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The CHA/CHIP Refresh

COMMUNITY HEALTH ASSESSMENT & IMPROVEMENT PLANNING

A full assessment every six years. A lighter, smarter in between.

Stephanie Moxley, MPH · Founder & CEO, Moxley Public Health

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A full CHA/CHIP is a big lift

THE CHALLENGE

Key informant interviews

Scheduling, conducting and analyzing conversations with leaders

Focus groups

Recruiting residents, hosting sessions, transcribing and coding

Full community survey

Designing, translating, promoting and analyzing a long survey

What if every other cycle didn't have to start from scratch?

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Who requires what, and how often

WHAT'S ACTUALLY REQUIRED

Source	Applies to	Timing
IRS Section 501(r)(3) (federal)	Tax-exempt hospitals	CHNA and implementation strategy (CHIP) every 3 years
Ohio Revised Code 3701.981	Boards of health and tax-exempt hospitals	Aligned 3-year cycle set by ODH
PHAB accreditation	Accredited health departments	CHA and CHIP dated within the last 6 years
Federal law for health departments	Local health departments	No statutory cycle; CDC grants often require or encourage a CHA/CHIP

Sources: IRS 501(r)(3) guidance; ORC 3701.981; PHAB Standards & Measures 2026; CDC

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What hospitals must do

HOSPITAL REQUIREMENTS · IRS 501(R)(3)

The CHNA must…

Define the community, including underserved groups
Assess and prioritize health needs
Get input from the health department and underserved residents
Be adopted by the board
Be posted publicly

The implementation strategy (CHIP) must…

Say how each need will be addressed, or why not
Be adopted by the board
Be posted publicly

Due: CHNA by fiscal year-end · Strategy by the 15th of the 5th month after

Ohio: Hospitals must align their CHNA and plan with the local health department.

Source: 26 CFR 1.501(r)-3; ORC 3701.981

Here's what hospitals must do. For the CHNA: define the community they serve, without leaving out medically underserved, low-income or minority residents. Assess and prioritize significant health needs, and list resources available to address them. Get input from at least one governmental health department, that's you, and from underserved, low-income and minority residents or groups that represent them; they also consider written comments on their last CHNA. Write a report that's adopted by an authorized body, usually the board, that includes their methods, how input was gathered, priorities, resources, and an evaluation of what they did since the last CHNA. And make it widely available: posted on their website, with paper copies on request, kept up until two later CHNAs are posted. For the implementation strategy: for each significant need, say how they'll address it, or why they won't. It's adopted by the board, and it's attached to or linked from their Form 990 Schedule H. Due dates follow the hospital's fiscal year: the CHNA by the end of the fiscal year, the implementation strategy by the 15th day of the fifth month after. The penalty for missing these requirements is a $50,000 excise tax per facility. In Ohio, hospitals also have to align with their local health department under ORC 3701.981. In practice, that means collaborating with you on timing and, often, on a shared report.

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Hospital deadlines follow their fiscal year

HOSPITAL DEADLINES (EVERY 3 YEARS)

Fiscal year ends Dec. 31

CHNA due

December 31

+4½ months

Implementation strategy (CHIP) due

May 15

Fiscal year ends June 30

CHNA due

June 30

+4½ months

Implementation strategy (CHIP) due

November 15

"Due" means

Done, approved by the board or CEO, and posted publicly

Verify the dates

Check the tax year on the hospital's Form 990

Sharing a report?

