CHA Submits Comments to IRS on Community Health Needs Assessment

Under the new Section 501(r)(3) of the Internal Revenue Service (IRS) code, added by the Affordable Care Act (ACA), tax-exempt-status hospitals are required to conduct a community health needs assessment at least once every three tax years. This new requirement applies to tax years beginning two years after March 23, 2010, the date of ACA enactment. California state law already requires private nonprofit hospitals to assess the health needs of the communities they serve, and develop a plan with broad community involvement. In response to the IRS request for comment, CHA urged the IRS to establish a “deemed status” policy for California hospitals as being in compliance with the new 501(r)(3) requirements for federal income tax status purposes. CHA also urged the IRS to exempt California small and rural hospitals from the federal requirement because they are precluded from complying with the state law. CHA further requested that the IRS allow the three-year reporting cycle to be flexible so California hospitals would not have duplicate reporting burdens. CHA’s comment letter is available at Contact: Alyssa Keefe, (202) 488-4688,; John Nadone, (916) 552-7543,