Transcript Document

Welcome!
Wisconsin Hospital Association
and Members
Presented by:
Douglas W. Lyon, CPA
and
Trina Hackensmith
1
Background
Historical Challenges to All NFP Hospitals
 Are not-for-profits sufficiently charitable?
 Should the playing field be level?
 Is the “Community Benefit Standard”
adequate?
©Lyon Software, 2011
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Heath Care Reform
PPACA Requirements for charitable hospitals:
 Community health needs assessment
 Implementation strategy
 Financial assistance (FA) policy
 Free emergency care to those meeting FA
policy
 Limit charges to those meeting FA policy
 No extraordinary collection practices
Julie Trocchio, Catholic Health Association, 2010
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Topics for Today’s Webinar
A Review of “What Counts”
New Requirements – Health Reform and IRS
Implementing a Community Benefit Program
 identify who should be involved in the
tracking/reporting process
 Identify programs, collect data
 report to your communities
CBISA Survey™ and CBISA Online™
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A Review of “What Counts”
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What is Community Benefit?
Community benefit programs or activities provide treatment and/or
promote health and healing as a response to identified community
needs.
For a program to “count”:
1. It must address a documented community need, and
2. It must have at least one of these community benefit objectives
a) Improve access to health care services
b) Enhance health of the community
c) Advance medical or health care knowledge
d) Relieve/reduce the burden of government/other community efforts
Source: A Guide for Planning & Reporting Community Benefit 2008 Edition
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What is Community Benefit?
1. It must address a documented community need
•Health needs assessment survey
•Public health department
•Healthy Communities/Healthy People 2010 goals
•CDC
•Board or management
•Community leaders
•Research findings
Source: A Guide for Planning & Reporting Community Benefit 2008 Edition
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What is Community Benefit?
2. It must have at least one of these community benefit objectives
a) Improve access to health care services
•The program is available broadly to the public
•The program participants include vulnerable or underserved
persons
•A barrier to access is reduced or eliminated
•If the program ceased to exist, the community would lose
access to a needed service
Source: A Guide for Planning & Reporting Community Benefit 2008 Edition
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What is Community Benefit?
2. It must have at least one of these community benefit objectives
b)
Enhance health of the community
•The program is designed around public health goals and
principles
•The program yields measurable improvements to health status
•The community’s health status would decline if the program
ceased to exist
•A public health agency provides comparable services
•The program is operated in collaboration with public health
partners
Source: A Guide for Planning & Reporting Community Benefit 2008 Edition
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What is Community Benefit?
2. It must have at least one of these community benefit objectives
c) Advance medical or health care knowledge
•The program trains health professionals/students as they
advance toward health profession degrees or other credentials
•The organization does not require trainees to join the staff
•Health professional continuing education programs are open to
professionals in the community
•The program involves research, with findings available broadly
to the public within a reasonable period of time
Source: A Guide for Planning & Reporting Community Benefit 2008 Edition
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What is Community Benefit?
2. It must have at least one of these community benefit objectives
d) Relieve/reduce the burden of government/other community efforts
•The program relieves a government financial or programmatic
burden
•Government provides the same or a similar service
•Government provides support of the activity
•If the program were closed, cost to government or another taxexempt organization would increase
•The program receives philanthropic support through community
volunteers or contributions
Source: A Guide for Planning & Reporting Community Benefit 2008 Edition
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What is NOT Community Benefit
A program does not count as community benefit, if:

The program is primarily for marketing purposes

A n objective “prudent layperson” would question whether the program
truly benefits the community / The program benefits the organization
more than the community

The program or donation is unrelated to health or the hospital’s mission

The program represents a community benefit provided by another entity
or individual