Plan backward from the hospital's deadline

Source: 26 CFR 1.501(r)-3; IRS guidance on Section 501(r)(3)

First, the big picture: hospitals must complete a new CHNA and implementation strategy every three years. Within that three-year cycle, the exact deadlines are tied to the hospital's fiscal year, and this trips people up. Sometimes the hospital knows its dates; surprisingly often, it doesn't. The CHNA has to be done by the last day of the fiscal year it's due in. The implementation strategy, the hospital's version of the CHIP, is due on the 15th day of the fifth month after that fiscal year ends. So a hospital with a December 31 year-end has its CHNA due December 31 and its implementation strategy due May 15. A June 30 year-end means June 30 and November 15. "Due" means the report is complete, adopted by an authorized body, usually the board or the CEO, and publicly available, usually posted on their website. When you build a timeline, verify the fiscal year on the hospital's Form 990; the tax year is at the top of the form. And here's the balancing act: the health department may want its CHA done on its own schedule, but if you're sharing a report with the hospital, the hospital's deadline is the fixed, spelled-out one. Plan backward from it, and build in time for board approval and posting.

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What it looks like in the report

REAL REPORT PAGES

CHNA: health needs ranked in priority order

CHNA: one paragraph on adoption and posting

Strategy: adoption, posting, and needs not addressed

Here's how simple these requirements look in an actual report. On the left, the Fulton County CHNA: the health needs, ranked in priority order from the community survey. That's the prioritized list of significant needs the hospital has to have. In the middle, the Wood County CHNA: one short paragraph saying the report was adopted by the health department and hospital leadership, the month it was made available, the websites where it's posted, and an email address for written comments. That one paragraph covers adoption, posting and the written comment requirement. On the right, the Wood County implementation strategy: again, a paragraph on adoption and where it's posted, and then one paragraph on the health needs that won't be directly addressed and why. It doesn't take pages. These are short, plain statements, but they're what make the report meet the hospital requirements.

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What Ohio asks for

OHIO REQUIREMENTS · ORC 3701.981 AND ODH

Required by law from ODH

Boards of health and tax-exempt hospitals complete assessments and plans on ODH's aligned three-year cycle
Submit the plan and related assessment to ODH every three years

Encouraged by ODH

Collaborate with hospitals, at least county-wide; joint or aligned plans
Align priorities, indicators and strategies with the State Health Improvement Plan
Name priority populations and strategies that reduce disparities

Sources: ORC 3701.981; ODH, Improving Population Health Planning in Ohio; ODH SHIP guidance

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What PHAB asks of health departments

ACCREDITATION REQUIREMENTS · PHAB 2026

Every 6 years: a CHA and CHIP with new data and new community input. That's your full CHA.

The CHA must have…

Partners, and how they worked together
New primary data + 2 secondary sources
At least 4 demographics
Health issues and disparities
Findings actively shared (a website post alone doesn't count)

The CHIP must have…

At least 1 measurable objective for every priority
Activities, timeframes and who's responsible
Assets and resources
A way to track progress
Proof of implementation and revisions with partners

Source: PHAB Standards & Measures for Initial Accreditation and Reaccreditation, 2026 (Measures 1.1.1, 1.1.2, 5.2.1, 5.2.2)

PHAB's 2026 standards, for both initial accreditation and reaccreditation, made two changes that help us. First, the timing: the CHA and CHIP must be updated at least once every six years. And PHAB says this does not require creating an entirely new assessment process; you can keep the same framework, methods and advisory structure, as long as you incorporate current data and meaningful community input. Same for the CHIP: you don't need a brand-new plan, but it has to be updated at least every six years. Second, the requirements are lighter. For the CHA: a list of partners and how they collaborated; primary data, which PHAB defines as newly collected for the CHA, plus secondary data from at least two sources; at least four demographic variables; health issues, and disparities for at least two subpopulations with the factors behind them; and the findings actively shared. That means two examples: one showing you informed organizations, including some outside your CHA partnership, for example an email or presentation summarizing key findings and how to get the full report; and one showing you informed the public, for example a press release, newsletter, social media post or printed summaries at the library. Just posting it on a website doesn't count. For the CHIP: at least one priority, where three to five is typical, and at least one measurable objective for each priority, meaning what you'll achieve, for whom and by when (SMART objectives are recommended, not required); activities with timeframes and who's responsible; assets and resources; a way to track progress; and implementation and revisions. That means two examples of a CHIP activity actually carried out, like a news article, photos or meeting minutes, since a tracking sheet alone isn't enough and the activity doesn't have to be finished; plus one example of revising the CHIP with partners, such as updating an objective, strategy, timeframe or who's responsible after a review. Gone are the minimum partner counts and the required policy recommendations. In practice, that six-year update, with newly collected primary data and meaningful community input, is your full CHA and CHIP. That's why the refresh model does a full assessment every six years: it lines up with PHAB, and the refreshes in between keep you on Ohio's three-year cycle.

