CMS Seeks Comments on Draft Guidance Clarifying Hospital Co-location

PUBLISHED: May 6, 2019
Relevant to: Critical Access Hospitals, Hospitals

The US Centers for Medicare and Medicaid Services (CMS) has released a draft memorandum seeking to provide clarity about how CMS and State Agency surveyors will evaluate a hospital’s space sharing or contracted staff arrangements with another hospital or health care entity when assessing the hospital’s compliance with CMS Condition’s of Participation (CoPs). The agency will accept comment on the draft guidance through July 2, 2019.

According to CMS, increasingly, hospitals have co-located with other hospitals or other healthcare entities as they seek efficiencies and develop different delivery systems of care. 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. All co-located hospitals must demonstrate separate and independent compliance with the hospital CoPs. This guidance clarifies:

  • How shared spaces, services, personnel and emergency services can be organized to allow the hospital to demonstrate independent compliance.
  • That sharing of staff may be done through a contractual arrangement where there are clear lines of authority and accountability.

Additionally, under this guidance, sharing public areas such as entrances and waiting rooms would be permissible. However, due to infection control, patient management, confidentiality, and other quality and safety concerns, the use of shared clinical spaces would be limited.

CMS accept comments through July 2, 2019. See the memorandum to review the proposed guidance and for comment submission instruction.

StayAlert! is monitoring this topic and will publish additional information once the guidance is finalized.

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