Access to the program is restricted to individuals affiliated with the
hospital

The activity represents a normal “cost of doing business” or is associated
with the current standard of care
Source: A Guide for Planning & Reporting Community Benefit 2008 Edition
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What Qualifies (Counts) as a Community Benefit?
Charity Care,
at cost
A. Community Health Improvement
B. Health Professions Education
Unreimbursed
Medicaid
Unreimbursed
Costs-other
Means-tested
Government
Programs
C. Subsidized Health Services
D. Research
E. Financial & In-kind Contributions
F. Community Building Activities
G. Community Benefit Operations
Categories A-G
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Questions and Recommendations
Community Health Improvement
Q:
We continue to wrestle with the decision about counting
prenatal education and lactation services in the community…
R:
In most situations, we recommend that prenatal classes
not be reported as community benefit because they are
typically part of a hospital's comprehensive maternity
program, and, while not legally or professionally required, is
the current standard of care.
Source: http://www.chausa.org/Pages/Our_Work/Community_Benefit/What_Counts/What_Counts_Q_and_A/Categories/
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Questions and Recommendations
Community Health Improvement
Q: All babies born in our facility are sent home with hats that are knit by
our volunteers. If parents of limited means request booties, sleepers,
quilts, receiving blankets, etc., we provide the parents with a bag of
needed supplies. All these supplies are donated to us.
Can we report as community benefit our employees' time to support this
program? Our facility is paying the employees for their time.
R: This is a lovely program but since these items are only for your own
patients and are part of the services you provide them, the costs to
support this program should not be reported as community benefit.
Source: http://www.chausa.org/Pages/Our_Work/Community_Benefit/What_Counts/What_Counts_Q_and_A/Categories/
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Questions and Recommendations
Community Health Improvement
Q: When should care management be reported as
community benefit?
R: Visit the “What Counts Q & A” section on CHA’s website
(www.chausa.org) for the complete answer to this and other
questions.
Source: http://www.chausa.org/Pages/Our_Work/Community_Benefit/What_Counts/What_Counts_Q_and_A/Categories/
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Questions and Recommendations
Health Professions Education
Q: Should we report the cost to our organization to train
chaplains? Our Clinical Pastoral Education (CPE) program
receives federal reimbursement for three supervisor positions
in our CPE program.
R: We recommend reporting as community benefit the cost
of the CPE program as long as the students are not required
to work for your organization post training and you offset the
cost of the CPE program with both the federal funds you
receive and student fees. This cost should be reporting in the
category of Health Profession Education.
Source: http://www.chausa.org/Pages/Our_Work/Community_Benefit/What_Counts/What_Counts_Q_and_A/Categories/
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Questions and Recommendations
Cash and In-Kind Contributions
Q: Should we report the expenses for recreational
fundraising events.
R: The task force recommends that organizations consider the following
guidelines when deciding whether to report fundraising costs for golf
outings, galas and other entertainment-oriented events:
•Do not report any costs if the primary purpose of the event is
marketing/public relations.
•Do not report costs related to entertainment aspects (green fees, prizes,
food).
•Report other expenses associated with fundraising, such as staff time, if all of
the proceeds go to community benefit.
•Be very conservative and be sure any expense reported passes the "laugh
test.”
Source: http://www.chausa.org/Pages/Our_Work/Community_Benefit/What_Counts/What_Counts_Q_and_A/Categories/
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Questions and Recommendations
Cash and In-Kind Contributions
Q: Our hospital provides 24/7 telemedicine services to community
hospitals, primarily in EDs, to assist with the evaluation of patients with
symptoms of an acute stroke… There is no charge to the community
hospitals or patients for this service… regardless of their insurance
coverage.
R:
We recommend first carefully analyzing why this program is being
provided… If the primary purpose of the program is to address an
identified community health need, we recommend reporting this as an "in–
kind" contribution ...You are providing the service to other organizations,
not directly to patients, and services to other organizations should be
reported in this category.
Source: http://www.chausa.org/Pages/Our_Work/Community_Benefit/What_Counts/What_Counts_Q_and_A/Categories/
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Questions and Recommendations
Community Building Activities
Q: Our hospital participates in the Volunteer Income Tax Assistance
(V.I.T.A) program with the IRS, a free tax preparation program open to
individuals and their families who earn less than $46,000 a year…
R:
We recommend it be reported as "Community Building" in the
category of "Community Support" . We further recommend that your
organization determine - to the extent possible - the actual cost to the
organization for providing the service, for example, the employees' time if
they participate on paid time. If your employees are not participating on
paid time, then calculate the administrative expenses incurred to