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Full every six years, refresh in between

THE REFRESH MODEL · EXAMPLE YEARS

CYCLE 1 · 2025

Full CHA/CHIP

New interviews and/or focus groups
Full survey
All new secondary data

CYCLE 2 · 2028

Refresh

Updated secondary data
2025 primary data cited

Shared with a hospital? Add fresh input

CYCLE 3 · 2031

Full CHA/CHIP

New interviews and/or focus groups
Full survey
All new secondary data

Still on Ohio's aligned three-year calendar. Still a new, dated CHA every cycle.

Here's the model. You stay on Ohio's aligned three-year calendar with your hospital. But you alternate. Cycle one is a full CHA and CHIP: new interviews, focus groups, a full survey, all new secondary data. Cycle two, three years later, is a refresh: we update the secondary data and reference the interviews and focus groups from the previous cycle. If the report is shared with your hospital, add fresh input from the health department and underserved residents, such as a short ranking survey or a partner meeting, because the hospital needs new input for every CHNA. Cycle three is full again. That means the heavy qualitative work happens every six years, and you still produce a new, dated CHA every three years, and the full assessment every six years lines up with PHAB. A refresh works best after you've completed one full CHA, so there's solid qualitative data to build on.

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Full CHA vs. refresh, side by side

THE REFRESH MODEL

Component	Full CHA	Refresh/Updated CHA
Secondary data	Collected and analyzed	Updated with newest releases
Interviews (primary data)	New interviews	Prior cycle's findings referenced
Focus groups (primary data)	New groups	Prior cycle's findings referenced
Community survey (primary data)	Full survey	Short ranking survey, or none
Report	Built from scratch	Same template, updated data and input from health department and underserved residents (can be done by conducting a few interviews…)
Requirements met	PHAB, ODH and hospital	ODH; hospital too if shared

Note: These are common methods, not requirements.

Minimums: PHAB, 1+ primary and 2+ secondary sources. Hospitals, the health department and underserved residents.

Side by side. One note first, especially for anyone newer to this: interviews, focus groups and surveys show up in this table because they're the most common methods, but neither PHAB nor the IRS requires any of them. What's required is primary data for PHAB and community input for the hospital; how you gather it is up to you. And the minimums are small. PHAB requires primary data, with no minimum number of sources, so at least one, plus secondary data from at least two sources, in the CHA updated at least every six years. Hospitals must get input from at least two sources for each CHNA: at least one governmental health department, and members of medically underserved, low-income and minority populations or organizations that represent them. Secondary data is updated either way, because the data changes. The big savings are in the qualitative work and the survey: in a refresh, you don't redo interviews and focus groups; you reference what was collected in the prior cycle, essentially treating it as secondary data. Instead of a full survey, you run a short ranking survey, or no survey at all. The report keeps the same template, so you're updating years, names, data, and rankings rather than writing from scratch. Now look at the last row. The full CHA meets everything: PHAB, ODH and the hospital. The refresh meets ODH's requirement, and it meets the hospital's requirements too if you're sharing the report with your hospital, as long as you add fresh input from the health department and underserved residents. PHAB is covered by your full CHA every six years.

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Can we just update the secondary data?

IN A REFRESH YEAR

HEALTH DEPARTMENT ONLY

Likely yes

Ohio sets timing, not methods. Updated secondary data and report details (cycle years, resources) are likely enough.

SHARED WITH A HOSPITAL

Add fresh input

The hospital needs new input from the health department and underserved residents.

