The AHA today urged the Department of Treasury to issue guidance clarifying that hospitals are promoting health for the benefit of the community as a whole when they address housing, nutrition, transportation and other social determinants of health. “We urge issuance of formal guidance recognizing what the research demonstrates – that promoting health goes beyond providing medical care,” wrote AHA General Counsel Melinda Reid Hatton. AHA also recommended updating Schedule H to reflect this guidance on social determinants, reduce unnecessary burden and accurately report the full value of community benefit activities. In addition, AHA again asked for clear guidance permitting tax-exempt hospitals to participate in all accountable care organizations that serve their communities, including ACOs that partially or entirely engage with private payers. “Tax-exempt hospitals continue to face significant challenges in structuring ACOs because IRS guidance is limited to [the Medicare Shared Savings Program],” AHA said. “The only other written statement – a nonprecedential redacted denial letter issued to a single organization that applied for a determination of exemption – sent a message that participation outside of an MSSP ACO placed a hospital’s exemption at risk.”

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