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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Health

Date & Time
  • event Date

    Wednesday, October 2, 2024

  • schedule Time

    1:00 p.m. ET./10:00 a.m. PT

  • timer Program Length

    90 minutes

Credit Information

  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.


  • Live Online


    On Demand

$297.00

This course is $0 with these passes:

CLE
ALL

This CLE webinar will guide healthcare counsel on the Centers for Medicare and Medicaid Services (CMS) guidance for co-location arrangements, discuss the considerations for entering a co-location arrangement and the regulatory hurdles, and offer best practices for structuring and managing compliant arrangements.

Faculty

Sandra M. DiVarco
Partner
McDermott Will & Emery, LLP

Ms. DiVarco focuses her practice on the representation of hospitals and health systems. She counsels healthcare facility and system clients regarding all aspects of health law transactions and health system restructurings. She has a deep knowledge of regulatory, licensing and accreditation issues of particular concern to healthcare providers. She regularly advises clients on the legal aspects of clinical regulatory issues and policy/procedure and operational matters. She is a registered nurse, and holding a current license in Illinois, she brings a pragmatic perspective and first-hand knowledge of health care operations to these complex and mission-critical matters.

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Alison Hollender
Partner
Husch Blackwell LLP

Ms. Hollender focuses on the licensure and certification of healthcare facilities, regulatory compliance and operations, Medicare and Medicaid reimbursement, and corporate healthcare transactions. She work with co-located hospitals. Before joining Husch Blackwell, she worked in the healthcare industry at Cook Children’s Healthcare System in Texas.  

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Description

Hospitals and healthcare providers are entering into co-location arrangements with other entities, such as physician practices and departments of other hospitals, to improve the quality and efficiency of patient care. The CMS issued guidance for ensuring compliance with co-location arrangements in late 2021.

CMS provides guidance on how state surveyors evaluate hospital compliance with Medicare hospital conditions of participation (CoPs) in connection with hospital co-location arrangements with other hospitals and healthcare providers. The guidance removed most examples of compliant and noncompliant co-location arrangements. Instead, the CMS provides general statements that hospitals should ensure that co-location arrangements are compliant.

Further, CMS excluded critical access hospitals and private physician offices from the definition of "healthcare providers" in the context of the guidance. However, CMS was silent about whether this means that co-location arrangements with these entities are prohibited, thereby adding to the uncertainty.

Parties to co-location arrangements must grasp the regulatory requirements in order to continue to participate in the Medicare program and compliantly bill for services. Identifying and addressing potential legal and regulatory hurdles is critical.

Listen as our authoritative panel of healthcare attorneys examines the CMS guidance for co-location arrangements. The panel will also discuss the considerations when entering a co-location arrangement and the regulatory hurdles involved. The panel will offer best practices for structuring and managing compliant arrangements.

Outline

  1. CMS guidance
  2. Regulatory hurdles
  3. Compliance considerations
  4. Best practices
    1. Structuring agreements
    2. Ensuring compliance

Benefits

The panel will review these and other key issues:

  • How does the guidance both clear and muddy the waters for compliance when in co-location arrangements?
  • What informal guidance do the communications of CMS regional offices offer?
  • What steps should counsel and healthcare entities and providers take to ensure compliance?