Lexology December 16, 2021
In 2019, the Centers for Medicare and Medicaid Services (CMS) issued draft guidance on hospital co-location (when hospitals share space and resources with other health care entities). We previously summarized that draft guidance here. On November 12, 2021, CMS issued its final guidance and — surprise! — it changed quite a bit.
Generally, the changes may create more flexibility for hospitals, but they also create a tremendous amount of confusion and will undoubtedly be applied differently by surveyors across the country. Let’s take a look at the specific changes in the final guidance and what impact they may have.
Health Care Entities/Providers. The draft guidance simply stated that hospitals may co-locate with other hospitals as well as with “other healthcare...
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