[Ongoing Program] On Location: New CMS Hospital Co-Location Guidance in the Spotlight

February 17th, 12:30 pm - 1:30 pm ET
McDermott Will & Emery
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McDermott Will & Emery

February 17th, 2022
12:30 PM - 1:30 PM ET

Demystifying the Regulatory Framework for Vendor Arrangements with Hospitals – A Three Part Series

Hospital and health systems rely on vendors and other partners to provide vital services that support patient care, efficient operations and smooth administrative functions. However, the regulations governing different types of arrangements with hospitals are complex and can often present unexpected pitfalls.

In this three-part webinar series, our regulatory attorneys will examine the practical implications for vendors and other entities working directly with hospitals, hospitals working with other providers through the “under arrangement” rule, and organizations navigating the intricacies of co-location agreements. This engaging series is a must-attend for hospitals and health systems, clinical services vendors and management companies, digital health companies, and any clinical entity providing services at a hospital campus or within a hospital’s physical structure.

On Location: New CMS Hospital Co-Location Guidance in the Spotlight

Particularly thorny regulatory issues arise when a hospital shares space, services or staff with another provider. Further complicating matters, the guidance historically provided by the Centers for Medicare and Medicaid Services (CMS) has not always been clear or consistent. Recently, CMS issued new guidance that sheds more light on the subject.

In this session, we’ll offer insights into the current regulatory environment and how it might continue to evolve, including:

  • What’s new in CMS’s November 2021 final guidance on hospital co-location and space-sharing arrangements
  • The most common issues that crop up when external provider services are offered on a hospital’s property
  • How vendor contracts work under co-location agreements
  • Enforcement trends.

SPEAKERS

Emily Jane Cook

Partner | Los Angeles

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Sandra M. DiVarco

Partner | Chicago

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Caroline Reigart

Partner | Washington, DC

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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