CMS proposes long-awaited draft guidance on co-located hospitals

On May 3, 2019, the Centers for Medicare & Medicaid Services (CMS) issued draft manual guidance for surveyors evaluating whether hospitals that are co-located with other hospitals (or with other health care entities) meet the Medicare Conditions of Participation (CoPs).

The draft co-location guidance is a long-awaited clarification of CMS's views regarding co-located hospitals' sharing of space and services – which has been an area of growing scrutiny as CMS has increasingly emphasized the need for co-located hospitals to "independently" comply with CoPs. In issuing the new proposed guidance, CMS stated that its objective is to allow some flexibility for co-located hospitals to share common areas and certain services, so long as patient safety and quality of care are adequately protected.

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