New Community Benefit Report Form and Instructions Don't Apply to Investor-Owned or Public Hospitals

April 11, 2022

Memorandum

The Office of Attorney General (OAG) recently posted a revised form and instructions on its website, updating the Non-Profit Hospital Community Benefits Plan Annual Report and Community Benefits Plan Annual Report Instructions. The revised form and instructions are intended to reflect the changes required per Public Act 102-0581. IHA’s summary of the Act and subsequent clarifications can be found here.

IHA believes there are two changes to the form and instructions that may cause confusion to reporting hospitals. Below are the results of a conversation with OAG representatives on the two concerns. IHA has sent a letter asking that this clarification be put in writing.

Report Form/Instruction Changes:

  • Page 1 – Health Systems. The new form includes a Note stating, “A separate report must be filed for each Hosp.” The OAG representatives indicated it does not mean that health systems that include more than one hospital now have to file completely separate forms and information for each of the hospitals in the system.  Rather it means there are some data points that must be supplied at a hospital-specific level (charity cost and financial assistance application data) if the system does not intend to file separate hospital reports.  Health systems may attach that information and put a note on the appropriate lines stating “a separate report for (name) Hospital is attached to this health system report.”
  • Page 2 and Instructions – Financial Assistance. The form adds a new line for financial assistance. Charity care and financial assistance are typically considered interchangeable and charity cost is reported on page 1. However, P.A. 102-058 requires charity care to be reported at a hospital-specific level and also requires data related to financial assistance applications to be reported at a hospital-specific level: applications received (complete and incomplete), applications approved, applications denied and the five most frequent reasons for denial. As indicated above, this hospital-specific information may be reported in an attached document with appropriate notation on the charity and financial assistance lines.

Other Public Reporting:
In addition to the new information required in reports to the OAG, hospitals are also required to make public on their website additional information not required in the OAG reports:

  • Net patient revenue by hospital.
  • Charity provided in the emergency department as a subset of total charity care.
  • To the extent that race, ethnicity, sex or preferred language is collected and available for financial assistance applications, the financial assistance application data reported must be reported by race, ethnicity, sex and preferred language beginning with reports filed on or after July 1, 2022.  If this data is not provided by the patient, the hospital needs to indicate that.  

Contact us with any questions.