Hospitals can share space and services under the guidance of the final CMS


A hospital can be located on the same property or even in the same building as another hospital, as long as each entity can independently comply with the participation requirements of the medical insurance and medical assistance programs, according to guide The Medicare and Medicaid Service Center announced on Friday.

This policy document provides answers to the questions raised by hospitals over the years and provides them with more leeway than before under federal guidance. This policy also applies to housekeeping, security, laboratories and other services at facilities in the same location.

Mark Howell of American Hospital said: “It provides a lot of instructions, and I think it somehow allows our members to be truly flexible in their approach, as long as they can meet all compliance requirements.” The association is responsible for the hospital. Senior Deputy Director of Standards and Drug Policy.

CMS wrote in the guidelines that hospitals need to consider whether the space used by another hospital located within their premises would jeopardize their medical insurance and Medicaid certification.

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The guide stated that surveyors who inspect a hospital that shares a campus or property with another hospital need to determine mutual space. The hospital under review will be cited for failing to comply with the requirements of the shared space plan, but these incidents may also lead to complaints against hospitals in the same place.

“The surveyor is not expected to assess the co-location space, but to determine whether the hospital under investigation meets the hospital’s participation conditions, independent of its co-location provider,” the guide said.

The final guidelines are less normative than Draft Guidelines Released in May 2019. CMS produced this early version in response to requests from AHA and other agencies that the agency is more aware of its expectations for shared spaces, services, and staff between hospitals. The previous lack of clear federal advice has caused some hospitals to terminate sharing arrangements, which has raised concerns about access to medical services. AHA wrote CMS In 2017.

The 2019 draft guidelines are still more lenient than the previous CMS hosting policy, but still instruct hospitals to have a “clear and unique space” under its control. The clinical space must be separated, and the public space and pathways can be shared between different entities. The draft also includes additional requirements for investigative and shared staff, which were not included in the final guidance.

Lawrence Vernaglia, a partner at Foley & Lardner, stated that hospitals that share space, equipment, staff, or other resources with other facilities in the same location must be prepared to meet Medicare and Medicaid participation requirements.

“They now say that hosting will not be a problem, as long as the certification provider independently manages their requirements under their conditions of participation, which always makes sense to me,” Vernaglia said.

Vernaglia said that since the policy is still in progress, CMS should be tolerant of it.

Vernaglia said the guide did not address key issues. For example, CMS did not specify whether the guidelines are applicable to the practice of doctors co-located with hospitals. The policy is unclear how the agency will distinguish between clinical and non-clinical spaces in hospitals located in the same location. CMS needs to provide more information on how critical access hospitals work with doctor officials.



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