CHNA Guide
The Community Health Needs Assessment Guide
A working reference for hospital community benefits teams, CHNA consultants, FQHCs, public health departments, and anyone preparing a Community Health Needs Assessment in the 2026-2028 cycle.
This guide is a continuously updated resource for the practitioners who actually do CHNA work. We publish two kinds of content here. Cornerstone references cover the foundational topics every CHNA practitioner has to navigate: the Section 501(r)(3) regulatory framework, methodology selection, data source evaluation, and implementation strategy authoring. Insights articles are deep dives into specific findings from our analytical work across all 3,222 US counties, written for practitioners who want to see what compound signal analysis surfaces in different geographies.
If you have arrived here because you are scoping or writing a CHNA in 2026 or 2027, the cornerstone below labeled “Start here” is the right entry point.
The compliance framework
These references cover the regulatory and methodological foundations every CHNA touches.
Section 501(r)(3) Explained
The IRS requirement, the implementing regulation at 26 CFR § 1.501(r)-3, the Section 4959 penalty, and the operational compliance details.
Implementation Strategy + Form 990 Schedule H Part V-B Coming Q3 2026
The often-overlooked back half of the regulation: how to author an implementation strategy that addresses each significant health need, the May 15 adoption deadline, and the Schedule H Part V-B reporting layer that the IRS actually reviews in audit.
Choosing a CHNA Methodology Coming Q3 2026
The methodology decisions that shape every CHNA: weighted scoring versus convergence detection versus social vulnerability indexing, how to defend methodology choices in audit, and how to align methodology with the IRS regulation's flexible-but-documented standard.
Evaluating Data Sources for Community Health Needs Assessments Coming Q4 2026
A practical framework for assessing federal, state, and commercial data sources for CHNA work: vintage discipline, methodology transparency, source diversification, and how to document data lineage in a way that holds up under regulatory scrutiny.
Methodology and data integrity
The technical foundation of CHNA analytical work. These articles cover how we score communities, how we handle federal data disruptions, and how to build CHNA methodology sections that withstand audit.
How We Score Every US County for Environmental Health Risk
The full methodology behind our four-pillar compound signal scoring across all 3,222 US counties. Environmental Risk, Disease Burden, Provider Gap, SDOH Stress. The pillar weights, the percentile-ranking architecture, and the validation against CDC mortality data.
Building CHNAs That Do Not Break When Datasets Do
A diagnostic on the federal health data landscape entering the 2026-2028 CHNA cycle. PRAMS, EJScreen, the HRSA UDS variables, and what changed. Practical recommendations for methodology sections that survive upstream disruption.
CDC PLACES Is Missing Disease Data for 187 Counties
A specific case study in federal data integrity: how a routine CDC release came in with 187 counties at zero across every health indicator, why it happened, and how downstream CHNA users should respond when source data is operationally degraded.
Compound signal analysis by state and region
We publish state-level and topic-level analyses of compound signal patterns across the United States. These articles are useful for practitioners scoping CHNA work in specific geographies and for benchmarking community profiles against state and regional patterns.
Texas CHNA Data: Four Regions, Four Different Health Stories
Texas has 129 compound signal counties, more than any other state. The four-region clustering (East Texas, Rio Grande Valley, Hill Country, Panhandle) and what it means for CHNA methodology in each region. Within-Texas mortality validation and the behavioral health desert finding.
Featured counties: Cameron · Hidalgo · Jeff Davis
Mississippi: Highest Rate of Converging Health Risks, and Not One Is Environmental
74% of Mississippi counties carry compound signal flags. The pattern is structural Provider Gap and SDOH Stress, not environmental exposure. What this means for CHNA priority-setting in the Delta and across the state.
West Virginia's Health Crisis Isn't About Access. It's About How Sick the Population Is
The mirror image of Mississippi. West Virginia carries the highest Disease Burden in the country with relatively intact provider access. What that signature looks like for CHNA practitioners in Appalachia.
568 US Counties Are at Elevated Heat Health Risk. The Cardiology Gap Is the Story
A topic-level analysis: where heat exposure meets chronic cardiovascular disease meets cardiology provider deserts. The metro finding (large urban counties carry fewer cardiologists per capita than their same-size national peers in elevated heat-risk areas) is the unexpected result.