(Easy to get: a few interviews, or one partner meeting)

PHAB

Use your full CHA

A full CHA, done at least every six years, covers PHAB accreditation.

Confirm with ODH and your PHAB accreditation specialist for your situation

This is the question I get most: can we just update the secondary data? It depends on who the report has to satisfy. Health department only, meaning your own report that isn't shared with a hospital: likely yes, because Ohio is the requirement that applies. ORC 3701.981 sets timing and submission, not content. Boards of health complete an assessment and plan on the aligned three-year cycle and submit them to ODH. The law doesn't say what methods the assessment must use, and ODH's guidance doesn't require primary data. So a refresh built on updated secondary data, plus the usual report updates like the new cycle years and current community resources, with the prior interviews, focus groups and survey cited by year, appears to meet Ohio's requirement. Confirm with ODH, since guidance can change. Shared with a hospital: add fresh input. If the refresh is a joint report the hospital also uses as its CHNA, the IRS requires new input for each CHNA, from the health department and from underserved, low-income and minority residents or groups that represent them. Your input is easy, you're at the table. This can be really easy: a few interviews, for example one with the health commissioner and a couple with organizations that serve low-income, minority or underserved residents, or one partner meeting with those organizations. If you do your own separate report, the hospital rules don't apply to you. PHAB: use your full CHA. Under PHAB's 2026 standards, the CHA must be updated at least every six years. A full CHA with new primary data in year zero counts for PHAB until year six, so the year-three refresh doesn't have to meet PHAB at all. One catch: if you submit the refreshed CHA to PHAB as your CHA, it needs newly collected primary data, so submit the full one.

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Many ways to hear from the community

FRESH INPUT, LIGHT LIFT

Health department input

Interview the health commissioner or other staff

Partner ranking meeting

Groups serving underserved residents rank needs

Listening sessions

At food pantries, senior centers, coalitions

Community meeting

Share the data; hear residents' priorities

A few targeted interviews

Reach groups missed last time

Written comments

On the last report and the draft

No specific method is required. Just document who took part and when.

PHAB examples: community meetings, interviews, focus groups, asset mapping, photovoice, surveys

Especially for those of you newer to the CHA and CHIP process: neither PHAB nor the IRS requires interviews, focus groups or a survey. PHAB requires primary data, and hospitals require input from the health department and underserved residents, but how you gather it is up to you. Interviews, focus groups and surveys are just the most common examples. Here are other ways to get fresh input, in a refresh year or any year. Health department input: for the hospital's requirement, the simplest is an interview with the health commissioner, or having the health department on the steering committee of a joint assessment. A partner ranking meeting: invite organizations that serve low-income, minority and medically underserved residents to review the updated data and rank needs together. That one meeting can cover the hospital's underserved-population input and PHAB's partner requirements. Listening sessions at gatherings that already happen, like food pantries, senior centers and coalition meetings. A community meeting where you present the data and capture reactions. A few targeted interviews to fill gaps or reach groups missed last time. And a written comment period on the last report and the draft. Whatever you choose, document who took part, who they represent, and when. These all count as primary data under PHAB's own examples. The short ranking survey is just one more option.

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A short ranking survey (idea for refresh data collection)

NEW PRIMARY DATA, LIGHTER LIFT

About five minutes, phone-friendly
Ranks the same health needs listed in the last full CHA
Adds ZIP code and a few demographics to show who you reached
Shared by partners, at events and by QR code. (Can easily be translated into Spanish or other languages to get input from underserved residents.)

[County] Community Health Survey

1. Which three community conditions most affect health where you live?

Access to healthcare

Transportation

Housing

Access to childcare

Food insecurity

Substance use

Income/poverty

…and the rest of the list

2. Which two health outcomes concern you most?

Mental health

Chronic diseases

Maternal & child health

…and the rest

3. Your ZIP code, age range and a few demographics

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Finding the most significant needs

IDENTIFYING SIGNIFICANT NEEDS

HOW WE DO IT

Residents rank needs on the survey (Wood County, 2025)

OTHER WAYS, NO SURVEY NEEDED

Score the data

Worse than Ohio or the U.S., getting worse, or a disparity

Count mentions

How often a need comes up in interviews or listening sessions

Use a "2 of 3" rule

Stands out in 2 of 3 sources: data, community input, partner judgment

Partners confirm

Steering committee agrees on the ranked list

Hospitals set their own criteria. PHAB doesn't require ranking in the CHA.

