Two Models of LTACH

FREESTANDING LONG TERM CARE HOSPITAL MODEL

An existing freestanding long-term care hospital is an ideal candidate for development if an existing freestanding hospital facility can be designated for use as a long- term care hospital, or, if there is a facility available that can be converted to meet hospital licensure requirements at a reasonable cost.

Although Part 482 Conditions of Participation apply to a freestanding LTACH as well as a hospital-within-a-hospital, hospital-within-a-hospital requirements do not apply to freestanding LTACHs. However, the freestanding LTACH must be treated and governed as any other hospital within the system. In addition, it must have its own CEO and medical staff, as would any other acute care hospital.

If no such facility exists but a floor or a wing of it consists of at least 25 available beds, then the “hospital-within-a-hospital” model becomes a viable option.

THE HOSPITAL-WITHIN-A-HOSPITAL MODEL

The regulations governing the hospital-within-a-hospital are found at 42 CFR § 412.22(e). A hospital-within-a-hospital is defined as a hospital that occupies space in a building also used by another hospital, or in one or more separate buildings located on the same campus used by another hospital. The following criteria apply to hospital-within-hospital models to exclude them from the prospective payment system:

1. Separate governing body — The long-term care hospital must have a governing body that is separate from the host hospital. The long-term care hospital’s governing body may not be under the control of the host hospital or any other third-party entity that controls both hospitals.
2. Separate chief medical officer — The long-term care hospital must have a single chief medical officer who reports directly to the long-term care hospital’s governing body and who is responsible for all the medical staff activities of the hospital. The chief medical officer of the hospital may not be employed by or under contract with either the host hospital or any third-party entity that controls both hospitals.
3. Separate medical staff — The long-term care hospital must have a medical staff that is separate from the medical staff of the host hospital. The long-term care hospital’s medical staff is directly accountable to the governing body for the quality of medical care provided in the hospital; it adopts and enforces by-laws governing medical staff activities, including criteria and procedures for recommending to the governing body the privileges to be granted to individual practitioners.

Chief executive officer — The hospital has a single chief executive officer through whom all administrative authority flows, and who exercises control and surveillance over all administrative activities of the hospital. The chief executive officer may not be employed by, or under contract with, either the host hospital or any third-party entity that controls both hospitals.