33.5M Children Breathe Unhealthy Air. 1.5M Live Where the Health System Cannot Help.
A cross-reference of the American Lung Association's State of the Air report against our compound signal data. The 59 convergence counties where ALA air quality failures stack on top of underlying community health vulnerability.
Frequently asked CHNA questions
How often does a nonprofit hospital have to conduct a CHNA?
Every three years. The IRS measures this as the current taxable year plus the two immediately preceding taxable years, and the implementation strategy must be adopted by the 15th day of the fifth month after the end of the year the CHNA was conducted.
What counts as a hospital facility for Section 501(r)(3) purposes?
Any facility that is required by a state to be licensed, registered, or similarly recognized as a hospital. The requirement applies on a facility-by-facility basis, so a hospital organization with four facilities owes four CHNAs every three years, not one.
Can two hospitals collaborate on a single CHNA?
Yes. Joint CHNAs are permitted and encouraged. The underlying analysis can be shared between facilities in the same defined community, but each participating facility must still separately adopt a CHNA report and an implementation strategy.
What is the penalty for failing to conduct a CHNA?
A $50,000 excise tax under Section 4959, applied per noncompliant facility per year. More consequentially, the IRS may revoke the organization's 501(c)(3) tax-exempt status entirely; for a single-facility organization, revocation is the only available remedy.
Does the IRS require a specific CHNA methodology?
No. The regulations are deliberately non-prescriptive about methodology, which gives facilities flexibility to choose an approach appropriate to their community context. The methodology has to be documented in the CHNA report so it is defensible in audit.
Does a CHNA written to satisfy Section 501(r)(3) automatically satisfy state community-benefit requirements?
No. Several states (including Texas, California, Illinois, Massachusetts, New York, and Pennsylvania) layer their own community benefit reporting frameworks on top of the federal CHNA requirement. Methodologies should be aligned so the same underlying analysis can support both.
How Banana Analytics supports CHNA work
The Banana Analytics platform was built to support the analytical core of the Community Health Needs Assessment process. The platform scores all 3,222 US counties and 74,000 census tracts across four dimensions (Environmental Risk, Disease Burden, Provider Gap, SDOH Stress) by fusing CDC PLACES, CDC WONDER, HRSA, NPPES, Census ACS, EPA AQS, FEMA NRI, First Street Foundation, HHS emPOWER, CMS Geographic Variation, and many other federal and commercial sources.
For CHNA practitioners, the workflow looks like:
- Define the community using county selection, attribution file, drive-time isochrone, or state boundary
- Pull a scored profile of that community across all four pillars
- Identify significant health needs in language that maps to the Section 501(r)(3) regulation
- Generate a methodology section with cited data sources and vintages
- Export to PDF or draft narrative for inclusion in the CHNA report
The Professional tier ($99/month) covers compound signals, multi-county comparison, tract-level drill-down, and PDF report generation. The Consultant Studio tier ($299/month) adds the CHNA Canvas authoring workspace with versioned snapshots, AI-drafted CHNA narrative sections that cite the underlying data lineage, and the custom service-area builder. Both Pro tiers include a 14-day free trial.
For organizations that find the licensing cost out of reach for the work they are trying to do, we do conversational licensing. Reach out and we will work something out.
Authoritative sources
For specific compliance and regulatory questions, the underlying authority is the right place to look first. Useful starting points:
- IRS overview of Section 501(r)(3)
- 26 CFR § 1.501(r)-3, the implementing regulation
- Revenue Procedure 2015-21, correction and disclosure procedures
- IRS guidance on Section 4959 excise tax
- Form 990 Schedule H and instructions
For broader community benefits and 501(c)(3) hospital reporting, the Congressional Research Service report “Legal Requirements for Section 501(c)(3) Hospitals” is an authoritative overview.
Stay current with new resources
We publish new CHNA cornerstones and insights articles roughly once every two weeks. The most recent additions show up at the top of the Insights feed.
Banana Analytics is a public benefit corporation building community environmental health intelligence for health systems, public health departments, and community organizations. We are committed to 1% for the Planet. This guide is general reference information and should not be relied on as legal or tax advice; consult your tax counsel for specific compliance questions.