Hospital Mandates and Community Service

Putnam County Health SummitMay 22, 2013

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About Health Quest

Health Quest

Hospitals JointVentures

Corporate Affiliates

Vassar BrothersMedical Center

Putnam Hospital Center

Hudson Valley Home Care, Inc.

Northern DutchessResidential HealthCare Facility, Inc.

NorthernDutchessHospital

Ulster RadiationOncology Center(Vassar Brothers/Benedictine Hosp)

Health Quest Medical Practice

(“HQMP”)

Health QuestUrgent Medical

Care Center, P.C.

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Why Community Benefit is Important to Hospitals

• Federal and state governments are subjecting tax-exempt entities to ever-increasing scrutiny

• New Form 990 means new transparency and invites further scrutiny from regulatory and private groups

• State Dept of Health considers community health needs when approving new projects and programs

• Early care intervention leads to better outcomes/cost savings

• Fulfill social/moral mission to improve the health of our communities

• State and Federal Reporting Regulations

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Where We Started

• “Random acts of kindness”• Unconnected events and actions• Based on anecdotal or assumed need• No accountability of cost or effectiveness

• Questions:• How much do we spend on community service

programs?• How many people do we serve?• Are we meeting the community’s needs?• Are our programs effective?

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Where We Need to Be

• “A planned, managed, and measured approach to hospitals’ participation in meeting identified community

health needs. It implies collaboration with a “community” to “benefit” its residents---particularly the poor,

minorities, and underserved groups---by improving health status and quality of life.”

• Advancing the State of the Art in Community Benefit (ASACB)

• Community benefits is an organized program, not a single event or collection of activities

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“Planned, Managed, and Measured”

CommunityAssessment

Diagnosis & Prioritization

Measuring Return

on Investment

CommunityBenefit

Plan

Evaluation of Outputs & Outcomes

Implementation

Target Desired

Outputs &Outcomes

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Infrastructure

• Each hospital has a community health needs committee• Comprised of 5-9 trustee members• Assess health needs• Develops measurable objectives and goals• Implements programs to meet objectives• Tracks results and reports to Board Committees • Reviews progress and efficacy

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Progress

• Slow and steady• Culture change• Good at selecting initiatives and implementing programs• Not so good at measurable objectives and metrics• But…the effort has paid off

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Current Regulatory Requirements

FederalState

Needs Assessment

Implementation Plan

Community Service Plan

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NYS Prevention Agenda Priorities

• Prevent Chronic Diseases• Promote a Healthy and Safe Environment• Promote Healthy Women, Infants and Children• Promote Mental Health and Prevent Substance Abuse• Prevent HIV, STDs, Vaccine Preventable Diseases and

Healthcare Associated Infections

• Each hospital must pick at least two priorities to work on with the local DOH

• At least one must address a health disparity

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NYS Requires Hospitals To:

• Develop an action plan for each chosen priority, including• Goals• Measurable objectives including some on disparities• Evidence based and promising practices• Action plans cover a three-year period, 2013-2017

• Collaborate with community partners

• Disseminate the plan to the public

• This Community Service Plan is due on November 15th

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Federal (IRS) Requirements for Hospitals

• Conduct a community health needs assessment at least every three years

• Include input from individuals who represent the broad interests of the community, including those with special knowledge or expertise in public health

• Adopt an implementation strategy to meet significant identified needs

• Make the assessment widely available to the public

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How Do We Satisfy Both Requirements?

FederalState

Needs Assessment

Implementation Plan

Community Service Plan(Prevention

Agenda)

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Federal Penalties for Non-compliance

• Forgiving of most infractions as long as they’re disclosed and not willful

• “Willful and Egregious” violations• Facility-level tax (aka FINE) of $50,000• Possible loss of tax exempt status

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Timeline

• May• Final data available• Select priorities in conjunction with local health department

• June-July• Select initiatives and develop programs• Set metrics and goals for 1st, 2nd, and 3rd years• Identify program leaders

• August• Write drafts of Needs Assessment, Implementation Plan and

Community Service Plan (Deb)

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Timeline Part 2

• September• Internal review and sign-off• Formatting for website

• November• Documents up on website• Submission of all state and federal documents by November

15th.

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In Conclusion

• Hospitals have always provided community benefits• We need to develop a more systematic approach to get the

best bang for our buck• State and federal requirements are about processes as much

as outcomes• Putnam Hospital center and Health Quest are well-positioned

to meet these requirements