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December 10, 2021

CMS Issues Final Guidance Allowing Flexibility for Co-Locating in Hospital Space

This Bulletin is brought to you by the Real Estate Affinity Group of AHLA’s Hospitals and Health Systems Practice Group.
  • December 10, 2021
  • Sandi Krul , Hooper Lundy & Bookman PC
  • Ryan J. Cuthbertson , Hooper Lundy & Bookman PC

On November 12, 2021, nearly two-and-a-half years after releasing draft co-location guidance (Prior Draft Guidance), the Centers for Medicare & Medicaid Services (CMS) released its long awaited final Guidance for Hospital Co-location with Other Hospitals or Healthcare Facilities (Final Guidance). The Final Guidance seeks to clarify how CMS and state surveyors will evaluate sharing of hospital space, services, personnel, and emergency services in compliance with the hospital Medicare Conditions of Participation (Hospital CoPs) and was welcome news to many hospitals and other providers—reversing prior sub-regulatory guidance that prohibited co-location within hospital space.

  • Hospitals and Health Systems
  • Government Reimbursement

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