New CMS Hospital Co-Location Guidance in the Spotlight - McDermott

On Location: New CMS Hospital Co-Location Guidance in the Spotlight

Overview



Particularly thorny regulatory issues arise when a hospital shares space, services or staff with another provider. Further complicating matters, the guidance historically provided by the Centers for Medicare and Medicaid Services (CMS) has not always been clear or consistent. Recently, CMS issued new guidance that sheds more light on the subject.

In this session, we’ll offer insights into the current regulatory environment and how it might continue to evolve, including:

  • What’s new in CMS’s November 2021 final guidance on hospital co-location and space-sharing arrangements
  • The most common issues that crop up when external provider services are offered on a hospital’s property
  • How vendor contracts work under co-location agreements
  • Enforcement trends.

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