Final CMS guidance says hospitals can share services, space

CMS has released final guidance clarifying how hospitals may organize shared spaces, services and personnel to meet regulatory requirements. 

Five things to know: 

1. The final guidance, released Nov. 12, updates draft guidance released in May 2019. 

2. The final guidance says several types of co-location are acceptable, including when one hospital is entirely located on another hospital's campus, when part of one hospital's inpatient services is in another hospital's building and when one hospital's outpatient department is on the same campus of another hospital. 

3. Services such as laboratory, pharmacy and maintenance may be contracted in a co-located hospital, CMS said. 

4. All co-located hospitals must demonstrate independent compliance with Medicare and Medicaid program participation requirements, CMS said. 

5. The co-location guidance does not apply to critical access hospitals or private physician practices in leased or shared space agreements with hospitals.

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