tci Medicare Compliance & Reimbursement - 2019 Issue 11

Policy: CMS Updates Hospital Co-Location Guidance

Draft argues for more detailed shared-space planning to protect patients. Sharing public areas, services, and staff with other healthcare entities is complicated. New guidance from the Centers for Medicare and Medicaid Services (CMS) reminds providers to keep quality, safety, and Medicare Conditions of Participation (CoP) in mind as they establish compliant arrangements. Definition: “Co-location occurs where two hospitals or a hospital and another healthcare entity are located on the same campus or in the same building and share space, staff, or services,” explain partner attorneys Lawrence W. Vernaglia, Adria Warren, and Judith A. Waltz of national law...

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