The Centers for Medicare & Medicaid Services (CMS) released a draft guidance for state survey agencies on May 3, 2019, impacting hospitals that share space, staff, and/or services with another co-located hospital or health care entity. The draft builds on informally followed principles by CMS employees which emphasized that certain payment rules, like those for hospitals-within-hospitals, should not override the requirement that every co-located hospital must independently meet Medicare hospital conditions of participation. The final guidance, when released, will provide an authoritative guidance for hospitals with co-location arrangements and result in greater consistency.

To read more on CMS’s draft guidance, please visit