The Centers for Medicare & Medicaid Services (CMS) recently released draft guidance on hospital co-location and shared service arrangements, available online. Prior to the draft guidance, hospital co-location was confusing at best, outright prohibited at worst. Co-location occurs where two hospitals or a hospital and another healthcare entity are located on the same campus or in the same building and share space, staff or services. All co-located hospitals must demonstrate separate and independent compliance with Medicare Conditions of Participation. With this draft guidance, CMS is clarifying how shared spaces, services and personnel and emergency services can be organized to allow each hospital to demonstrate independent compliance. CMS is seeking comments on the draft by July 2, 2019. WSHA is now seeking feedback on the draft guidance in anticipation of preparing its own comment letter by June 14, 2019. Hospitals are also encouraged to submit individual comments on the draft guidance.
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