Implementation Strategy

A hospital’s “Implementation Strategy” is a written plan that addresses each of the community health needs identified in a Community Health Needs Assessment (CHNA). In the Implementation Strategy the hospital describes the needs it will address and identifies those needs it does not intend to address.

The Implementation Strategy is considered complete after it is approved by the hospital’s authorized governing body (e.g., board of directors or trustees, committee of the governing body or others authorized to act on its behalf as permitted by state law). The final IRS rules on CHNAs allow for the Implementation Strategy to be approved on or before the 15th day of the fifth month after the end of the taxable year in which the CHNA was conducted.  For example, if your hospital’s CHNA was approved and posted on line for the fiscal year ending June 30, the Implementation Strategy must be completed and approved before November 15.  A copy of the Implementation Strategy must be attached to Form 990 Schedule H, or the URL where it is posted must be included.

While there is no specific IRS guidance on the process of obtaining public comment on the Implementation Strategy (other than including it in Form 990 filings), the IRS guidance does require input from the public. The IRS guidance notes that hospitals should include written comments on the most recently conducted CHNA and Implementation Strategy. To comply with this requirement a hospital may wish to post the Implementation Strategy on the hospital website with the CHNA and request public comment.  For a checklist of the Implementation Strategy requirements visit:

Post Two Community Health Needs Assessments on Website

The IRS requires your hospital to post two cycles of CHNAs on the hospital website and solicit public comment.  Once you have completed the 2016 CHNA, post it alongside the 2013 CHNA (do not delete the 2013 CHNA).  Going forward you must have two CHNAs posted.  This allows the public to compare community data over time.  Remember to also request community input and provide an email address or phone number for the public to provide you with comments.

The Inaugural Summit on the Social Determinants of Health
Chicago, Illinois | December 5 & 6, 2016

The Inaugural National Summit will engage healthcare executives, physicians, nurses, allied health professionals, economic development experts, community groups, and others in a discussion of social determinants and lead to the development of data-driven, community centered solutions to prevent long-term chronic health conditions in the most vulnerable populations.

The two-day agenda features an array of experts to share best practices, offer community connections and resources, and engage in crucial discussions. The event will feature presentations by Marc Morial, President and CEO, National Urban League; Rick Pollack, President and CEO, American Hospital Association; Donald Hinkle-Brown, President and CEO, Reinvestment Fund; Lisa Marsh Ryerson, President, AARP Foundation; and Randy Oostra, President and CEO, ProMedica. In addition, we’ll be joined by representatives from organizations across the country, including the Center for Health Law and Policy Innovation at Harvard Law, Feeding America, Ascension Health, Blue Cross Blue Shield of Minnesota, Loma Linda University Health, OSF HealthCare, Humana, Advocate Health, St. Joseph Mercy Health System, and UPMC Advantage, among others.

Please visit the registration page for event details as well as hotel information. To learn more about our work, please visit We look forward to working with you to foster discussion, engagement, and collaborative solutions.

Making Food Systems Part of Your Community Health Needs Assessment
Practical Guidance from the Tackling Hunger Project
The community health needs assessments (CHNAs) conducted by nonprofit hospitals present an opportunity to identify and address a broad spectrum of factors that impact health and well-being in local communities. The newly released TACKLING HUNGER CHNA Guidance was developed as a practical guide for hospitals to address an important factor in community health: the community food environment. It provides hospitals with links to external stakeholders and user-friendly tools and strategies, and features practical examples of collaborative partnerships between hospitals and food system stakeholders across the country.  This guidance is a collaboration between the Public Health Institute and members of the Nutrition and Obesity Policy Research Evaluation Network.

Free Webinar

Opportunities to Integrate “Root Cause” Determinants of Community Health in the CHNA Process: Focusing on Food Insecurity

October 26, 9 am PT/12 noon ET

Marydale DeBor, JD
Founder/Managing Director, Fresh Advantage® LLC

Food relates to obesity, diabetes, and other diet sensitive diseases that are ranked among the top priority needs in Community Health Needs Assessments.  When people have limited food resources, it is difficult to eat the specified diet that is necessary for preventing or managing conditions such as diabetes, high blood pressure, and/or obesity.   There are increasing opportunities for hospitals to leverage their limited resources by aligning their efforts with diverse public and private stakeholders who are currently working to address food insecurity at local and regional levels.  Community food security, the food environment and diet-related health measures can be incorporated into the CHNA process and the Implementation Strategy: from secondary and primary data collection, to setting of priority needs, to partnerships at the community level, to models of interventions in health improvement plans.  This webinar will focus on resources and tools that can be incorporated into community benefit initiatives to address food insecurity and improve opportunities for healthy food choices.  Information will be shared from the new guidance – Making Food Systems Part of Your Community Health Needs Assessment: Practical Guidance from the Tackling Hunger Project.

To register for the webinar, log on to the site first and then go to the webinar link.  If you do not have a member log in, you may register for free as a Registered Guest:

Click here to register