The implication, says Regier, is that eventually these reports will be used by the agency to determine baseline measurements of the cost and benefit of various community benefit programs across the nation—a way to compare and contrast with an idea that some minimum standard might be implemented in future years.
In completing the community health needs assessment and action plan, Regier says, one huge complication has already arisen. Regulations seem to indicate that hospital facilities must satisfy these new obligations on a facility-by-facility basis. That means multi-facility health systems can't use one document for the entire organization—instead, the forms must be filed by each facility.
"It's the place where the IRS could give multi-hospital systems the most heartburn," Regier says. "They want to be able to do one system-wide community health needs assessment. If you require facility-by-facility implementation plans, you may lay on duplicative and unnecessary costs."
Regier says he worries that longer term, the IRS is constrained by the legislation into setting this needs assessment process up in a way that may not move the healthcare system toward the health policy goals of paying for population health management rather than paying for volume.
"The community needs health needs assessment could be a powerful tool on population health management," he says. "But if we set up a system that has the unintentional effect of making hospitals define their community as narrowly as possible, you don't use this tool and you suboptimize its ability to manage population health. At the same time, the IRS has to live with the statutory language they've got."