Here's how we find the most significant health needs. Residents rank the health needs on the community survey, and then each health need's section shows the secondary data and community input behind it. That's our approach, but it's not the only way, and you don't need a survey to do this well. Many hospital CHNAs never run one. Other ways: Score the data. For each health need, pull a few indicators and give a point when it's worse than Ohio, worse than the U.S. or Healthy People 2030, getting worse over time, or showing a disparity by race, income, age or geography. Average the points by need, and the highest scores are your most significant needs. Count mentions: how often each need comes up in interviews, listening sessions or focus groups, including prior-cycle ones cited by year. Use a two-out-of-three rule: a need is significant if it stands out in at least two of three places, the data, community input, and partner or expert judgment. Then have partners confirm: the steering committee reviews the ranked list and agrees on it, which also counts as partner input. On requirements: hospitals must give a prioritized description of significant needs, but they choose their own criteria, so they just describe the process. PHAB doesn't require ranking in the CHA at all; setting priorities is a CHIP step. And Ohio has no ranking requirement.

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Ideas for wording to cite prior data

HOW THE REPORT SAYS IT

Interviews

“Key informant interviews were conducted in 2025 as part of the 2025 CHNA. Their findings are referenced in this assessment alongside updated data.”

Focus groups

“Focus groups held in 2025 captured residents' experiences. Their themes are carried forward and cited by year.”

Survey

“From the full community survey distributed in 2025… In 2028, a short ranking survey asked residents to rank the same health needs.”

Example wording for a 2028 refresh of a 2025 assessment

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Where the refresh touches the report

UPDATING A REAL REPORT

Acknowledgments

UPDATE

Current partner names

County demographics at-a-glance

UPDATE

Newest census and County Health Rankings, etc.

Key informant interviews

KEEP

Cite as collected in the prior cycle

Focus groups

KEEP

Cite as collected in the prior cycle

Community survey and ranking

KEEP

Cite prior survey, or add a short ranking survey

Health need pages

UPDATE

Newest data; new rank only if surveyed

Quotes and ideas for change

KEEP

Cited as prior-cycle interviews

Report dates and references

UPDATE

New years, sources and data releases

Report sections from the 2025 Fulton and Wood County CHNAs

Here's a map of where a refresh touches a typical report, using the sections in the 2025 Fulton and Wood County reports. Acknowledgments: update partner names. The at-a-glance demographics: newest census and County Health Rankings. Key informant interviews and focus groups: we keep them and simply note they were conducted in the prior cycle. The community survey section can stay as it is, cited as the prior cycle's survey. A new survey isn't required, not even a short one. If you do choose to run a short ranking survey, that's where its results go. Each health need page gets the newest secondary data. That's the only required change. If you ran a ranking survey, you can also add the new rank beside the prior rank at the top. Quotes and community ideas for change stay, cited by year. And we update report dates and references. Same structure, same template. Much less work.

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New date, newest data

REAL PAGES · FRONT OF THE REPORT

1

2

Red = update

1

Year, title and publication date on the cover

2

Every census and county statistic, from the newest release

The layout, icons and structure stay the same.

