Five details:
1. The draft guidance outlines how state surveyors should evaluate how hospitals may share space, clinical services and staff with other facilities. It has significant implications for Medicare and Medicaid billing and reimbursement.
2. If finalized as is, the draft guidance would clarify the definition of “shared space” to prohibit certain arrangements.
3. If a hospital is on the same campus or in the same building as another healthcare entity, it will only be allowed to use public spaces and public pathways used by both, with some exceptions.
4. The draft guidance contains instructions regarding “distinct” versus “shared” space, staff and service contracts, and emergency services.
5. Hospitals and co-located healthcare entities can submit comments on the draft guidance to CMS by July 2.
“The draft guidance could have a substantial impact on hospitals and co-located healthcare entities, especially where an entity desires to lease clinical space from the hospital that is not physically distinct,” said article authors Arthur J. Fried and Sidra S. Zaidi of Epstein Becker & Green.
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