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CMS and Hospital Co-location: Long-Awaited Draft Guidance

Level: Advanced
Runtime: 87 minutes
Recorded Date: June 13, 2019
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Closed Caption


  • What is Hospital Co-location with Hospitals and other Healthcare Facilities?
  • Survey Considerations for co-location?
  • Staffing
  • Contracted Services
  • Distinct Space
  • Shared Space
  • Leased Space
  • Time Share
  • Emergency Services
  • Identification of Deficiencies
  • Key Takeaways
Runtime: 1 hour and 27 minutes
Recorded: June 13, 2019


Many hospitals share a campus or even buildings with other hospitals or health care entities. The health care providers may share space, services, and even staff. Nevertheless, each must also comply independently with the Medicare Conditions of Participation for Hospitals. On May 3, 2019, CMS issued draft guidance on how co-located hospitals can organize shared elements while still demonstrating independent compliance. CMS is asking for comments on the draft by July 2, 2019. Hear from three CMS staff who oversaw development of the draft guidance and from an attorney experienced in representing hospitals.

This program was recorded on June 13th, 2019.

Provided By

American Bar Association
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Lawrence W. Vernaglia

Foley & Lardner, LLP

Lawrence Vernaglia is a partner and health care lawyer with Foley & Lardner LLP where he is the department chair for the firm’s Industry Teams Department, responsible for overall strategy and leadership across all industry teams. Prior to that, he served for 8 years as chair of the firm’s Health Care Industry Team. Lawrence represents hospitals, health systems and academic medical centers and a variety of other health care providers. Lawrence's practice involves regulatory and transactional matters, including Medicare/Medicaid reimbursement compliance advice and appeals; mergers, acquisitions and financings; state regulatory issues including licensing, change of ownership, and CoN/DoN; survey/certification appeals; fraud & abuse/Stark law analyses; managed care contracting; and general corporate and business planning in health care. He runs strategic planning programs for senior management and governing boards.

Lawrence is the past co-chair of the Boston Bar Association's Health Law Committee. He serves on the editorial boards of The Report on Medicare Compliance, JONA's Journal of Healthcare Law, Ethics, & Regulation; and Medicine & Health/Rhode Island. Lawrence is one of nine members of the Medical Economics' Board of Legal Editorial Consultants and for many years, he has been chair of MCLE's comprehensive Health Law Basics program and the advanced Health Law Conference. He is involved with several not-for-profit organizations as a board member and legal advisor. He has been a co-chair of the Health Care Compliance Association’s (HCCN) northeast regional annual meeting for the past decade.

Lawrence earned his J.D. and his master's in public health from Boston University, and his bachelor's degree from New College of Florida.

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Danielle Miller

Nurse Consultant
Centers for Medicare and Medicaid Services

Danielle Miller is a Nurse Consultant at the Centers for Medicare & Medicaid Services.

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