Left: 2025 Fulton County CHNA, cover. Right: 2025 Wood County CHNA, page 18

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Cite what you have, add what's new

REAL PAGES · DATA COLLECTION

3

4

Red = update

Blue = keep, cite the year

3

Interviews and focus groups stay, noted as collected in the prior cycle

4

Survey section: cite the prior survey, or add new ranking results if you run one

Left: 2025 Fulton County CHNA, page 21. Right: 2025 Wood County CHNA, page 20

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One health need page, marked up

1

2

3

4

5

REAL PAGE · A HEALTH NEED

Update

Keep, cite the year

1

Ranking stays, cited by year; add the new rank if you surveyed

2

Prior full-survey findings, labeled with their year

3

Census figures from the newest release

4

Other local data, like Walk Scores, re-pulled

5

Community quotes, cited as prior-cycle interviews

2025 Fulton County CHNA, page 37

Here's one full health need page, Transportation from the Fulton County report, marked up. Red means update, blue dashed means keep and cite the year. One: the line at the top showing how residents ranked transportation can stay as it is, cited by year. If you ran a ranking survey, add the new rank beside the prior rank. The only required changes on this page are the red ones: the newest data. Two: the findings from the prior full survey stay, labeled with their year. Three: census figures like driving alone, walking, and commute time come from the newest American Community Survey release. Four: other local data like Walk Scores get re-pulled. Five: community quotes stay, cited as interviews from the prior cycle. Multiply that across every health need page and you can see it's real work, but it's nowhere near starting from scratch.

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You already have a CHIP to build on

THE CHIP REFRESH

MEETINGS · VIRTUAL OR IN PERSON

Review the refreshed CHA data and choose priorities with partners (the priorities might stay the same)

UPDATED CHIP

New dates, names, strategies and objectives in the same report

Option A: An outside facilitator runs the meetings and writes the CHIP report

Option B: Health department staff facilitate the decision making meetings and write (or refresh) the CHIP report

The CHIP refresh is flexible; it can work many different ways. The idea is that you're not starting from a blank page. Every health department in Ohio already has a CHIP from the last cycle, and many teams have been through the process before. Even if your staff are new to it, the last plan gives you the structure, the partners and the templates. A typical refresh: one or more meetings, virtual or in person, where partners review the refreshed data and choose priorities, using the same process and templates as last cycle. How many meetings and how they're run is up to you. Then the CHIP report is updated with new dates, names, strategies and objectives. Two common approaches: an outside facilitator runs the meetings, or health department staff facilitate the meetings and write, or simply refresh, the CHIP report themselves. Either way, the CHIP can be a review and light refresh of the last plan, not a new plan from scratch.

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Much of the plan carries forward

1

2

3

4

5

REFRESHING THE IMPROVEMENT PLAN (CHIP)

Update

Keep, confirm with partners

1

Strategy target dates move to the new plan period

2

Action steps: keep what's working, drop what's done, add what annual reviews showed

3

Priority populations, checked against refreshed data

4

Desired outcomes and measures

5

Plan years and partner list

2026–2029 Fulton County IS/CHIP, page 17

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When a refresh fits, and when to go full

CHOOSING THE RIGHT CYCLE

A refresh fits when…

You completed a full CHA/CHIP last cycle
Your community hasn't changed much since
Your hospital partner agrees on the approach
Current priorities still match what you hear

Go full when…

It's your 6-year PHAB update: meet all current PHAB standards and measures for accreditation
Interviews/focus groups are six years old
A major shift hit, like a closure or disaster
Key groups were underrepresented last time
Your service area or partners changed

A refresh isn't right every time. It fits when you completed a full CHA and CHIP in the last cycle, so there's solid qualitative data to reference; when the community hasn't changed dramatically; when your hospital partner is on board; and when your current priorities still match what you're hearing from partners. Go full when it's your six-year update for PHAB accreditation or reaccreditation. That's the one to build around PHAB's current standards and measures, with new primary data and meaningful community input. Also go full when it's been six years since interviews and focus groups; when there's been a major shift like a plant closing, a natural disaster or a big economic change; when key groups were underrepresented last time; or when your service area or partners changed. And always check your accreditation timeline.

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Full every six years.

Refreshed every three.

A new report that meets your requirements, without starting from scratch.

Stephanie Moxley, MPH · stephanie@moxleypublichealth.com · moxleypublichealth.com

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