The CHNAudit: Evaluating hospital Community Health Needs Assessments

The CHNAudit Explained

What is a community health needs assessment and how can it improve hospital accountability?

Watch as Senior Policy Analyst Judith Garber digs into this process and discusses a new tool, the CHNAudit, designed to assess how hospitals are doing.

To improve transparency and accountability in the hospital Community Health Needs Assessment (CHNA) process, the Lown Institute created the CHNAudit.

In collaboration with experts from hospitals, academia, policy, and community advocacy, we developed the CHNAudit as a tool to assess hospital alignment with IRS requirements and with best practices identified by specialty organizations, peer-reviewed literature, and members of the CHNAudit working group.

We believe stakeholders can use this tool to improve the CHNA/IS process. Community groups can identify opportunities for partnership and advocacy, hospitals can see how they stack up against their peers and discover ways to improve the CHNA/IS process for greater impact, and policymakers can gain insights into their local hospital’s performance and identify areas for potential oversight or regulation.

Read our article in Health Affairs: “Improving Hospital Accountability And Public Health: The CHNAudit Project,” Health Affairs Forefront, October 16, 2026.

CHNAudit criteria

To conduct a CHNAudit, you will need the most recent Community Health Needs Assessment, Implementation Strategy, and previous cycle Implementation Strategy of the hospital you are evaluating.

CHNAudit Assessment Tool (.xlsx)

Hospitals are evaluated on 52 criteria across four main categories:

Transparency

How well does the hospital make CHNA and community benefit information available and accessible?

Transparency
Accessibility
IRS Requirements	Current and two previous versions of CHNA and IS are published on the website.
Best Practices	All CHNAs/ISs from 2016 onward are published on the website. Executive summary of CHNA/IS is available in additional languages.
Readability
IRS Requirements	n/a
Best Practices	An executive summary is available. Executive summary provides an overview of methods and priority health needs. Executive summary is at a 6th–8th grade reading level.
Contractors used
IRS Requirements	CHNA must identify any parties with whom the hospital facility collaborated or contracted for assistance in conducting the CHNA.
Best Practices	CHNA provides credentials of consultants or contractors.
Regional collaborative
IRS Requirements	CHNA must state if it is a joint collaboration (e.g., conducted with other hospitals or in a regional collaborative).
Best Practices	Hospital acknowledges why they did or did not participate in a joint CHNA/IS. CHNA is done collaboratively with public health department, community organizations, and local health providers (including those not within the hospital’s health system).
Updates on progress
IRS Requirements	n/a
Best Practices	Hospital provides annual updates on progress toward addressing priority health needs. Hospital updates their Implementation Strategy mid-cycle based on community feedback or evaluation of progress (i.e., the IS is a “living document”).

Community Engagement

To what extent does the hospital involve their community in the development of the CHNA/IS?

Community Engagement
Defining the community
IRS Requirements	Community must be defined, and include consideration of people and organizations within some circumscribed geographic area. Hospitals may not exclude medically underserved, low-income, or minority populations or exclude patients based on insurance coverage. Must include description of how the community was determined.
Best Practices	Priority areas and populations extend beyond hospital’s traditional service boundaries in one or more of the following ways: Includes those served by hospital’s community benefit programs, those residing in nearby neighborhoods and other geographic areas, or at-risk populations navigating inequities related to access to adverse social, economic or environmental factors.
Community input methods
IRS Requirements	Methods for taking community input must be described.
Best Practices	Input from both individual community members and group leaders or experts representing specific groups of residents is included. Primary data collection efforts include a qualitative (open-ended) element. Methods for taking community input address equity concerns (for example: soliciting feedback in multiple languages or conducting outreach to underserved community members or groups).
Community resident feedback results
IRS Requirements	Hospital must engage members of medically underserved, low-income, and minority populations in the community served by the hospital facility, or individuals or organizations serving or representing the interests of these populations. Hospital must include written comments received on the hospital’s most recently conducted CHNA/IS.
Best Practices	Hospital provides demographic breakdown of participants in all community input efforts. If a survey is used and described as representative, respondents reflect the racial, ethnic, and economic diversity of the community. If hospital conducted a survey, it oversampled at least one underserved demographic group (e.g., low-income, rural location, racial/ethnic minority). If they conducted focus groups/interviews, they targeted underserved populations for participation.
Group/expert feedback results
IRS Requirements	Hospitals must engage at least one public health department with knowledge, information, or expertise relevant to the health needs of the community.
Best Practices	Hospital engages with other hospitals and health providers, FQHCs, mental health providers. Hospital engages with nonprofit organizations, consumer advocates, housing, transportation, education, faith-based groups, or labor organizations.
Community leadership in the process
IRS Requirements	n/a
Best Practices	Community members/groups are driving the CHNA development process, rather than the hospital or contractor. Community members/groups are driving the IS development process, rather than the hospital or contractor. Hospital has an active community-based and/or patient advisory group involved in the process.

