CHA has submitted comments on the draft guidance on co-location policies for hospitals that share space, staff, or services with another hospital or health care entity, released by the Centers for Medicare & Medicaid Services (CMS).
In the letter, CHA urges CMS to think strategically about how to increase flexibility in distinct and shared spaces in the context of both patient safety and affordability. CHA encourages CMS to consider policies and procedures that address a limited number of shared staff exceptions as outlined in the draft policy that CHA believes are appropriate and continue to prioritize patient safety.
CHA urges CMS to clarify the shift and training requirement for the contracted services and to allow hospitals to contract with a co-located hospital for specialized teams, such as emergency response teams, to best address the needs of its patients.
Additionally, absent a formal rulemaking process, CHA asks CMS to consider a period of education and non-enforcement — at a minimum, one year from release of the guidance — and urges CMS to consider a process similar to the Ligature Risk Extension Request, as well as a limited exceptions process or “grandfathering” of shared space arrangements.
There is no timeline for CMS to finalize this guidance. However, CHA will follow up with CMS via in person meetings to discuss the examples outlined in our letter and urge the agency to quickly make revisions and finalize the guidance.