CMS Issues Long-Awaited Draft Guidance on Hospital Co-Location and Space Sharing

K&L Gates LLP
Contact

K&L Gates LLP

Summary
On May 3, 2019, the Centers for Medicare & Medicaid Services (“CMS”) issued long-awaited draft guidance[1] addressing compliance with the hospital Conditions of Participation (“CoPs”) and survey procedures in regard to hospitals co-located with other hospitals or healthcare entities. The guidance aims to clarify how shared spaces, services, personnel, and emergency services may be organized in a hospital co-located with another hospital or healthcare entity. CMS notes its goal of ensuring safety and accountability without being overly prescriptive. Once finalized, the guidance will be incorporated into Appendix A of the State Operations Manual.

As discussed in greater detail below, this guidance modifies CMS’ prior position on hospital co-location. Historically, CMS has largely prohibited space sharing between hospitals and other healthcare entities. If finalized, this guidance will provide some additional flexibility in structuring compliant co-location arrangements, although it still contains significant limitations and may not go as far as some providers would have liked. CMS is seeking comments through July 2, 2019.

History of Co-Location and CMS Guidance
CMS defines co-location as an arrangement under which two hospitals or a hospital and another healthcare entity are located on the same campus or in the same building and share space, staff, or services. A desire to co-locate has increased in recent years as hospitals and healthcare providers seek to improve coordination of care and efficiently deliver services to patients. Historically, CMS’ position has effectively been that hospitals are barred from sharing clinical or nonclinical space with other healthcare entities because such sharing prevented the hospital from complying with the CoPs, although that position was not formalized in guidance.

Analysis of Draft Guidance
The draft guidance clarifies the circumstances under which a hospital can be co-located with another healthcare provider consistent with the CoPs. CMS provides several examples of permitted co-location, as well as prohibited arrangements. Additionally, the guidance specifically addresses contracted staff and services and emergency services and discusses how state survey teams will evaluate compliance with this guidance.

The guidance focuses primarily on co-located hospitals, but is likewise applicable to hospitals co-located with other healthcare entities. The term “healthcare entity” is not defined in the guidance, but CMS lists ambulatory surgical centers (“ASCs”), rural health clinics (“RHCs”), federally qualified healthcare centers (“FQHCs”), imaging centers, and separately Medicare-certified providers and suppliers as examples of healthcare entities. CMS cautions that the guidance is specific to the requirements under the hospital CoPs and does not address the specific location and separateness requirements that apply to other types of providers/suppliers, such as psychiatric hospitals, independent diagnostic testing facilities, ASCs, and RHCs[2].

Compliance with Medicare CoPs
While permitting co-located providers, the guidance emphasizes that when a hospital is in the same location as another healthcare provider, each provider is responsible for demonstrating separate and independent compliance with the CoPs.

The guidance also contains procedures for CMS and state agency surveyors (collectively, “Surveyors”) to evaluate a hospital’s space sharing or contracted staff arrangements when assessing the hospital’s compliance with the CoPs. A short discussion of these instructions is included in each of the sections below.

Distinct Space vs. Shared Space
Under the guidance, a hospital must have defined and distinct clinical spaces, meaning that these spaces must remain under the control of the hospital at all times. CMS describes clinical space as any nonpublic space in which patient care occurs. Thus, the guidance explains, clinical spaces must be distinct and may not be used in a manner that comingles patients in a clinical space. CMS bases this position by noting that shared clinical spaces could jeopardize a patient’s right to personal privacy and confidentiality of his/her medical record information and could pose safety risks. The effect of this guidance is that clinical spaces may not be shared.

By contrast, the guidance states that nonclinical spaces may be shared by co-located providers. Shared spaces are described as public spaces and public paths of travel that are utilized by the hospital and co-located healthcare entity. CMS provides the following examples of public spaces and public paths of travel that may be shared:

  • public lobbies 
  • waiting rooms
  • reception areas (with separate "check-in" areas and clear signage)
  • public restrooms
  • staff lounges
  • elevators and main corridors through non-clinical areas
  • main entrances to a building

However, where a path of travel goes through a clinical space, that would not be considered a public path of travel and would be prohibited based on patient privacy, security, and infection control concerns.

