Structuring Healthcare Co-Location Arrangements: Legal and Regulatory Requirements

Under pressure to improve the quality and efficiency of patient care while cutting costs, hospitals and other healthcare providers are turning to co-location arrangements with other entities such as ambulatory surgery centers, radiology departments and outpatient rehab facilities.

These arrangements offer many benefits, including reduced overhead costs, increased convenience to patients, and enhanced continuity of care. However, these same arrangements can also put hospitals’ payments and status as a Medicare provider at risk. Parties to co-location arrangements must grasp the regulatory requirements to bill Medicare and maintain billing privileges.

With little formal guidance from CMS, healthcare counsel must rely on letters and other informal communications from CMS regional offices to identify and address the potential legal and regulatory hurdles facing parties to co-location arrangements.

Listen as our authoritative panel of healthcare attorneys examines the steps providers and counsel should take when considering a co-location arrangement and the regulatory hurdles involved. The panel will discuss the operational and financial benefits of such arrangements, review the potential penalties if done incorrectly, and offer best practices for structuring and managing compliant arrangements.

1. Benefits of co-location arrangements
2. Potential penalties
3. Regulatory hurdles
4. Best practices for structuring arrangements
5. Best practices for ensuring compliance

The panel will review these and other key issues:

• What constitutes shared space such that the healthcare provider’s Medicare payments or certification are jeopardized?
• What informal guidance can be gleaned from the communications of CMS’ regional offices?
• What steps should counsel take to ensure compliance with Medicare requirements?