CMS' Final Guidance on Hospital Co-Location Arrangements

Time: 2:00-3:30 PM ET

Difficulty: Intermediate

Overview: Over recent years, CMS' policies on hospital co-location arrangements were not written in formal guidance, but were communicated through survey activity and informal guidance. On May 3, 2019, CMS memorialized its policies in subregulatory guidance by publishing draft guidance for hospital co-location arrangements. After more than two years, CMS finalized its guidance on November 12, 2021. The final guidance will be included in CMS' State Operations Manual, Appendix A. In this webinar, CMS officials will discuss the final hospital co-location guidance. This program will compare the final guidance to the May 3, 2019 draft guidance. The program will also address hospital co-location arrangements with physicians. Finally, the program will answer questions about staff sharing and space sharing in hospital co-location arrangements.

Speaker Information:

  • Judith A. Waltz, Partner, Foley & Lardner, LLP
  • Danielle Adams, Centers for Medicare and Medicaid Services

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