Forty-eight of Montana’s fifty-two hospitals are Critical Access Hospitals (CAHs), making them essential to the health of the community and its residents. Being responsive to the health needs in its service area is absolutely vital to CAH. However, an effective response, one that is proactive, timely and also contributes to the health of the facility, can take resources and expertise not readily available within small communities.
To assist CAHs, the Montana Office of Rural Health has been providing a form of its Community Health Services Development (CHSD) program for over two decades. In 2007, this process was revitalized and implemented in nearly 30 communities since that time.
The CHSD Program provides technical assistance to rural communities, with stabilization of health care delivery systems and community health responsiveness as the primary objectives. In most instances, the assistance given has been in the form of conducting community-based surveys, analyzing survey data, presenting survey data to the community and facilitating strategic planning. Delivering services offered through the CHSD Program usually includes a multi-step process including: organization, analysis, plan development, implementation of the plan, governance education and follow-up. The Montana Office of Rural Health has assembled a menu of quality and readily available tools, options for new and secondary data utilization, and best practice strategies to provide community benefit.
The CHSD Program promotes the following as tenets of any strategic plan: (a) health care is a local affair, (b) health care delivered in rural communities is affordable, high quality, and necessary to the good health of the entire community, (c) citizens of rural communities/counties should take responsibility for the health of the community, (d) most communities face a larger number and greater array of issues than usually acknowledged, (e) adequate dollars exist to maintain local health care delivery systems and (f) effective problem-solving by communities is the most important factor to the survival of rural health care services.
New Federal Requirements for Community Health Needs Assessment
The Patient Protection and Affordable Care Act of 2010 (PPACA) set forth new requirements tax-exempt hospitals must follow to maintain their tax-exempt status. Among new requirements, hospitals must: (1) conduct a Community Health Needs Assessment (CHNA) once every three years, (2) adopt an implementation strategy to meet the health needs identified in the CHNA, (3) include input from individuals who represent broad interests of the community served by the hospitals, and (4) make the CHNA widely available to the public. Tax-exempt hospitals are required to complete a CHNA by the last day of their first tax year beginning after March 23, 2012. Additionally, each hospital must develop a prioritized community health needs implementation plan and a summary of and rationale for needs not being addressed Failure to comply may result in a $50,000 excise tax for each year of non-compliance.
Now, in collaboration with the Rural Health Resource Center of Minnesota, the Montana Office of Rural Health has aligned its CHSD process with community health needs assessment (CHNA) for tax-exempt hospitals identified in the Affordable Care Act. Each step within the CHSD process has been linked to specific requirements of the CHNA. The CHSD process is utilized to fulfill these requirements including; community definition, conducting the health needs assessment, documenting the process and results, developing and distributing a community health strategies plan, identifying resources for implementation, implementing the plan, and using process document outputs to report to the IRS.