Detailed discussion of recent proposed regulations on Community Health Needs Assessments under Section 501(r)

May 2013

Overview

As reported in a prior EOTS NewsFlash, the IRS recently issued proposed regulations on the requirements for tax-exempt hospitals to conduct Community Health Needs Assessments (CHNA) under IRC Section 501(r)(3), as well as certain other aspects of IRC Section 501(r).

These proposed regulations supersede prior guidance on the conduct of CHNAs under IRS Notice 2011-52. However, hospital organizations may continue to rely on Notice 2011-52 for CHNAs completed, and implementation strategies adopted, before October 5, 2013. Organizations that have not yet completed a CHNA or adopted an implementation strategy will have to decide whether to rely on Notice 2011-52 or implement provisions of the proposed regulations.

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