feel, easily qualifies as a community benefit activity. Our "What Counts" question relates to the dollars spent in providing 5210 t-shirts to all program participants.  The t-shirts do have our health system logo on them as well as the 5210 Challenge text, thus we have previously not counted any expense as we assumed it would be seen as marketing for the health system.  Program leaders oppose this notion and state that many children would not participate if we did not provide the specific t-shirt incentive. 

Does having the health system logo on the t-shirt incentives disqualify them as a reportable program expense, because it could be seen as marketing for the health system?  If so, is it reasonable to report a percentage of the expense; equal to perhaps a reasonable amount that would be spent on an incentive without a logo?

Recommendation:  If experience has shown that the t-shirts are an effective incentive to get children to participate in the program we suggest counting all the costs. However, if you want to be conservative in your reporting you could subtract a percentage of the cost that reflects marketing.

(December 2014)

Topic: Support Group

Question: Our hospital owns 50 percent of a retirement facility located on our campus. One of our hospital employees, a social worker, is assigned to lead a support group at this retirement facility for the care-givers of elderly/ailing patients. The support group is open to anyone in the community caring for a loved one.

Recommendation: We recommend reporting the full expense to the hospital for the staff person conducting support groups in the retirement facility for care givers as long as the support group is open to anyone in the community. The expense could be reported as community health education, Category A1.  

 (Updated November 2015)