Do all hospitals have to publish a community health needs assessment?

No. The requirement in section 501(r)(3) is a condition of tax exemption for hospital organizations recognized under section 501(c)(3), applied facility by facility. A for-profit hospital is outside it. A government hospital that voluntarily gives up its 501(c)(3) recognition is not required to meet the rule in the tax year it terminates.

How often does a hospital update its assessment?

At least every three years. A hospital facility meets the rule for a tax year if it conducted an assessment in that year or either of the two years before it. Older reports must stay available on a website and in paper until two newer reports have been made public, so most hospitals show at least two cycles you can compare.

Can a transportation company comment on a hospital's assessment?

Yes. A hospital must take into account written comments it receives from anyone on its most recently conducted assessment and its most recently adopted implementation strategy, and the next report has to describe how it handled the input it received. Send a short comment to the community benefit office about service gaps you see, with no rider names or health details.

What if a hospital lists transportation as a need but chooses not to address it?

Its implementation strategy has to say so and give a brief reason. Common reasons in IRS guidance include limited resources, other organizations already working on the need, a lack of expertise, or a low priority. When the reason is that someone else is handling it, the organizations named are often the transit agency or county program you should contact next.

Does a hospital-funded ride program have to follow anti-kickback rules?

When the riders include Medicare or Medicaid patients, yes. Free or discounted rides fit the federal local transportation safe harbor only when the hospital applies a set policy uniformly and consistently, does not advertise the rides, pays the cost itself, and does not pay drivers or arrangers per patient carried. Invoice these trips per mile or as a flat fee, never per rider.

Community health needs assessment transportation

What a community health needs assessment commits a hospital to

A community health needs assessment (CHNA) is a public report in which a nonprofit hospital defines the community it serves, identifies its significant health needs, and puts them in priority order. Section 501(r)(3) of the Internal Revenue Code makes it a condition of tax exemption, checked hospital by hospital. Each facility must complete one in the current tax year or one of the two years before it, so a new report appears at least every three years.

The report is half of the duty. An authorized body of the hospital, such as its board, must also adopt an implementation strategy by the 15th day of the fifth month after the end of the tax year in which the assessment was finished. For every significant need, that written plan either describes the actions the hospital intends to take, the resources it plans to commit, and any partners, or names the need as one the hospital will not address and gives the reason. A hospital that fails these steps owes a $50,000 excise tax under section 4959, which it reports on Form 4720.

For a transportation company, the CHNA is a published list of commitments with money and staff behind them. This guide covers reading those documents and turning them into an offer. The paperwork for working with a hospital (supplier packet, insurance, privacy agreement, contract) is in becoming an approved hospital transportation vendor, and the wider facility sales playbook is in NEMT facility contracts.

Where to find a hospital’s report and plan

Start on the hospital’s own website. The IRS requires the CHNA report to be posted on a website and a paper copy to be available for public inspection at the hospital, on request and free of charge. Prior reports stay up until two newer ones are public, so you can usually read two or three cycles side by side. Search the site for “community health needs assessment” or “community benefit”. At Southern Illinois Healthcare, for example, the reports sit in the Giving Back section.

If the search box finds nothing, use the hospital’s Form 990. Schedule H, Part V, Section B asks each hospital facility for the direct web address of its most recent CHNA (line 7a) and of its implementation strategy (line 10a), or whether the strategy is attached to the return instead (line 10b). Line 11 asks the hospital to explain how it is addressing each significant need, and why it is not addressing any it dropped.

A health system may file one report for several campuses. The IRS allows a joint CHNA when the collaborating hospitals define their community the same way, and a joint implementation strategy must still show each hospital’s role and the resources it commits. In a joint plan, look for the table of actions by facility. It tells you which campus has signed up for the transportation work and which has not.

How to tell whether transportation is a real priority

Transportation is a real priority when the implementation strategy gives it an action, a measure, and named partners. A transportation bar in a survey chart, with nothing in the plan, is background.

Read the documents in this order:

The prioritized list of significant needs. The report must describe how needs were judged significant and how they were ranked. Note whether transportation stands alone or sits inside a broader need such as access to care.
The plan entry for that need. Look for specific actions, the anticipated impact, and the resources the hospital says it will commit.
The measures. A metric such as appointments cancelled for lack of a ride is what the hospital will report back to its board, and it is the number your service has to move.
The partners. Transit districts, area agencies on aging, health centers, and Medicaid health plans or brokers listed as collaborators show who already handles the riders.
The reasons for skipping a need. IRS guidance lists acceptable reasons, among them resource limits and other organizations already working on the need. When a hospital says another group has transportation covered, that group is your next call.
The review of the last cycle. Every report must evaluate the impact of the actions taken on the needs found in the previous CHNA, so the newest report shows what the hospital tried and how far it got.

