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AAMC Submits Comment Letter on Draft Hospital Co-Location Guidance

July 12, 2019

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PRESS CONTACTS
Mary Mullaney, Director, Hospital Payment Policies

The AAMC July 2 submitted a comment letter on the Centers for Medicare and Medicaid Services’ (CMS) draft guidance for hospital co-location with other hospitals and healthcare facilities.

In the draft guidance, CMS seeks to clarify how surveyors will evaluate co-location hospitals’ compliance with Medicare’s Conditions of Participation (CoPs). The AAMC supports CMS’s intent to clarify CoPs for co-located hospitals. However, the AAMC calls on CMS to more clearly define some of the terms used in the draft guidance and not restrict co-hospitals’ ability to utilize staff from the acute care hospital.

The guidance outlines the differences between distinct and shared spaces. CMS seeks to limit traffic through patient care areas. While the AAMC agrees that patient safety and privacy should not be compromised, the decision on the best route to transport a patient should be at the discretion of the host hospital based on considerations such as safety, patient privacy, noise, and volume of traffic.

Under the draft guidance, hospitals would be prohibited to contract for services with a co-located hospital if the contracted staff were also working or on duty simultaneously at the other entity. Specifically, this requirement would limit co-located hospitals from utilizing rapid response or code teams from the acute care hospital. The AAMC’s comments highlight that limiting a co-located hospital’s ability to contract with the acute care hospital for these services would impact patient care.

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