CMS Publishes Final Co-Location Guidance but Leaves Hospitals Guessing on Expectations for Compliant Arrangements
This Briefing is brought to you by AHLA’s Regulation, Accreditation, and Payment Practice Group.
- February 28, 2022
- Emily Cook , McDermott Will & Emery LLP
- Sandra M. DiVarco , McDermott Will & Emery LLP
- Caroline Reigart , McDermott Will & Emery LLP
- Moyosore Koya , McDermott Will & Emery LLP
On November 12, 2021, the Centers for Medicare & Medicaid Services (CMS) released an updated and final version of a Quality, Safety and Oversight Group (QSO) memorandum, QSO-19-13-Hospital, containing much-anticipated final guidance on how state surveyors are to evaluate hospital compliance with Medicare hospital conditions of participation (CoPs) in connection with hospital co-location arrangements with other hospitals and health care providers (Final Guidance). Co-location arrangements refer to any arrangement under which a hospital or other Medicare-certified entity shares space, services, or staff with a different hospital or another separate health care provider. The Final Guidance contained in QSO-19-13-Hospital may be perceived as providing additional flexibility for co-location arrangements, but upon a close reading, and as confirmed in a subsequent public presentation, CMS indicated continuing concern with how co-location arrangements are implemented.
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