CMS Issues Guidance on Co-Located Hospitals

The Centers for Medicare & Medicaid Services (CMS) recently released final guidance for evaluation of compliance with Medicare conditions of participation (CoPs) related to shared space and services for hospitals co-located with other hospitals. Co-location occurs when two Medicare-certified hospitals or a Medicare-certified hospital and another healthcare entity are on the same campus or in the same building and share space, staff, or services.

For example, an outpatient department of one hospital is located on the same campus of or in the same building as another hospital or separate Medicare-certified provider, such as an ambulatory surgical center. All co-located hospitals must demonstrate independent compliance with the CoPs.

The long-awaited guidance provides clarification about requirements related to space, contracted services, staffing, and emergency services. For example, CMS specifies that whether employed or contracted, staff providing services in each facility must receive training and education on their facilities’ policies and procedures, undergo periodic evaluation, and adhere to quality and performance improvement standards of the individual hospital.

The final guidance is not as prescriptive as the draft version released on May 3, 2019. But examples in the draft guidance could still be useful when assessing the appropriateness of co-located provider space and staffing arrangements.

CMS notes that, if both facilities use the same space, noncompliance in the surveyed space would be cited for the hospital undergoing the survey and could trigger a complaint in the co-located facility.