CMS has scheduled a June 27, 2019 listening session to get public feedback on its recent draft guidance on how state surveyors should evaluate hospital co-location arrangements for compliance with the Medicare hospital conditions of participation (COPs).  In particular, CMS is looking for input on how the guidance addresses staffing, contracted services, emergency services, and distinct and shared spaces.  The agency is accepting comments and questions in advance of the listening session (note that the comment deadline on the draft guidance is CMS July 2, 2019).  The target audience for the listening session includes hospitals, hospital associations, accreditation organizations, state survey agencies, and other interested stakeholders. For Reed Smith’s analysis of the draft guidance, please see our client alert.