A guide to common questions directly related to use of the CBI tool.
What is the source of CBI data?
Data are imported directly from Hospital IRS Schedule H, 990 forms. Supplementary data sources are used to provide information on hospital name, system affiliations, etc. While data may be visually presented in different ways, the data utilized will be exactly as it is submitted by the hospitals. See the exact data acquisition and matching process here.
Note: In the case that any errors may occur due to hospital misreporting, there are no retroactive changes made to the data on CBI. This ensures integrity in the data presented.
When can we expect more recent data to be posted on CBI?
Currently, the time from the end of a tax-exempt hospital’s tax period to when their return is made publicly available is about 16 months. Hospitals have a five-month window from the end of their tax year to submit taxes to the IRS, and additionally an optional six-month extension to re-submit their returns. Read more about the IRS reporting timeline here.
As 2015 tax years can end in calendar year 2016, this results in some returns not being made available until late 2017 and into early 2018. Once the majority of electronically submitted tax returns for 2015 are available, they will be processed and made available on CBI, approximately spring 2018. Tax year 2016 data availability will be actively monitored and once determined to be approximately 50% complete, these data will be processed and added to CBI (estimated fall 2018). The remainder of the tax year 2016 data will be processed and added to CBI in approximately spring 2019. Processing of tax year 2017 will follow a similar methodology.
Can I download CBI data?
The CBI tool has an Application Programming Interface (API) feature and multiple hospital data can be downloaded into a spreadsheet. The API can be used to download raw hospital data, organized in whichever way is most meaningful in meeting the user’s needs. Data can be downloaded to a JSON file and then converted to Excel. Please find further directions on how to download this data, here.
What is the difference between reporting as a hospital or as a health system?
A hospital can operate as an individual entity or as part of a multi-facility organization, or system. Oftentimes, hospitals belonging to a system will file group returns, aggregating their data in one 990. On CBI, those reporting in aggregate totals for multiple facilities are indicated with an orange asterisk. The group with whom it “files in aggregate with”, can also be seen. Typically, this group is either the entire hospital system or a subset of hospitals that file under a single EIN within that larger system. It is important to note that when hospitals report in aggregate, the figures do not reflect particular community benefit activities for that specific hospital. While it is common for hospitals within a system to file a group return, many do not.
A formula to gain better insight of the hospital community benefit spending for those filed in aggregate is underway. Reach out to the CBI team to discuss data for any particular hospital filed in aggregate or the CACHE team for assistance in interpretation.
Why can’t I find my hospital on CBI?
Hospitals are reported under the name they file to the IRS, which may be different than how the hospital is branded or commonly known to the community at large. The hospital’s website may provide the right combination of keywords to identify the filing name hospitals file under in order to find it on CBI.
There are a number of reasons you may not find a hospital, including, but not limited to the following reasons:
- Since the most recent CBI data update, the hospital has changed its name. The hospital may still be listed under their previous name in the CBI tool.
- Since the most recent CBI data update, the hospital has changed ownership. The hospital may still be listed within their previous owner’s name. If the previous owner was NOT a tax-exempt 501(c)3 entity, they may not have been required to file a Schedule H and will not be included in the CBI tool until their first Schedule H is reported and data made available.
- The hospital is jointly owned. If the joint owner is NOT a tax-exempt 501(c)3 entity, they may not be required to report community benefit expenditures.
- The facility is filed within another hospital. Oftentimes children’s hospitals and women’s hospitals will be affiliated with a larger hospital and file within their IRS 990. This means there will only be one IRS 990 and those hospitals will be listed as facilities within that report.
CBI Data Interpretation
Common questions for interpreting community benefit financials.
The 990H does not provide a complete picture of how tax-exempt hospitals fulfill their charitable obligations. Hospitals may undertake a other activities and/or make resource allocations that are not captured in their 990H reporting, due to an oversight in documentation, an internal decision not to report the activity(ies), and/or a judgment that the total of expenditures currently reported meet expected financial thresholds aligned with tax-exempt obligations, and additional documentation is unnecessary. There are, for example, a growing number of hospitals and health systems which allocate a portion of their investment portfolio in the form of low (1-2%) or no interest loans to support community development investments such as affordable housing, grocery stores, and small business development in low income communities. They do not report these important contributions to build health and well-being in their communities as part of their 990H documentation.
CBI should be viewed as a starting point for thoughtful inquiry and engagement of nonprofit hospitals into how to support the optimal allocation of charitable resources to improve health and well-being in local communities. Inquiries should also be conducted into the contributions of both public and private sector stakeholders in the health, social services, and community development arenas, with a focus on the alignment and focus of resources in communities where health inequities are concentrated.
How do hospitals determine what can be reported in the 990H?
Hospitals are provided criteria for determining what to report in their 990H instructions, but it should be noted that there is considerable room for interpretation. While the general expectation is that fulfillment of nonprofit hospital charitable obligations as tax-exempt institutions would suggest that services and activities would focus on populations who are uninsured, underinsured, and/or in some way economically and/or socially disadvantaged, there are no definitive parameters provided by the federal government. As a result, there could be substantial differences in the totals reported by two different hospitals delivering the same configuration of services and activities. The leadership of one of those hospitals may, for example, determine that they don’t want to count services such as patient education classes that also benefit commercially insured populations, or services that have a positive return on investment (e.g., home visits that yield a reduction in preventable ED and inpatient utilization). In the absence of further criteria, it is important to take into consideration that comparative analyses yield results that are approximations subject to interpretation.
What does a negative number in the reporting financials indicate?
Following IRS guidelines, the “Net Community Benefit Expense” and the “Percent of Total Expense” should not be reported as negative numbers in the IRS 990 Schedule H. If the amount is negative, it should be entered as 0. If you see a negative number reported, it is a reporting error.
My hospital is part of a health system. What does that mean for its reporting?
A hospital belonging to a multi-facility system may report to the IRS as part of a group, filing their 990s with other hospitals in the system. On CBI, those reporting in aggregate will be indicated with an orange asterisk. The group with whom it “files in aggregate with” can also be seen. Depending on how large or geographically expansive the system is, they may even report within subgroups based on proximity or prior system affiliations. It is important to note that when hospitals report in aggregate, the figures do not reflect particular community benefit activities for that specific hospital. While common, many systems do not file in aggregate.
How can I learn more about what is being done with these CB resources?
Tax-exempt hospitals are required to perform Community Health Needs Assessments (CHNA) at least once every three years. They must then adopt an Implementation Strategy to meet the community health needs identified in the CHNA by the end of the taxable year in which the CHNA was conducted. (LINK to CHNA and Implementation Strategy IRS requirements) On CBI, the “Supplemental Information” section will include any qualitative information submitted by the hospital on the 990H in regard to their CHNA and community benefit activities.
In general, the CHNA must:
- Include the process and methods used to conduct the CHNA
- Define their community served
- Assess community health needs
- Include input from persons who represent the broad interest of the community served
- Be performed individually or as a joint effort
- Be made widely available to the public
In general, the Implementation Strategy must:
- Describe how the hospital plans to address a significant health need
- Describe why the hospital is not addressing a significant health need
I think I’ve identified discrepancies or inaccuracies in my hospital’s data.
Why could this be and what can I do to get it corrected?
A great deal of effort was made to ensure that CBI reflect exactly what was reported by hospitals in their 990H, but due to the complexity of the data and reporting processes, additional adjustments may be needed. By providing these FAQs, we aim to provide clear communication of the appropriate caveats for data users and supporting information that minimizes potential for misinterpretation. If you have questions regarding the data reported on CBI, please contact us here and we will be more than happy to review and discuss the data.
How is Hospital “similarity” determined in CBI?
This content coming soon.
Teaching Hospitals and 2013 Adjustments in Reporting Requirements
Users may observe a substantial reduction in the community benefits totals reported by teaching hospitals beginning in 2013 that is a function of a change in IRS requirements. For 2013 and beyond, teaching hospitals are not permitted to include contributions secured from outside sources (e.g., NIH, private philanthropy) that are explicitly designated for research purposes (they are, however, permitted to report internal costs accrued in carrying out those activities). In most cases, these institutions were not able to sufficiently “ramp up” other charitable expenditures within the time period to compensate for the reductions demanded by the change in reporting requirements.