CMS provides the following examples of public and nonpublic paths of travel:

  • A public path of travel is, for example, a main hospital corridor with distinct entrances to departments (such as outpatient medical clinics, laboratory, pharmacy, radiology). It is necessary to identify, for the public, which healthcare entity is performing the services in which department.
  • By contrast, the following examples would not be public paths of travel:

    • A hallway, corridor, or path of travel through an inpatient nursing unit; or
    • A hallway, corridor, or path of travel through a clinical hospital department (e.g., outpatient medical clinic, laboratory, pharmacy, imaging services, operating room, post anesthesia care unit, emergency department).

The guidance instructs Surveyors to ask for a floor plan that distinguishes the spaces used by the hospital being surveyed and the spaces used by the other co-located healthcare entity. The floor plan must clearly identify which healthcare entities use the spaces. If two healthcare entities utilize the same space, noncompliance identified in that space can be cited against both entities. For example, where a Surveyor identifies noncompliance with a shared space, the Surveyor could initiate a complaint against the healthcare entity not currently being surveyed.

When reviewing the floor plan, Surveyors will specifically look for the following space sharing situations and assess compliance with the CoPs:

  • Whether spaces within the co-located hospital are defined and identified as belonging to the hospital being surveyed;
  • Whether spaces that belong to another entity can only be accessed by traveling through public paths of travel from within the hospital;
  • Whether spaces that appear to be shared by the surveyed hospital and the other entity as public spaces are identified as belonging to both; and
  • Whether there are any shared spaces and/or services between the hospital and the other co-located entity.

When surveying physical spaces and locations of a hospital, Surveyors will evaluate whether any clinical care space is being shared between the hospital and the other healthcare entity with which it is co-located. The guidance states that, in general, a hospital should not share space where patients are receiving care. This would include, but is not limited to, any space within nursing units (including hallways, nursing stations, and exam and procedure rooms located within nursing units), outpatient clinics, emergency departments, operating rooms, and post-anesthesia care units. Additionally, the sharing of spaces used for medical records and patient registration could potentially pose risks to patient privacy and likewise may indicate non-compliance with the CoPs.

Given this guidance, hospitals with co-location arrangements should evaluate whether any space meeting the definition of clinical space is shared with another healthcare entity, particularly whether a patient must travel through clinical space to get to non-clinical space. Where such space is shared, the hospital would need to take steps to limit the shared space only to space that is public space or a public path of travel.

Contracted Staff and Services
A hospital may obtain certain services from other healthcare entities under arrangements, including from co-located healthcare entities. Such services could include food preparation services, laboratory services, pharmacy services, housekeeping, and security services.

In regard to sharing of staff between co-located providers, the guidance makes clear CMS’ position that clinical staff cannot “float” between providers. Instead, any such contracted staff must be assigned to work for only one hospital during a specific shift. For example, a hospital must be able to provide nursing services at all times. Where nursing services are shared between two co-located hospitals, CMS opines that neither hospital can meet this standard. The exception to this rule is that medical staff privileged and credentialed at two or more hospitals may be shared between those hospitals.

The guidance for Surveyors states that where a hospital has contracted for services, such as laboratory or dietary services,[3] the Surveyor will ask hospital leadership to provide a list of all services that the hospital has contracted to use from the other co-located entity or healthcare entities. CMS explains this information is critically important as Surveyors must know what specific space/locations to survey and what services are being directly provided by the hospital being surveyed or are being provided by another entity.

With respect to contracted staff, the Surveyor is responsible for surveying the actual physical location where the contracted services (such as the laboratory or kitchen) are being provided if it is physically located and provided on-site. When a contracted service is not located or is not being provided on-site, such as a laundry service for hospital linens, the Surveyor is not required to survey the off-site location.

Surveyors will review the contracts for staffing services with co-located entities to ensure that they provide for the following:

  • Adequacy of staff levels;
  • Adequate oversight and periodic evaluation of contracted staff;
  • Proper training and education of contracted staff;
  • Contracted staff have knowledge of and adheres to the quality and performance improvement standards of the individual hospital;
  • Accountability of the contracted staff related to clinical practice requirements; and
  • That staffing and schedules ensure that staff are immediately available at all times to perform services required by the hospital.

