With recent changes to the Hospital within Hospital (“HwH”) rules, is it easier to meet the HwH standards? Likely, not. HwHs are hospitals excluded from the inpatient prospective payment system (“IPPS”), such as psychiatric, long-term care, children’s and cancer hospitals, but are located in the same building or on the same campus as another hospital (the “host hospital”). HwHs must still meet Centers for Medicare and Medicaid Services’ (“CMS”) evolving and stringent views on the Conditions of Participation (“COP”) requirements for co-located hospitals. CMS has long been concerned about the financial incentives for hospitals to operate a HwH in form, while in substance, operating it as a department or unit of the host hospital, using the same staff, equipment reporting structure as the host hospital, while receiving the higher reimbursement associated with IPPS-exclusion.