coordinate this activity. We do not recommend reporting what you might
have charged. Community benefit equals actual expense not lost
opportunity costs.
Source: http://www.chausa.org/Pages/Our_Work/Community_Benefit/What_Counts/What_Counts_Q_and_A/Categories/
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Questions and Recommendations
Community Benefit
For the complete questions and answers to these and many
other “what counts” questions, visit CHA’s website
http://www.chausa.org/communitybenefit/
©Lyon Software, 2011
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IRS Requirements:
Form 990 Schedule H
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New IRS Requirement: Form 990 Schedule H
What does Schedule H want to know?
 Programs and Services
•
Community Benefit
•
Community Building
 Policies
•
Charity Care
•
Billing and Collection
•
Assessment
 Other information
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•
Medicare
•
Bad Debt
•
Joint Ventures
•
Facilities
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990H Part I: Community Benefit
IRS Schedule H, 2009 Form
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990H Part II: Community Building
IRS Schedule H, 2009 Form
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IRS Form 990H Part VI: Essays
Part VI questions describe:
 how the organization assesses the health needs
 how the organization informs patients about financial
assistance
 the community the organization serves
 how community building activities promote health of the
communities
 other ways the organization promotes the health of the
community
 (if part of a system) the role of the system and affiliates
in promoting health
©Lyon Software, 2011
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990H Part VI: Essay Questions
IRS Schedule H, 2009 Form
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IRS Form 990 Schedule H: The Team
The three main team members in collecting,
tracking and reporting community benefit:
 Finance
 Community Benefit Professional
 Communicators
©Lyon Software, 2011
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IRS Form 990 Schedule H: Finance
The first 3 lines of Part I, Table 7 – lines 7a through 7c
Charity Care
Medicaid
Other Means-Tested Programs
©Lyon Software, 2011
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IRS Form 990 Schedule H: Finance
CBISA™ Charity Care, Medicaid and Means-Tested Screens
IRS prescribed format
Allows for IRS specified fields such as Medicaid or
provider taxes and uncompensated care pools.
Cost-based: cost accounting or ratio (with IRS
prescribed numerator and denominator)
©Lyon Software, 2011
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IRS Form 990 Schedule H: Finance
Part III
The form itself (Part III) and instructions call for
some limited information on:
Medicare
Bad Debt
They’re not Part I – Community Benefit – but
they are items of interest to the IRS.
©Lyon Software, 2011
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IRS Form 990 Schedule H: CB Professional
Further Information is collected by your
community benefit professionals.
Part I, Table 7, lines 7e through 7j
Part II Community Building Activities
Part VI Questions
©Lyon Software, 2011
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IRS Form 990 Schedule H: CB Professional
Programs
Each program must be qualified as a true community
benefit, using the CHA Guide and the IRS
instructions. (CHA and the IRS are in complete
agreement on these definitions)
There are often 100s of these CB programs in most
hospitals, even CAHs and other smaller hospitals.
©Lyon Software, 2011
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The Team Approach
Hospital staffs will quickly embrace a “team effort” /
“team approach”, for compelling reasons
Coordinators
Senior
Leadership
Board
Members
©Lyon Software, 2011
Reporters
Finance
PR &
Marketing
Tax & Legal
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Three Easy Steps
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Three Easy Steps
1. Create a team
Who should be involved?
2. Identify and account for the Programs currently in
place, assess needs, develop more programs
What counts, what’s needed, and what do you collect?
3. Report to your communities
How do you tell your story and who needs to know?
©Lyon Software, 2011
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Step 2: Qualify & Identify Existing Programs
Collect the Required Data
• Programs
 Titles
 Types
e.g., Charity Care; Health Screenings; Mobile Van
e.g., Charity Care; Medicaid; A – G
 Objectives
e.g., increase access
 Community need
 Target audience(s)
©Lyon Software, 2011
e.g., can’t get to hospital
e.g., disadvantaged
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Step 2: Qualify & Identify Existing Programs
Collect the Required Data
• Statistics
 Number of persons served
 Hospital costs
Staff hours
Supplies
Other direct (if any)
Indirect (if applicable)
 Offsets (program fees, net patient service revenue)
Total Cost – Total Offsets = Net Community Benefit
©Lyon Software, 2011
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Step 3: Tell Your Story
• Tell your story
Through numbers
Through narratives
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Step 3: Tell Your Story
• Results / Outcomes
Can be related to community needs
Can be related to program objectives
Can (usually) be measured (numbers,
ratios, percentages)
Can always be described (anecdotal
outcomes)
©Lyon Software, 2011
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Step 3: Tell Your Story
• Strategies for telling your story
1. Separate community benefit report
2. Community section in the annual report
