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The Hospital Community Benefits program, established under the 2010 Affordable Care Act (ACA), requires nonprofit hospitals to invest in their local communities through population health initiatives, as a requirement for retaining the hospital or health system’s tax-exempt status with the federal government. Section 501(r) of the Internal Revenue Code lays out the requirement in more detail, including the following provisions that nonprofit hospitals must meet:
- Conduct a Community Health Needs Assessment (CHNA) on an every-three-year basis, and create an implementation strategy for the top priority needs;
- Establish a written financial assistance policy for medically necessary and emergency care;
- Comply with specified limitations on hospital charges for those eligible for financial assistance; and
- Comply with specified billing and collections requirements1
In many cases, hospitals and health systems direct the majority of their Community Benefits dollars to medically necessary and emergency care for patients who cannot qualify for Medical Assistance. However, according to the guidelines of the ACA, Community Benefit funds can be used to address the upstream causes of poor health outcomes, or social determinants of health. These include housing conditions, specifically lead-based paint hazards that lead to lead poisoning. In order to invest in lead remediation, the hospital’s CHNA must identify residential lead exposure as a local health priority in the community that the hospital or health system serves.
A first step is to understand how Hospital Community Benefits dollars are currently deployed in your community or state. Then, develop a relationship with those involved in the Community Health Needs Assessment process at the non-profit hospitals and health systems that serve your geographic area of interest. For statewide efforts, it can be beneficial to work with a Hospital Association or other umbrella organization which represents the not-for-profit hospitals in your state. Hospitals are increasingly recognizing the value of making investments in healthy housing, especially where housing interventions can reduce direct costs related to emergency care for uninsured or under-insured ‘high utilizer’ asthma patients. The goal of your efforts is to effectively make the case that community benefit dollars should be used to address lead-based paint along with asthma and injury-related health and safety hazards in the home environment, or that these funds can be used for other in-home services like education and resources to mitigate lead exposure. Demonstrate the other funding sources within your partnerships that can leverage the investment of community benefits dollars in housing. Hospitals may see the value of investment in partnerships that result in tangible impacts on housing quality.
More information for hospitals on making housing investments through Hospital Community Benefits here .
To our knowledge, no hospitals have used their Community Benefit dollars for investments in lead poisoning prevention to date, but there are numerous examples of investments in housing:
- Presence Health (Chicago, IL) invested $35,000 of community benefit funds into a pilot project to re-mediate asthma triggers of its uninsured patients in Chicago’s West Side neighborhood.
- Dignity Health (San Francisco, CA) provides loans to affordable housing developers in California as part of the organizations Community Investment Program. In September 2018, Dignity provided a $1.2M bridge loan at below market-rate interest to push forward a community revitalization project that will include 400 units of affordable housing.2 3
- Nationwide Children’s Hospital (Columbus, Ohio) partnered with community organizations to form a nonprofit housing organization, Healthy Homes, with the goal to “revitalize the neighborhood adjacent to Nationwide Children’s and Columbus’ South Side.” The partnership provides home repairs and builds new affordable housing. From 2008-2017, Nationwide Children’s Hospital invested $6.6M in Healthy Homes, with additional investments from United Way, City of Columbus, Frank County Land Bank, Home Sales, and donations for a total investment of $22.6M. With this capital, the partnership built 58 affordable housing units and 15 new homes, renovated 71 homes, and distributed 149 home improvement grants.4