Prioritizing Health Needs

Do the hospital’s identified health needs align with those identified by community members and public health experts?

Prioritizing Health Needs
Identifying and prioritizing health needs
IRS Requirements	Health needs are identified and prioritized. Methods for the process of identifying & prioritizing health needs are available, including a description of the process and criteria used in identifying certain health needs as significant and prioritizing those significant health needs. Method of identifying and prioritizing health needs in CHNA includes community feedback.
Best Practices	n/a
Data sources
IRS Requirements	Hospital described the data and other information used in the assessment, as well as the methods of collecting and analyzing this data and information.
Best Practices	Hospital utilizes both primary and secondary data sources (including public health data collected by government agencies and other authoritative sources). Hospital utilizes indicators for community health (e.g., demographics, SES, access to care, health status, risk factor behaviors). Most indicators are disaggregated by demographics to highlight health issues disproportionately impacting minority groups OR discussion of health disparities demonstrates this data was taken into account.
Health needs chosen to address
IRS Requirements	Hospital’s IS includes for each significant health need identified, either: (1) how they plan to address the health need or (2) why they won’t address the health need.
Best Practices	Among the most significant health needs identified by community members/groups, hospital explains why or why not each were included or not in their final list of priority health needs. Hospital is addressing at least one health need related to “Equity, Racism, Structural Inequality, Health Disparities, or Social Determinants of Health.” Among the most significant health needs identified by public health officials, hospital has included among health needs to address or explains why they are not addressing this need given the importance placed by the public health department. Community members/group feedback is taken into account to determine which health needs the hospital will address. Community members/groups are on the team deciding which health needs the hospital will address.

Accountability

Does the hospital include targets intended to measure program success? How many of these targets are fulfilled?

Accountability
Actions taken to address health needs
IRS Requirements	Hospital describes the actions they intend to take to address the health need in IS and anticipated impact of actions.
Best Practices	At least 80% of actions include at least one measurable target in the IS to measure success. For long-standing community health programs, hospital tracks at least one outcome metric to show potential improvement in community health over time.
Partners, resources, and spending
IRS Requirements	Hospital identifies the resources planned to commit to address the health need, and any planned collaboration between the hospital facility and other facilities or organizations in addressing the health need in IS.
Best Practices	Budget/spending amounts on programs or health needs listed in IS are included (either in IS or subsequent CHNA).
Evaluation of previous actions
IRS Requirements	CHNA must include an evaluation of actions taken in years since previous CHNA.
Best Practices	At least 80% of actions mentioned in the previous IS are included in hospital evaluation in subsequent CHNA. Evaluation in CHNA includes community feedback on progress and how hospital plans to improve in upcoming IS. At least 80% of targets/metrics mentioned in the previous IS are included in hospital evaluation in subsequent CHNA. If target was not achieved, it’s explained why target was not achieved.

Results from large hospital CHNAudits

Where are hospitals succeeding and where is there room for improvement? We looked at 26 nonprofit hospitals operated by the largest health systems by revenue; here’s what we found:

IRS compliance is high. Most hospitals we studied were compliant with IRS requirements, with hospitals completing 91% of these requirements on average. The IRS requirements completed the least often were acknowledging written comments from the previous cycle and publishing the current and two previous CHNAs/ISs on the hospital website.

Room for improvement on best practices. Hospitals completed fewer of the “best practices” criteria compared to those required by the IRS (53% of criteria met on average). The most commonly completed best practices include using public health indicators and offering an executive summary. The least commonly completed best practices were continuity of targets across CHNA cycles and including budget or spending amounts for community health programs.

What hospitals did well. The categories with the highest proportion of criteria met across hospitals were Community Engagement (71% of criteria met, on average) and Prioritizing Health Needs (83%). Hospitals performed especially well on data analysis and community engagement methods such as using both primary and secondary data sources and engaging with a wide variety of community organizations and health providers.

Where hospitals struggled. The categories with the lowest proportion of criteria met across hospitals were Accountability (41% of criteria met, on average) and Transparency (57%). Hospitals struggled with criteria around accessibility, reporting, and community leadership. For example, very few hospitals put community groups in a leadership role in the CHNA/IS process, included measurable targets for all community health programs, or offered documents in multiple languages.

