Due to COVID-19, the IRS is giving tax-exempt hospitals additional time to complete their required Community Health Needs Assessment (CHNA).
Under Notice 2020-56, issued on July 14, 2020, the deadline has been extended until December 31, 2020, for hospitals to comply with CHNA requirements due on or after April 1, 2020, and before December 31, 2020. Previous guidance had extended the due date to July 15, 2020, for CHNA requirements due on or after April 1, 2020, and before July 15, 2020.
Tax-exempt hospitals must conduct a CHNA in either the current tax year or the two preceding tax years and must also adopt an implementation strategy to meet any significant health needs identified in the most recent CHNA.
A CHNA must be completed, adopted by a governing body, and posted publicly by an organization’s year-end in the year in which it is due—generally every three years or less. The implementation strategy must be completed, adopted by a governing body, and posted publicly four and a half months after the year end. Failure to comply with either requirement results in a $50,000 excise tax and could impact a hospital’s tax-exempt status.
Any hospitals using this relief and filing their Form 990 before December 31, 2020, should state in the narrative for Part V, Section C of Schedule H that they’re using the relief in Notice 2020-56 and should not be treated as failing to meet their CHNA requirements.
We’re Here to Help
If you have questions or would like assistance with your CHNA form or implementation strategy, please contact your Moss Adams professional.
For regulatory updates, strategies to help cope with subsequent risk, and possible steps to bolster your workforce and organization, please see the following resources: