WSHA recently commented on draft guidance on hospital co-location and shared service arrangements by the Centers for Medicare & Medicaid Services (CMS). That draft guidance is available online. Co-location occurs where two hospitals or a hospital and another health care entity are located on the same campus or in the same building and share space, staff or services. WSHA supports co-location and flexible arrangements that increase coordinated, efficient and cost-effective health care, and commended CMS for its move towards explicitly allowing these arrangements.
Our comments concentrated on recommendations that provide increased clarity on how these arrangements may be structured and more nuanced direction around specific issues that would promote rather than hinder flexibility in co-location. Specifically, we recommended greater flexibility around “floating” staff, revisions to the guidance’s section on the provision of emergency services, providing explicit direction about the use of timeshare agreements and co-location arrangements with provider-based clinics, more flexible use of check-in areas and recommendations for implementation including a grandfather clause for co-locations arrangements previously found to be compliant with Medicare Conditions of Participation.