Illinois Hospital Association

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August 4, 2004/revised August 2, 2005

 

Community Benefits Reporting in Illinois: Definitions and Standards for Reporting

The Illinois Community Benefits Act (PA 93-0480) was enacted on August 8, 2003 and requires certain non-profit hospitals to file several types of reports with the Attorney General's office, including an annual community benefits report. The legislation outlines ten types of community benefits that must be reported: charity care, language assistant services, government-sponsored indigent health care, donations, volunteers, education, government-sponsored program services, research, subsidized health services and bad debt.

Compliance instructions were issued in February 2004 by the Illinois Attorney General's office that provided broad guidance on types of costs to include in the annual report. But, quantifying the many and varied benefits that a hospital provides is a challenging task. Especially so as many organizations are increasingly complex and provide such diverse benefits to their communities based on the individual community needs. It is therefore unwise to attempt comparisons among hospitals as they are responding to their unique communities in the benefits they provide. It is important for hospitals to maintain consistency from year to year in what types of benefits they are including and if there is a significant change in what is counted, to make a note in the report as to the nature of the change. Also, hospitals that are a part of a system, should maintain consistency across the system as to what types of community benefits are reported.

Catholic Health Association Guidelines and Other States
In the interests of promoting consistency and accuracy among reporting hospitals, the IHA formed a work group to look at the definitions outlined in the legislation and compliance instructions and determine if further guidance could be provided. At the same time (April 2004), the Catholic Health Association (CHA) and the VHA, forerunners in the development of community benefits reporting, issued a document examining this same issue entitled, "Community Benefit Reporting Guidelines and Standard Definitions." The work group reviewed this document and determined it could be used as a reference guide for hospitals in preparing their community benefit reports, except as to where it deviated from required areas contained in the Illinois legislation. They also determined that hospitals could be directed to the resource guide published by the Catholic Health Association entitled "Community Benefit Planning; A Resource for Nonprofit Social Accountability" for developing a community benefit plan and to the reporting software developed by Lyons, Inc. in conjunction with the CHA, which many Illinois hospitals currently use.

It is important to note that in all documents pertaining to community benefit reporting there is an understanding that there is no one way of reporting and no one way to determine what specific services should be included or excluded. The CHA document emphasizes that their guidelines are simply that, guidelines, and that it is perfectly acceptable for organizations to develop their own criteria for community benefits. They also emphasize that their guidelines are fluid and will be revised as a result of ongoing discussion and experience.

The work group examined community benefit reporting definitions from fifteen other states that required or had voluntary reporting requirements. In general, most of these states have very broad definitions similar to that in the Illinois legislation of areas to include in the community benefit report.

The following outlines three specific areas of Illinois community benefit that will differ from the CHA guidelines: language assistance services, volunteers, and bad debt. In addition, Medicare shortfalls are open for debate in the CHA guidelines, while specifically included in the Illinois statute. In conversations with the CHA, it was made clear that their recommendations pertain to a quantitative report by the organization that focuses on intentional services provided as a result of community need. However, they also recommend that hospitals issue a qualitative report that would include other community benefits that better lend themselves to a narrative report, such as the amount of volunteer hours and bad debt. Bad debt reporting is usually associated with a quantitative report and should be included there for Illinois reporting purposes. The CHA report stressed that their guidelines are not intended to preclude a hospital from reporting whatever benefits it determines are justifiable for their community.

Community Benefits: Illinois Specifics
In addition to the information outlined in the above-referenced CHA report, Illinois hospitals need to include the following costs in the annual community benefit report filed with the Illinois Attorney General's office.

Language Assistant Services:
The Illinois law is clear that unreimbursed costs of language assistant services should be included. The compliance instructions require inclusion of costs pertaining to language assistance services such as salaries and benefits of translators, costs of translation services provided via phone and cost of forms, notices and brochures provided in languages other than English, offset by any revenue received for these services.

