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CMS OKs Sharing of Nonclinical Space in Draft Co-Location Guidance

In May 3 draft guidance on co-location, CMS said hospitals may share nonclinical space with another hospital or entity without risking their Medicare certification, but the same isn’t true of clinical space. CMS also said sharing workers is possible if they don’t overlap shifts, according to its Guidance for Hospital Co-location with Other Hospitals or Healthcare Facilities, which looks at co-location through a health and safety prism.

The guidance will be used by surveyors to determine compliance with the Medicare conditions of participation (CoP) for hospitals on sharing spaces, services, personnel and emergency services. In the draft, “you can share common areas, but you can’t share clinical areas,” says attorney Larry Vernaglia, with Foley & Lardner LLP in Boston. Sharing waiting rooms and reception areas with other providers is the primary concern of many hospitals, he explains. “But the guidance hasn’t solved time shares—the ability to have the hospital rent out some clinical space for physicians to use either exclusively or nonexclusively for a period of time,” Vernaglia says.

CMS is asking for feedback on the draft by July 2, so there may be revisions before it’s finalized. “Nobody should make expensive changes to their facility until the final version,” he notes.

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