AHA comments on draft guidance on hospital space-sharing arrangements

The Centers for Medicare & Medicaid Services’ proposed guidance for hospital co-location with other hospitals or health care facilities “represents an important update to existing CMS policy,” AHA said today, and urged the agency to consider a series of revisions to enable successful implementation of the policy and promote safer, higher-quality care.
 
“For hospitals, the option and ultimate decision to co-locate is only as meaningful as the benefits both patients and the providers who treat them receive as part of a more streamlined and coordinated process,” AHA wrote. “Failure to provide critical flexibility for these co-located entities significantly hampers the benefits of such arrangements, diminishing the value of co-location, and likely leading to far less utilization of the option to co-locate. For these reasons, we recommend the agency consider a series of revisions and clarification to key components of the guidance. Specifically, we ask CMS to revise provisions related to distinct and shared space, staffing contracts and emergency services. In addition, we request that the agency address a number of co-location possibilities not directly discussed in its draft guidance.”
 
The guidance seeks to clarify how CMS and state surveyors will evaluate space-sharing arrangements for compliance with the Medicare conditions of participation. Prior sub-regulatory interpretations prohibited co-location of hospitals with other health care entities.