Question: Last year the California Legislature passed SB-1152 — Hospital Patient Discharge Process: Homeless Patients. This law took effect on Jan. 1, 2019, and requires hospitals to implement a set of requirements regarding discharge planning for their homeless patients. We are inquiring as to whether fulfilling the requirements (meals, clothing, transportation, etc.) can be counted as community benefit or should it be considered the cost of doing business since it is now required bylaw?
Recommendation: We recommend that the expense of the items and services be reported as community benefit. We realize that the IRS instructions include language that activities not be reported if they are required for licensure or accreditation. However, this restriction is in the context of excluding programs that are "more beneficial to the organization than to the community." In this situation, it is our opinion that these services to homeless persons are responding to a community health need, enhancing public health and relieving the burden of government to improve health, therefore meeting the definition of reportable community benefits.
It should also be noted that there are some other activities required of hospitals by law that are also reportable as community benefit. These include offering financial assistance/charity care and conducting community health needs assessments.
(Updated March 2019)
Question: When should we report as community health improvement those non billed services (not covered by financial assistance or Medicaid) provided post discharge for our low-income patients?
Recommendation: We recommend that programs and services that assist low-income persons be reported as community health improvement if the primary purpose of the activity is to provide or improve access to needed services and/or to improve their health, so long as other criteria for community benefit are met. (See Chapter 2, A Guide for Planning and Reporting Community Benefit, for example, do not report if the activity benefits the organization more than the community or if the primary purpose is to prevent readmissions to avoid penalties). Take care not to double count, that is, assure that the cost is not already reported as financial assistance (charity care), Medicaid shortfall, or as part of a subsidized health service. For example, do not report as community health improvement any clinic services that are billed and treated as financial assistance.
Examples of services that could be reported in category A3, Community Health Improvement/Health Care Support Services:
- Taxi vouchers and other transportation for patients who otherwise could not afford to access the service.
- Services that support the well-being of low-income patients, such as wigs and other supplies for low-income cancer patients.
- Follow-up and case management services that help patients connect with primary care and other needed services, beyond routine discharge planning.
Examples of services not to report:
(Updated June 2015)
- Services that are part of routine care of all patients.
- Follow-up care that is part of discharge planning or is primarily designed to avoid readmissions penalties or in other ways financially benefit the organization.
- Taxi vouchers and other transportation with a primary purpose to increase revenue for the hospital, such as transporting insured seniors from a community retirement center.
While activities a hospital provides for its patients are not usually reported as community benefit, what about care management to prevent hospitalization and following discharge from acute care? We are establishing a Care Transitions department to strictly monitor our older adult discharged patients (65 and older) and wanted to confirm if the expenses for this department/program can be considered community benefit. Nurse coordinators and health coaches will be assigned to make sure these patients discharged to their homes or assisted living facilities are taking their medications as advised as well as following their doctor's orders so they are not readmitted back to the ER for the same conditions.
Some examples of care management services are:
- Diabetes self-management classes offered without a fee so people (uninsured and insured) will participate.
- Hospitals paying the salaries of nurses to act as a 'health coach' for both uninsured and insured chronic care patients at hospital owned physician practices. They say that patients will not participate if they have to pay for the health coach and currently payer sources don't cover health coaches.
- Hospital paying for hospital employed nurses to monitor Coumadin levels for patients referred by physician practices.
Recommendation: We recommend reporting the following as community benefit:
Report as A3. Health Care Support Services chronic disease/care management services (such as peer counseling, health coaching and educational programs) that meet all of the following criteria:
- Responds to an identified community need
- Is directed to persons who are vulnerable, disadvantaged and face barriers to accessing such health care services
- Goes beyond what is required for accreditation, licensure or the professional standards for discharge planning.
Report as D. Research pilots and demonstration programs to study the quality, effectiveness and cost implications of chronic disease management programs if:
We recommend not reporting as community benefit:
(Updated June 2015)
- Chronic disease/care management services routinely provided to all of the hospital organization's patients (including patients of a hospital-owned physician practice). Chronic disease/care management services when the primary purpose of the program is to benefit the hospital organization, either as marketing or to avoid re-hospitalization penalties.