Volunteers:
Illinois law includes volunteer services and the Attorney General compliance instructions defines this as the value of volunteer time provided by hospital employees and non-employee volunteers to various activities of the hospital and community. The value of such time could be calculated as the number of volunteer hours multiplied by minimum wage for non-employees and hourly wage for employees. Do not count time volunteered by hospital employees that is not on behalf of the hospital or that is during hospital work time. Several other states, such as Utah, Massachusetts and Oregon specifically include non-employee volunteer time.

The hospital is the conduit for such services to be provided to the community. Without the hospital, such volunteer service would likely be lost. Although volunteers provide very valuable services, these services would likely be discontinued if they required employee time. Volunteers provide such appreciated services such as accompanying patients during discharge, locating family members in the facility when there are developments with the patient, conveying test results immediately, delivering flowers and mail, etc. Also, as most of the volunteers are seniors, the volunteer time could also be looked at as a benefit for social interaction.

Bad Debt:
Bad debt is uncollectible charges from those unwilling, as opposed to unable, to pay for services rendered. It is important that hospitals separate bad debt from charity and the compliance instructions quote the AICPA Health Care Audit Guide in differentiating charity and bad debt. Numerous other states such as California, Idaho, Indiana, Oregon and Rhode Island include bad debt in their reported community benefits.

The provision of health care is different from providing other services, in that hospitals, although they may attempt to obtain financial information before service is provided, focus on providing the patient with needed health care and later try to obtain payment. In other industries, the service provider can check the customer's credit rating, ask for payment in advance, etc and is usually asking this information when the consumer is not in a health crisis and under great stress and worry. At a later time, when the provider attempts to collect payment and finds the patient unwilling to pay, their options are again limited given the nature of the service provided and the inability to repossess the service.

Medicare Unreimbursed Cost:
Illinois law defined government-sponsored indigent health care as the unreimbursed cost of Medicare, Medicaid and other federal, State or local indigent health care programs, eligibility for which is based on financial need. This is not contractual allowances, rather costs should be counted if the reimbursement from these programs across all hospital services is below the cost of care provided to patients covered by these programs. Other states, such as California, Idaho, Indiana, Minnesota, Oregon, Texas and Utah require the inclusion of Medicare unreimbursed costs in their community benefit reports.

Conclusion
In the wake of the passage of the Illinois Community Benefit Act, there has been questions from the hospital community regarding what types of benefits should be included in the annual community benefits report. The IHA work group formed to examine this question has determined that a recently released document from the CHA entitled "Community Benefit Reporting Guidelines and Standard Definitions" could be used by hospitals as a guide in developing their hospital-specific reports. In addition to the suggested reporting areas contained in the CHA guidelines, Illinois law mandates the inclusion of language assistance services, bad debt and volunteers, whereas the CHA guidelines suggest these areas might be better addressed in a separate qualitative report.

Hospitals need to keep in mind that these are simply guidelines and hospitals are free to use their own criteria for development of these reports within the outline of Illinois law and the Attorney General's compliance instructions. The Illinois hospital community is varied and complex and their reports will reflect such diversity as they meet the needs of their own local communities.

The IHA Work Group on Hospital Community Benefits urges Illinois hospitals follow these recommendations to be more consistent in reporting as a hospital community. Please feel free to contact Sandy Kraiss at (630)276-5522 or any of the members of the Work Group with questions or suggestions. The Work Group will continue to periodically review these recommendations and welcomes any input to the process.

IHA Work Group on Hospital Community Benefit Members:
Lindsey Artola - Provena Health - (708) 478-6300
Michelle Carrothers - OSF Healthcare System - (309) 655-2850
Elizabeth Lively - Adventist Health System - (630) 856-9000
LuAnn Russell - Memorial Medical Center, Springfield - (217) 788-3000
Valerie White - Advocate Health Care - (630) 572-9393

Attachments:

Staff Contact: Sandy Kraiss: (630) 276-5522