The promised CMS guidance for hospitals that share space, staffing, and contract services finally arrived on Friday, May 3rd. CMS published a draft of the guidance as a Quality, Safety & Oversight Group Memorandum. The memorandum includes clarifications on certain prohibitions and new survey procedures that will apply to co-located entities. Although much of the guidance appears to adopt long-standing CMS enforcement policies (e.g., generally no sharing of clinical space), the guidance also leaves many questions unanswered.

Fortunately, CMS issued this guidance in draft form with a 60-day comment period. Advis strongly encourages health entities to submit comments. We recommend discussing the matter in-house to develop questions to be submitted to CMS. The questions should focus on how the guidance would impact different types of entities in various scenarios. Providers need to force CMS’ hand into addressing the outstanding ambiguities. Comments in response to the guidance are due to CMS on July 2, 2019. Advis is available to assist with drafting questions and comments to make certain that the specific aspects of the guidance which directly affect your entity are addressed. 

CMS breaks the guidance into three sections and so do we. Guidance regarding Shared Space and Co-Location; Guidance regarding Contracted Services and Staffing Contracts; and Guidance regarding Emergency Services are detailed below. Fill out our form to the right to receive the full report.

Advis is a national expert in healthcare consulting services.  For more information, please call our office at 708-478-7030 or contact us.