3. 990 Schedule H
4. Internally
• Bulletin boards
• Newsletters
• Cafeteria table tents, etc
©Lyon Software, 2011
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Resources/Checklists for
Implementing an Effective
Community Benefit Program
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Resources: Implementing a Community Benefit Program
Meeting the Federal Requirements:
 What to report as community benefit
 Community health need assessment
 Implementation strategy
 Financial assistance policies
 Billing and collection policies
©Lyon Software, 2011
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Resources: Implementing a Community Benefit Program
Community Assessment Checklist
 Done at least every 3 years
 Gets input from persons who represent broad
interests of community
 Gets input from persons with special knowledge of
public health
 Is made widely available to the public
 Can be done with/by others
Source: A Guide for Planning & Reporting Community Benefit 2008 Edition
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Resources: Implementing a Community Benefit Program
Implementation Strategy Checklist
 Adopted an implementation strategy to meet needs
found in assessment
 Description of how organization is addressing needs
identified
 Description of any needs not addressed and “reasons
why such need are not being addressed”
Source: A Guide for Planning & Reporting Community Benefit 2008 Edition
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Resources: Implementing a Community Benefit Program
Financial Assistance Policies Checklist
 Criteria for eligibility
 Basis to what is charged patients
 Method for applying for financial assistance
 Measures to “widely publicize” the policy
 Nondiscrimination in emergency care for eligible
persons
Source: A Guide for Planning & Reporting Community Benefit 2008 Edition
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Resources: Implementing a Community Benefit Program
Billing and Collection Checklist
 Limitation on what is charged to persons eligible for
financial assistance
 Prohibition against use of gross charges
 No “extraordinary collection actions” until eligibility
determination
Source: A Guide for Planning & Reporting Community Benefit 2008 Edition
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Resources: Other Organizations
Catholic Health Association
www.chausa.org/communitybenefit
Association for Community Health Improvement (ACHI)
www.communityhlth.org
Source: A Guide for Planning & Reporting Community Benefit 2008 Edition
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Trends in Community Benefit
 Moving from random acts of kindness to
strategic thinking
 Moving from fringe to core business
 Moving from counting to evaluation
 Moving from the basement to the boardroom
 Professionalism, accountability, transparency
Julie Trocchio, Catholic Health Association, 2010
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CBISA Survey™
and
CBISA Online™
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CBISA Online™
Login to CBISA Online™
©Lyon Software, 2011
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CBISA Online™
What’s New: Some Changes to CBISA Online™ in the last 12 months
 Locking and Closing a Fiscal Year
 IRS 990H Enhancements
 Additional fields for IRS Bad Debt screens
 Joint Venture screen
 IRS Multi Reports
 “Memo Only” fields for Restricted gifts/grants/support
 Reporter Enhancements
 “Publishing” feature
 Copying Programs & Occurrences
 Reports & Listing
©Lyon Software, 2011
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CBISA Online™
What’s New: Some Changes to CBISA Online™ in the last 12 months
 Program Enhancements
 “Targeted for” moved to Program/General screen
 Community Benefit Objectives (4)
 CBISA™ Customizations
 Custom Report Generator
 Email Users from the User Control Panel
 “Bring Forward” Department rates
©Lyon Software, 2011
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CBISA Online™
1. Complete your Program and Occurrence information
2. Complete your Financial Services numbers
a) Charity Care
b) Medicaid
c) Other Means Tested
d) IRS Medicare
e) IRS Bad Debt
3. Check the box to send any narratives/stories from the Leadership
Journal
©Lyon Software, 2011
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CBISA Online™
Acknowledge the Snapshot request (ok)
and import any Pending records
Accept the Snapshot request
©Lyon Software, 2011
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CBISA Survey™
Login to CBISA Survey™
using the secure URL and
the User Name and
Password assigned to you
by your State Administrator
https://www.cbisaonline.com/wi_8901_survey
©Lyon Software, 2011
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CBISA Survey™
Choose each Activity in the
Browse Box, then “add” the
Occurrence. “Save” each
new Occurrence.
©Lyon Software, 2011
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CBISA Survey™
“Add” and “Save” each
applicable Financial Service
Record: Charity Care,
Medicaid, Other MeansTested, Medicare, Bad Debt
©Lyon Software, 2011
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CBISA Survey™
=
Let’s you know your Association is requesting
your data
Edit your facility
(Defaults, highlight your
hospital name, click edit)
©Lyon Software, 2011
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CBISA Survey™
Accept the Rollup Request
…and you are done!
©Lyon Software, 2011
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Disclaimer: This webinar presentation
Is not intended to constitute tax advice upon
which your organization should rely. For qualified
advice, consult with a tax professional.
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