Finally, the Surveyor will ask the governing body to verify that any clinical services being provided under contract from the other entity are not being simultaneously shared with another hospital or entity and, among other criteria, will request staffing schedules to verify that individuals providing contracted services are only scheduled to work at one facility per shift.

Given this guidance, hospitals with co-location arrangements should evaluate their respective services and staffing contracts and ensure that staff are not shared in a manner that prevents the hospital from complying with clinical staffing requirements under the CoPs. Among other staffing-related criteria, each hospital’s governing board is responsible for ensuring adequate staffing levels and oversight of contracted staff and must ensure that contracted staff are accountable for their clinical practice requirements.

Emergency Services
Hospitals without emergency departments are required to have appropriate policies and procedures in place for addressing individuals’ emergency care needs 24 hours per day, seven days per week. The draft guidance describes CMS’ expectations in regard to policies and procedures and notes the circumstances under which a hospital may and may not contract for emergency services from a co-located hospital. Under the draft guidance, a hospital without an emergency department that is co-located with another hospital may not arrange to have that other hospital respond to its emergencies in order to appraise the patient and provide initial emergency treatment. However, after initiating treatment, the hospital may transfer a patient to the co-located hospital for further treatment if appropriate.

When evaluating the emergency care of patients in a hospital without an emergency department that is co-located with another healthcare entity, the Surveyor will review for the following:

  • Whether the hospital responds to its own patients in hospital emergencies, with its own trained staff (not another hospital’s or entity’s staff);
  • Whether the hospital has the proper emergency equipment in the event that a patient requires resuscitation;
  • Whether hospital staff is properly trained in the use of the emergency equipment;
  • Whether the hospital’s emergency equipment properly maintained; and
  • Whether the hospital’s staff is properly trained for appraisal of emergencies, initial treatment, and referral when appropriate.

If the hospital has no emergency department, but has its emergency services provided under a contract with an emergency department of a co-located hospital, the Surveyor will verify that the hospital meets the Emergency Medical Treatment & Labor Act requirements. Where emergency services are provided by staff under contract, the Surveyor will verify that staff are immediately available at all times and only committed to services at that hospital during those time.

Conclusion
Hospitals have long awaited formalized co-location guidance from CMS. This draft guidance represents a notable departure from the agency’s prior position on shared spaces. As discussed above, if finalized, this guidance would give co-located providers the ability to share public areas and public paths of travel and is likely to allow hospitals to make structural changes that promote greater care coordination and enhance patient-centered care, although it may not provide as much flexibility as some providers would like. If finalized, hospitals should perform a comprehensive review of their co-located spaces and shared personnel and services to ensure compliance with this guidance and to be prepared to provide the documentation and floor plans anticipated to be requested upon survey.

CMS is accepting comments on this draft guidance until July 2, 2019. Comments should be submitted to HospitalSCG@cms.hhs.gov.

[1] Memo to State Survey Agency Directors, DRAFT ONLY- Guidance for Hospital Co-location with Other Hospitals or Healthcare Facilities (QSO-19-13-Hospital) (May 3, 2019).

[2] Please note this guidance also does not address other rules that might apply to co-located hospitals, such as the hospital-within-a-hospital rules or the satellite facility rules. See 42 C.F.R. 412.22(e), (h).

[3] In addition to the co-location guidance, Surveyors evaluate compliance with the CoPs through the use of contracted services can be evaluated by following the interpretive guidance and survey procedures under 42 CFR §§ 482.21, 482.12(e). These regulations require that Surveyors ask to see documentation as to how the contracted services are incorporated into the hospital’s quality assessment and performance improvement program.

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.

© K&L Gates LLP | Attorney Advertising

Written by:

K&L Gates LLP
Contact
more
less

K&L Gates LLP on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide

JD Supra Privacy Policy

Updated: May 25, 2018:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at www.jdsupra.com) (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services"). By using our Website and registering for one of our Services, you are agreeing to the terms of this Privacy Policy.

Please note that if you subscribe to one of our Services, you can make choices about how we collect, use and share your information through our Privacy Center under the "My Account" dashboard (available if you are logged into your JD Supra account).

