Co-Location of Hospital Space and Space Sharing: CMS Releases Draft Guidance

    View Authors June 2019

    On May 3, 2019, the Centers for Medicare & Medicaid Services (CMS) issued long-awaited draft guidance regarding compliance with the hospital Conditions of Participation at 42 C.F.R. Part 482 (CoPs) and survey procedures for hospitals co-located with other hospitals or healthcare entities (“Draft Guidance”). Co-location is where two hospitals, or a hospital and another healthcare entity, are located on the same campus as, or in the same building used by, another hospital or healthcare facility. The Draft Guidance is intended to provide clarity in the application of previous subregulatory guidance that may have caused confusion for surveyors and providers with respect to properly arranging shared spaces, staffing, contracted services and emergency services in a hospital co-located with another hospital or healthcare entity.