- CMS issued draft guidance for state survey agencies on the shared use of spaces, services or personnel by different hospitals or a hospital and other healthcare entity.
- The draft guidance, released Friday, aims to ensure such space-sharing arrangements comply with Medicare's conditions of participation while providing flexibility so that organizations can benefit from the efficiencies co-location provides.
- "Prior sub-regulatory interpretations prohibited co-location of hospitals with other health care entities," the draft states. "This guidance changes that to ensure safety and accountability without being overly prescriptive." CMS notes, for example, entities can share public spaces and "paths of travel" such as waiting rooms, public restrooms, elevators, staff lounges and main corridors.
Co-location refers to staff, services or equipment used by separated entities that are located in the same physical space but are not fully integrated with one another. In rural areas, particularly, they can help to increase access to care, streamline referrals and improve care coordination.
The American Hospital Association has repeatedly accused CMS of dragging its feet on setting policy around co-located healthcare facilities. In a September 2017 letter to CMS, AHA lamented the lack of guidance on expectations for use of shared spaces, noting some hospitals were dismantling co-location and shared service arrangements — to the detriment of patients — out of concern they would be found noncompliant with CMS rules.
More recently, AHA urged CMS to clarify its co-location policy as part of a roadmap to rescue rural hospitals and increase access to affordable, high-quality care in the communities they serve.
"We are closely reviewing today's draft guidance from CMS on co-location policies for how hospitals can share space, services and staff with other providers," Nancy Foster, AHA's vice president of quality and patient safety policy, told Healthcare Dive. "The AHA has long urged the agency to prioritize the release of guidance on these issues because confusion and mixed-messages about co-location can result in patients having difficulty accessing needed care."
Foster said AHA's comments will focus on ensuring the final guidance supports a "more coordinated, patient-centered" healthcare system. Comments on the draft are due July 2.
According to CMS, hospitals may be co-located on the same campus or within the same building as another hospital or healthcare entity, either in its entirety or for specific functions and services. However, co-located hospitals and entities should not share spaces where patients receive care. That includes such areas as nursing stations, exam and procedure rooms, outpatient clinics, emergency departments and operating rooms.
At the same time, there may times when the initial assessment and treatment performed in one hospital calls for transferring the patient to a co-located facility for continued care, CMS said.
"For example, a rehabilitation hospital, that is co-located with a separate acute care hospital, must ensure that unit staff are able to recognize and respond to patients that may be having a heart attack, stroke or other emergencies," the draft guidance said. "It is acceptable that the rehabilitation hospital arranges to refer or transfer patients with emergency conditions to the co-located acute care hospital if it cannot provide care beyond initial emergency treatment (e.g. CPR and use of an AED)."
In a Friday tweet, CMS Administrator Seema Verma said the guidance underscores her agency's desire to help hospitals make informed "decisions about how they partner with other providers … to deliver high-quality care."
Hospitals that provide clinical services via an arrangement with another co-located hospital or entity are not required to inform patients of the arrangement if the clinical services are provided under the oversight of the hospital's governing board, according to the document.
Hospitals must also ensure that any contracted staff are properly trained and educated, adhere to the hospital's quality and performance improvement standards, and are held accountable to clinical practice requirements.