Collection of Information

Registration Information. When you register with JD Supra for our Website and Services, either as an author or as a subscriber, you will be asked to provide identifying information to create your JD Supra account ("Registration Data"), such as your:

  • Email
  • First Name
  • Last Name
  • Company Name
  • Company Industry
  • Title
  • Country

Other Information: We also collect other information you may voluntarily provide. This may include content you provide for publication. We may also receive your communications with others through our Website and Services (such as contacting an author through our Website) or communications directly with us (such as through email, feedback or other forms or social media). If you are a subscribed user, we will also collect your user preferences, such as the types of articles you would like to read.

Information from third parties (such as, from your employer or LinkedIn): We may also receive information about you from third party sources. For example, your employer may provide your information to us, such as in connection with an article submitted by your employer for publication. If you choose to use LinkedIn to subscribe to our Website and Services, we also collect information related to your LinkedIn account and profile.

Your interactions with our Website and Services: As is true of most websites, we gather certain information automatically. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information to analyze trends, to administer the Website and our Services, to improve the content and performance of our Website and Services, and to track users' movements around the site. We may also link this automatically-collected data to personal information, for example, to inform authors about who has read their articles. Some of this data is collected through information sent by your web browser. We also use cookies and other tracking technologies to collect this information. To learn more about cookies and other tracking technologies that JD Supra may use on our Website and Services please see our "Cookies Guide" page.

How do we use this information?

We use the information and data we collect principally in order to provide our Website and Services. More specifically, we may use your personal information to:

  • Operate our Website and Services and publish content;
  • Distribute content to you in accordance with your preferences as well as to provide other notifications to you (for example, updates about our policies and terms);
  • Measure readership and usage of the Website and Services;
  • Communicate with you regarding your questions and requests;
  • Authenticate users and to provide for the safety and security of our Website and Services;
  • Conduct research and similar activities to improve our Website and Services; and
  • Comply with our legal and regulatory responsibilities and to enforce our rights.

How is your information shared?

  • Content and other public information (such as an author profile) is shared on our Website and Services, including via email digests and social media feeds, and is accessible to the general public.
  • If you choose to use our Website and Services to communicate directly with a company or individual, such communication may be shared accordingly.
  • Readership information is provided to publishing law firms and authors of content to give them insight into their readership and to help them to improve their content.
  • Our Website may offer you the opportunity to share information through our Website, such as through Facebook's "Like" or Twitter's "Tweet" button. We offer this functionality to help generate interest in our Website and content and to permit you to recommend content to your contacts. You should be aware that sharing through such functionality may result in information being collected by the applicable social media network and possibly being made publicly available (for example, through a search engine). Any such information collection would be subject to such third party social media network's privacy policy.
  • Your information may also be shared to parties who support our business, such as professional advisors as well as web-hosting providers, analytics providers and other information technology providers.
  • Any court, governmental authority, law enforcement agency or other third party where we believe disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals' personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues.
  • To our affiliated entities and in connection with the sale, assignment or other transfer of our company or our business.

How We Protect Your Information

JD Supra takes reasonable and appropriate precautions to insure that user information is protected from loss, misuse and unauthorized access, disclosure, alteration and destruction. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. You should keep in mind that no Internet transmission is ever 100% secure or error-free. Where you use log-in credentials (usernames, passwords) on our Website, please remember that it is your responsibility to safeguard them. If you believe that your log-in credentials have been compromised, please contact us at privacy@jdsupra.com.

Children's Information

Our Website and Services are not directed at children under the age of 16 and we do not knowingly collect personal information from children under the age of 16 through our Website and/or Services. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Websites

Our Website and Services may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using our Website or Services and click a link to another site, you will leave our Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites. This Policy applies solely to the information collected in connection with your use of our Website and Services and does not apply to any practices conducted offline or in connection with any other websites.

