Healthcare organization community benefit and tax-exempt status
- Hospital CHNAs and Implementation Strategies
- Developed CHNA reports for 60+ hospital facilities, most operated by multi-hospital systems
- Prepared CHNA reports:
- For major teaching, children’s, community, critical access, substance abuse, behavioral health, rehabilitation, and long-term acute care hospitals
- For several city-wide collaborations
- Under proposed and final IRS regulations
- Drafted implementation strategies for 25+ hospital facilities to address significant community health needs
- Commented extensively on proposed IRS regulations
- Developed and published 501(r) CHNA final regulations compliance checklist
- Helped Kaiser Permanente consider community health indicators to be assessed by affiliated/owned hospitals
- Present frequently (for the Catholic Health Association and at state and national conferences) on CHNA and implementation strategy preferred practices
- Community benefit accounting and reporting
- Developed the Catholic Health Association’s community benefit accounting guidelines; authored accounting chapter of CHA Guide to Planning and Reporting Community Benefit (1989, 2006, 2008, 2012, 2015, 2017 Update)
- Redesigned CHA’s approach to determining “what counts” as community benefit
- For the IRS, drafted major sections of instructions to IRS Form 990, Schedule H; contributed ongoing advice that led to a number of instructions changes
- Reviewed dozens of Schedule H filings (pre and post submission), identifying opportunities to assure full credit for community benefit work and effective responses throughout
- Helped major health system establish community benefit spending targets based on numerous factors including the value associated with tax-exempt status
- Lead author of two articles in HFMA’s HFM regarding community benefit reporting, one of which received the Helen Yerger/L. Vann Seawell Best Article Award for 2010
- Provided testimony for Oregon Legislature regarding differences between state and federal community benefit reporting guidelines
- Prepared analysis of community benefit reporting by critical access hospitals in Oregon, identifying opportunities for improvement and providing policy recommendations
- Present frequently on community benefit reporting – at basic and advanced levels
- Financial assistance and billing and collections policies
- Contributed substantive revisions to HFMA’s Example Financial Assistance Policy, reviewed by the Principles and Practices Board
- Helped numerous health systems rewrite or edit their policies to assure compliance with 501(r), maximize reportable charity care, and achieve cash flow objectives
- Provided detailed comments on proposed 501(r) regulations regarding financial assistance and billing and collections; advised IRS staff on key provisions
- Helped Maryland develop hospital charity care legislation
- Present frequently on financial assistance-related 501(r) requirements
- Community benefit program assessments
- Reviewed compliance with 501(r) for dozens of hospitals (ranging from critical access hospitals to large, multi-hospital systems and academic medical centers)
- Developed a community benefit strategic plan for a major, Texas multihospital system; the plan included an assessment of the organization’s strengths and weaknesses from a community benefit perspective
- Provided CHNA-related best practices recommendations for a large northeastern academic medical center. Recommendations were provided regarding:
- Community definition,
- Secondary data sources,
- Primary data gathering methods and sources,
- Community involvement in the CHNA and implementation strategy development process,
- Horizontal and vertical collaborations,
- Work plan and budget
- Process for identifying “significant” community health needs
- Process for developing implementation strategies
- CHNA report contents and formats
- Implementation Strategy contents and formats
- How reports are publicized
- Integration of CHNA findings into strategy
- Implementation Strategy monitoring system
- Integration of community benefit throughout the health system
- Helped several health systems quantify the return on investment realized from specific community benefit programs (ROI, Community ROI, and Societal ROI)
- Presented information at national conferences regarding assessing strengths and weaknesses of community benefit programs, and on developing community benefit strategic plans
- Effective program management and governance structures
- Provided recommendations regarding the management, staffing, and governance of a large mid-western health system’s community health and community benefit departments
- Studied and developed recommendations to enhance community benefit program management and governance for several multi-hospital systems, including one that recently merged and requested departmental integration strategies
- Community benefit program strategic plans that integrate population health goals
- Developed and presented approach to community benefit strategic planning at national conferences; approach implemented by several health systems
- Published and presented information regarding: integrating CHNA results into strategy, intersection of population health management and community health improvement, and achieving strategic value from community benefit
- Developed a strategic plan for the Peninsula Health Care District (San Mateo, California)
- Graduate Medical Education
- Supported a university in the launch of a new school of medicine by development of six new GME programs
- Helped a university and three hospitals explore developing a joint pediatrics residency program
- Provided technical support to help transition a vulnerable residency program to a different sponsor
- Projected the financial impact of new residency programs at community hospitals
Financing and delivery of safety-net health services
- Medicaid and public program provider reimbursement methodologies and systems
- Assessed the fairness and equity of hospital Medicaid reimbursement in multiple states, both as part of advocacy efforts and as an expert in litigation
- Assisted Federally Qualified Health Centers (FQHCs) in four states with developing and refining Alternative Payment Methodologies, resulting in materially increased reimbursement consistent with federal law
- Conducted and participated in numerous studies regarding various hospital Medicare reimbursement matters, including the impacts of PPS, design of Medicare Cost Report schedules (including S-10), and related topics
- Conducting financial feasibility, business planning, anti-trust, and strategic studies
- As a component of anti-trust reviews, assessed community benefit impacts associated with mergers
- Developed a Business Plan for the University Medical Center New Orleans
- Assisted the Boone County Hospital Board of Trustees with an assessment of Options for the Future Management and Governance of Boone Hospital Center, including designing and implementing an RFP process and assessing responses
- Helped the Peninsula Health Care District (PHCD) with numerous financial and strategic analyses and with development of a Finance Policy
- Also helped PHCD with developing lease terms for Mills Peninsula Medical Center
- Developed financial models and projections for numerous hospitals and FQHCs
- Prepared community health needs and related information to support decision making regarding the future of an Advocate Health Care hospital
- For the Louisiana Department of Health, analyzed state-wide public health clinic financial and operational data, supporting decisions regarding sites and services
- Helped several hospitals assess collaboration opportunities with FQHCs
- Analyzing provider financial health and performance
- For a foundation, assessed the strengths and weaknesses of an grantee FQHC and provided information to support decision making regarding future grants
- Analyzed and projected financial performance of Boone Hospital Center to support valuation considerations
- Assisted in budget and projections preparation process and ongoing financial oversight, as Treasurer and Board President of Neighborhood Health, an FQHC in Northern Virginia
- Assessing the health impacts of transactions involving hospital assets
- Performed numerous Health Impact Studies for the Office of the California Attorney General, as required prior to hospital transfers of ownership
Litigation support
- Prepared expert reports and provided testimony in multiple court cases involving: challenges to hospital tax-exemption, various aspects of FQHC Medicaid reimbursement, hospital Medicaid reimbursement, and hospital community benefits
- Assessed the fair market value of various health care services including hospital inpatient, hospital outpatient, physician, and ambulance services
- Assessed differences between “top-down” and “bottom-up” methodologies for determining Medicare Practice Expense Relative Value Units
- Estimated the impact of Medicare “site-neutral” payment methodologies on long-term acute care hospitals
For more information about and examples of our work, search Google for:
Verité Healthcare Consulting
Keith Hearle
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