Hospital performance by category

wdt_ID	wdt_created_by	wdt_created_at	wdt_last_edited_by	wdt_last_edited_at	Hospital	Transparency	Community Engagement	Prioritizing Health Needs	Accountability
53	atoleos@lowninstitute.org	15/10/2026 04:03 PM	atoleos@lowninstitute.org	15/10/2026 04:03 PM	AdventHealth Orlando (FL)	69%	69%	77%	40%
54	atoleos@lowninstitute.org	15/10/2026 04:03 PM	atoleos@lowninstitute.org	15/10/2026 04:03 PM	Ascension St. John Medical Center (OK)	62%	75%	77%	70%
55	atoleos@lowninstitute.org	15/10/2026 04:03 PM	atoleos@lowninstitute.org	15/10/2026 04:03 PM	Atrium Health Wake Forest Baptist (NC)	75%	56%	77%	30%
56	atoleos@lowninstitute.org	15/10/2026 04:03 PM	atoleos@lowninstitute.org	15/10/2026 04:03 PM	Banner - University Medical Center Phoenix (AZ)	54%	81%	77%	20%
57	atoleos@lowninstitute.org	15/10/2026 04:03 PM	atoleos@lowninstitute.org	15/10/2026 04:03 PM	Baylor University Medical Center (TX)	50%	56%	77%	30%
58	atoleos@lowninstitute.org	15/10/2026 04:03 PM	atoleos@lowninstitute.org	15/10/2026 04:03 PM	Cedars-Sinai Medical Center (CA)	54%	67%	77%	60%
59	atoleos@lowninstitute.org	15/10/2026 04:03 PM	atoleos@lowninstitute.org	15/10/2026 04:03 PM	Cleveland Clinic Main Campus	46%	63%	92%	30%
60	atoleos@lowninstitute.org	15/10/2026 04:03 PM	atoleos@lowninstitute.org	15/10/2026 04:03 PM	CommonSpirit St. Anthony Hospital (CO)	54%	69%	77%	70%
61	atoleos@lowninstitute.org	15/10/2026 04:03 PM	atoleos@lowninstitute.org	15/10/2026 04:03 PM	Corewell Health William Beaumont University Hospital (MI)	54%	63%	77%	40%
62	atoleos@lowninstitute.org	15/10/2026 04:03 PM	atoleos@lowninstitute.org	15/10/2026 04:03 PM	Hospital of the University of Pennsylvania	62%	75%	92%	40%
63	atoleos@lowninstitute.org	15/10/2026 04:03 PM	atoleos@lowninstitute.org	15/10/2026 04:03 PM	Intermountain Medical Center (UT)	67%	88%	92%	30%
64	atoleos@lowninstitute.org	15/10/2026 04:03 PM	atoleos@lowninstitute.org	15/10/2026 04:03 PM	Kaiser Permanente Oakland Medical Center (CA)	54%	81%	85%	40%
65	atoleos@lowninstitute.org	15/10/2026 04:03 PM	atoleos@lowninstitute.org	15/10/2026 04:03 PM	Loyola University Medical Center (IL)	54%	88%	100%	60%
66	atoleos@lowninstitute.org	15/10/2026 04:03 PM	atoleos@lowninstitute.org	15/10/2026 04:03 PM	Massachusetts General Hospital	75%	88%	92%	30%
67	atoleos@lowninstitute.org	15/10/2026 04:03 PM	atoleos@lowninstitute.org	15/10/2026 04:03 PM	Mayo Clinic Hospital, Saint Marys Campus (MN)	58%	75%	92%	30%
68	atoleos@lowninstitute.org	15/10/2026 04:03 PM	atoleos@lowninstitute.org	15/10/2026 04:03 PM	Mercy Health - St. Vincent Medical Center (OH)	62%	75%	85%	50%
69	atoleos@lowninstitute.org	15/10/2026 04:03 PM	atoleos@lowninstitute.org	15/10/2026 04:03 PM	New York-Presbyterian Hospital	62%	75%	92%	40%
70	atoleos@lowninstitute.org	15/10/2026 04:03 PM	atoleos@lowninstitute.org	15/10/2026 04:03 PM	North Shore University Hospital (NY)	25%	38%	54%	30%
71	atoleos@lowninstitute.org	15/10/2026 04:03 PM	atoleos@lowninstitute.org	15/10/2026 04:03 PM	Providence St. Vincent Medical Center (OR)	69%	94%	85%	50%
72	atoleos@lowninstitute.org	15/10/2026 04:03 PM	atoleos@lowninstitute.org	15/10/2026 04:03 PM	Sentara Norfolk General Hospital (VA)	50%	69%	69%	50%
73	atoleos@lowninstitute.org	15/10/2026 04:03 PM	atoleos@lowninstitute.org	15/10/2026 04:03 PM	SSM Health Saint Louis University Hospital (MO)	46%	69%	77%	30%
74	atoleos@lowninstitute.org	15/10/2026 04:03 PM	atoleos@lowninstitute.org	15/10/2026 04:03 PM	Sutter Medical Center - Sacramento (CA)	54%	81%	92%	30%
75	atoleos@lowninstitute.org	15/10/2026 04:03 PM	atoleos@lowninstitute.org	15/10/2026 04:03 PM	The Johns Hopkins Hospital (MD)	58%	81%	100%	40%
76	atoleos@lowninstitute.org	15/10/2026 04:03 PM	atoleos@lowninstitute.org	15/10/2026 04:03 PM	Tisch Hospital (NY)	67%	75%	100%	60%
77	atoleos@lowninstitute.org	15/10/2026 04:03 PM	atoleos@lowninstitute.org	15/10/2026 04:03 PM	UPMC Presbyterian (PA)	62%	69%	69%	30%
78	atoleos@lowninstitute.org	15/10/2026 04:03 PM	atoleos@lowninstitute.org	15/10/2026 04:03 PM	Wellstar Kennestone Regional Medical Center (GA)	46%	31%	85%	40%

