From Hall Render Killian Heath & Lyman PC:
On May 3, 2019, CMS released its long-awaited guidance on hospital co-location and shared service arrangements in the form of a draft survey memo (“Memo”), which is available here. The Memo clarifies how a hospital can co-locate with other health care entities without violating the Medicare Conditions of Participation (“CoPs”). CMS has been promising this guidance since at least 2016, and hospitals have been eagerly awaiting clarity on how they can structure their operations while being compliant with CMS policy.
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