A real plan: Southern Illinois Healthcare’s 2024 assessment

Southern Illinois Healthcare (SIH) shows what a transportation commitment looks like on paper. Its four hospitals (Harrisburg Medical Center, Herrin Hospital, Memorial Hospital of Carbondale, and St. Joseph Memorial Hospital) conducted a joint CHNA in 2024. The SIH Board of Trustees adopted the report on March 27, 2025 and the implementation strategies on July 24, 2025, for fiscal years ending 2025 through 2027.

The priority. SIH chose three needs, and Access to Care (Including Transportation) is listed first. SIH’s website says that priority focuses on non-emergency medical transportation. In the previous cycle, access to care was grouped with hunger, housing, and poverty under social determinants of health.
What the community said. The community survey drew 613 respondents across a seven-county service area, and 90 people answered a separate key stakeholder survey. Stakeholders described limited public transportation, unreliable bus schedules, few ways into Jackson County from outlying counties, and transportation systems that are hard to use without help.
The goal. Goal 5 of the access plan reads “Implement efforts to reduce patient appointment cancellations due to lack of transportation.” Its initiatives are developing better solutions for non-emergency ride needs and educating Medicaid members about their ride benefit.
The measures. The number and percentage of patient appointments cancelled because of transportation, and the number of Medicaid members using their insurance for rides to medical appointments.
The partners. Federally qualified health centers, the Illinois Department of Transportation, four mass transit districts, the Medicaid health plans and their transportation brokers MTM and Modivcare, and the regional metropolitan planning organization, among others.
The reach. The plan’s facility table marks the non-emergency transportation action for all four hospitals.

Read as a ride company, the plan splits into two openings. Medicaid members are being steered toward the broker benefit, so the way to carry them is to be in the broker’s network. The cancellation measure counts every patient, including people whose coverage pays for no routine rides, and those are the trips a hospital might fund itself.

Who controls the budget for the plan

A community benefit or community health department usually runs the implementation strategy, and the report’s acknowledgments name the team. SIH’s report lists the access-to-care strategy team, drawn from its community benefits, population health, mission integration, and patient financial services departments, alongside the county health department, the area agency on aging, a homeless coalition, and other partners. Meet those people first. Purchasing comes in once there is a program to put under contract.

Two lines in the Schedule H instructions shape the pitch:

What the hospital can count. Community health improvement services are activities a hospital subsidizes for the express purpose of improving community health, and they bring in no inpatient or outpatient revenue. Running the CHNA itself and administering community benefit programs are reported as community benefit operations.
What it cannot count. Activities provided primarily for marketing, or designed primarily to increase referrals of patients with third-party coverage, cannot be reported as community benefit. A ride program sold as a way to fill clinics with insured patients describes what the hospital is barred from counting. Frame it as access for the people the assessment named.

Getting into the next assessment

Hospitals must collect input from at least one governmental public health department and from members of medically underserved, low-income, and minority populations, or groups that represent them. They may also gather input from health care providers, community organizations, local officials, businesses, and others. Separately, the hospital must take into account any written comments it receives on its most recent CHNA and implementation strategy.

A transportation company can use both routes:

Comment on the current plan. Send a short letter to the community benefit office describing what you see on the road: trips you turn away, towns with no service, appointment times riders cannot reach. Leave out rider names and anything about a rider’s health.
Get on the invitation list for the next cycle. Ask to be included when the hospital runs its next survey, focus groups, or stakeholder interviews. SIH held its focus groups on May 21, 2024 and its stakeholder interviews from June 4 to June 12, 2024, for a report the board adopted in March 2025, so the conversation starts well before the vote.

What to offer a hospital that named transportation

Match each offer to an action or measure in the plan:

Rides for patients with no ride benefit. Uninsured patients and patients whose coverage includes no routine transportation are the gap other programs leave. The hospital pays you directly under its own policy.
A booking line for clinic schedulers. When the measure is cancellations for lack of a ride, give schedulers one place to book a ride the moment a patient says they cannot get in.
Set runs from the towns the report names. Where the assessment points to distance from specific counties, propose fixed days from those towns to the main campus and its clinics.
Network status with the broker. When the plan relies on the Medicaid ride benefit, being in the broker’s network is how those rides reach you. See NEMT broker contracts.
Numbers for the annual review. Monthly completed rides, no-shows, and on-time pickups by clinic give the community benefit office something to put in front of its board.

If the hospital pays for rides used by Medicare or Medicaid patients, its program must meet the conditions of the federal local transportation safe harbor, and those conditions also set your billing: per mile or a flat amount, never per patient carried. The Anti-Kickback Statute guide covers each condition. Two related plans often sit in the same hospital: readmission follow-up rides and rides paid by the hospital’s value-based care partners.

Reporting back to the hospital with HealthRide

With HealthRide, a hospital’s staff book rides from their own portal and can watch each vehicle on the live map. HealthRide’s reports show completed trips and on-time pickups, the figures a community benefit office needs for its yearly review. Completed rides roll into the hospital’s invoice, which staff can view and pay online.

Community health needs assessments: finding hospitals that have promised to fix transportation