More results

How some hospitals excelled on the CHNAudit

Tisch Hospital (New York) published their executive summary in six languages – Arabic, Bengali, English, Russian, Simplified Chinese, and Spanish.

Providence St. Vincent Medical Center (Oregon) used a community-centered approach, putting their community advisory group in a leadership position in the CHNA development process.

Mercy Health – St. Vincent Medical Center (Ohio) identified specific targets for its health programs and included details acknowledging why certain targets were or were not met.

Room for improvement on the CHNAudit

One hospital did not appear to offer their community feedback survey in multiple languages, despite 20% of their community identifying Spanish as their primary language

At one hospital, only five percent of actions they said they would take to address community health needs had measurable targets

One hospital did not evaluate their actions taken in the years since the previous CHNA.

How can policymakers improve accountability?

Require that hospitals include at least one measurable target for each community benefit program, and report on those actions and targets.

Require hospitals to tie community benefit program spending to specific health needs identified in the CHNA.

Specify hospital community engagement methods for sharing CHNA/IS results and soliciting feedback.

Read our piece in Health Affairs Forefront to learn more about our key takeaways and the potential the CHNA/IS process has to transform community health.

What is a Community Health Needs Assessment (CHNA)?

An IRS code created as part of the Affordable Care Act requires all nonprofit hospitals to conduct CHNAs every three years as a condition of their tax exempt status. They are also required to create an Implementation Strategy (IS) that explains how they will take action to address those needs and improve the health of their community.

CHNAs represent regulatory infrastructure that can have real community impact when done well. But studies show many hospitals fail to meet even basic requirements, such as posting their CHNA and implementation strategy online or soliciting and responding to written public comments. Deeper problems go beyond compliance: data collection often fails to reflect the community’s diversity, and hospitals track program outcomes inconsistently. The result is assessments and strategies that fall short of addressing what communities actually need.

CHNAudit Working Group

Ariel Childs, MPH, Vital CxNs
Ashlyn Burns, PhD, Indiana University School of Medicine
Cory E. Cronin, PhD, College of Health Sciences and Professions, Ohio University
Emma Clippinger, JD, NYC Office of Healthcare Accountability, Department of Health and Mental Hygiene
Lauren Espy, MPH, MLK Community Healthcare
Liz Coyle, BA, Georgia Watch
Melissa Gutierrez Kapheim, PhD, MS, Sinai Urban Health Institute
Michelle Burton, PhD, Rising Communities
Paul Hattis, MD, Lown Institute
Rajika Reed, PhD, MPH, MEd, St. Luke’s University Health Network
Sarah Grabe, MPH, Oregon Health Authority
Tatiane Santos, PhD, MPH, Tulane University Celia Scott Weatherhead School of Public Health and Tropical Medicine

For more information on the CHNAudit, contact jgarber@lowninstitute.org.

For media requests, contact atoleos@lowninstitute.org.

The Lown Institute received support from Arnold Ventures for this project.