CMS issues statement clarifying updated hospital co-location guidance

In response to an AHA request for clarification, the Centers for Medicare & Medicaid Services today released more information to clarify how its recently updated guidance on hospital co-location with other hospitals or health care facilities might apply to critical access hospitals and physician offices. 

“The recently issued hospital co-location guidance from CMS is not applicable to CAHs due to the regulatory requirements that they be at least 35 miles or 15 miles by secondary roads or mountainous terrain from another acute care hospital,” wrote David Wright, director of CMS’s Quality, Safety & Oversight Group. “Therefore, for most CAHs, being co-located with another hospital would not be allowed under the regulations. CAHs with necessary provider status (that do not otherwise have to meet the distance requirements) could co-locate with another hospital and would then be subject to this guidance.

“A Medicare-certified hospital that shares space with physician offices or co-locates with another hospital is responsible for maintaining its compliance with the Medicare Conditions of Participation (CoPs) at all times. There are no specific liabilities attached to either arrangement. If a hospital chooses to enter into a co-location or space sharing arrangement [it] is responsible for evaluating if the arrangement would otherwise risk their compliance with any of the CoPs.

“Compliance surveys of hospitals, whether co-located or sharing space, will be assessed for their compliance with the CoPs. If a space sharing or co-location arrangement results in non-compliance for the hospital, the hospital will be cited and subject to any appropriate enforcement action.”