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CMS Issues Draft Guidance on Hospital Co-Location Requirements

May 10, 2019—The Centers for Medicare and Medicaid Services (CMS) May 3 issued draft guidance addressing hospital co-location requirements under the Medicare Conditions of Participation (CoPs). 

Co-location occurs when 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. According to Medicare CoPs, all co-located hospitals must demonstrate separate and independent compliance with the hospital CoPs. The draft guidance seeks to clarify how shared spaces, services, personnel, and emergency services can be organized to allow the hospital to demonstrate independent compliance. 

CMS seeks comments on the draft guidance. Comments are due July 2, 2019. 


Mary Mullaney
Director, Hospital Payment Policies
Telephone: 202-909-2084


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Washington Highlights, a weekly electronic newsletter, features brief updates on the latest legislative and regulatory activities affecting medical schools and teaching hospitals.

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Jason Kleinman
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Telephone: 202-903-0806