CMS Issues Draft Guidance for Hospital Co-Location

Under the Guidance, CMS provides that the Medicare Conditions of Participation (COPs) allow hospitals to co-locate (i.e., share common areas on the same campus/building) with other hospitals or health care entities as long as each entity demonstrates separate, independent compliance with the COPs. A hospital is required to have distinct spaces, including clinical spaces, over which it maintains control at all times. CMS explains that this is necessary for the protection of patients including their right to privacy and to receive care in a safe environment. Contracted Services:

CMS states that a hospital may provide services under contract with another co-located hospital or health care entity such as laboratory, dietary, pharmacy, maintenance, housekeeping, security, food preparation, delivery services, and utilities (e.g., fire detection and alarm systems). For clinical services provided under contract with a co-located entity, the hospital is not required to notify its patients of all services provided under contract as the services still must be provided under governing body oversight like any other service provided by the hospital.


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