America’s Essential Hospitals submitted comments July 5 to the Internal Revenue Service (IRS) on a proposed rule implementing Affordable Care Act provisions that require charitable hospitals to perform community health needs assessments (CHNAs). In the letter, the association expresses support for CHNAs, but asks the IRS to grant dual-status organizations – governmental hospitals with 501(c)(3) status – additional flexibility to determine the form and content of the CHNAs. Additionally, America’s Essential Hospitals urges the IRS to exempt these dual-status hospitals from the prescriptive documentation requirements related to CHNAs. Granting these hospitals the ability to determine the form, content and implementation strategy for CHNAs would reduce their administrative and financial burdens, while ensuring they demonstrate they are fulfilling community needs.
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