Information for EU and Swiss Residents

JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

  • Our Legal Basis for Processing: Generally, we rely on our legitimate interests in order to process your personal information. For example, we rely on this legal ground if we use your personal information to manage your Registration Data and administer our relationship with you; to deliver our Website and Services; understand and improve our Website and Services; report reader analytics to our authors; to personalize your experience on our Website and Services; and where necessary to protect or defend our or another's rights or property, or to detect, prevent, or otherwise address fraud, security, safety or privacy issues. Please see Article 6(1)(f) of the E.U. General Data Protection Regulation ("GDPR") In addition, there may be other situations where other grounds for processing may exist, such as where processing is a result of legal requirements (GDPR Article 6(1)(c)) or for reasons of public interest (GDPR Article 6(1)(e)). Please see the "Your Rights" section of this Privacy Policy immediately below for more information about how you may request that we limit or refrain from processing your personal information.
  • Your Rights
    • Right of Access/Portability: You can ask to review details about the information we hold about you and how that information has been used and disclosed. Note that we may request to verify your identification before fulfilling your request. You can also request that your personal information is provided to you in a commonly used electronic format so that you can share it with other organizations.
    • Right to Correct Information: You may ask that we make corrections to any information we hold, if you believe such correction to be necessary.
    • Right to Restrict Our Processing or Erasure of Information: You also have the right in certain circumstances to ask us to restrict processing of your personal information or to erase your personal information. Where you have consented to our use of your personal information, you can withdraw your consent at any time.

You can make a request to exercise any of these rights by emailing us at privacy@jdsupra.com or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

You can also manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard.

We will make all practical efforts to respect your wishes. There may be times, however, where we are not able to fulfill your request, for example, if applicable law prohibits our compliance. Please note that JD Supra does not use "automatic decision making" or "profiling" as those terms are defined in the GDPR.

  • Timeframe for retaining your personal information: We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. For example, if you are an author, your personal information may continue to be published in connection with your article indefinitely. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
  • Onward Transfer to Third Parties: As noted in the "How We Share Your Data" Section above, JD Supra may share your information with third parties. When JD Supra discloses your personal information to third parties, we have ensured that such third parties have either certified under the EU-U.S. or Swiss Privacy Shield Framework and will process all personal data received from EU member states/Switzerland in reliance on the applicable Privacy Shield Framework or that they have been subjected to strict contractual provisions in their contract with us to guarantee an adequate level of data protection for your data.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, our customers who are California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

You can make a request for this information by emailing us at privacy@jdsupra.com or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our site.

Access/Correct/Update/Delete Personal Information

For non-EU/Swiss residents, if you would like to know what personal information we have about you, you can send an e-mail to privacy@jdsupra.com. We will be in contact with you (by mail or otherwise) to verify your identity and provide you the information you request. We will respond within 30 days to your request for access to your personal information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. If you would like to correct or update your personal information, you can manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard. If you would like to delete your account or remove your information from our Website and Services, send an e-mail to privacy@jdsupra.com.

Changes in Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and Services following such changes, you will be deemed to have agreed to such changes.

Contacting JD Supra

If you have any questions about this Privacy Policy, the practices of this site, your dealings with our Website or Services, or if you would like to change any of the information you have provided to us, please contact us at: privacy@jdsupra.com.

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at www.jdsupra.com) (our "Website") and our services (such as our email article digests)(our "Services") use a standard technology called a "cookie" and other similar technologies (such as, pixels and web beacons), which are small data files that are transferred to your computer when you use our Website and Services. These technologies automatically identify your browser whenever you interact with our Website and Services.

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

  1. Improve the user experience on our Website and Services;
  2. Store the authorization token that users receive when they login to the private areas of our Website. This token is specific to a user's login session and requires a valid username and password to obtain. It is required to access the user's profile information, subscriptions, and analytics;
  3. Track anonymous site usage; and
  4. Permit connectivity with social media networks to permit content sharing.

There are different types of cookies and other technologies used our Website, notably:

  • "Session cookies" - These cookies only last as long as your online session, and disappear from your computer or device when you close your browser (like Internet Explorer, Google Chrome or Safari).
  • "Persistent cookies" - These cookies stay on your computer or device after your browser has been closed and last for a time specified in the cookie. We use persistent cookies when we need to know who you are for more than one browsing session. For example, we use them to remember your preferences for the next time you visit.
  • "Web Beacons/Pixels" - Some of our web pages and emails may also contain small electronic images known as web beacons, clear GIFs or single-pixel GIFs. These images are placed on a web page or email and typically work in conjunction with cookies to collect data. We use these images to identify our users and user behavior, such as counting the number of users who have visited a web page or acted upon one of our email digests.

JD Supra Cookies. We place our own cookies on your computer to track certain information about you while you are using our Website and Services. For example, we place a session cookie on your computer each time you visit our Website. We use these cookies to allow you to log-in to your subscriber account. In addition, through these cookies we are able to collect information about how you use the Website, including what browser you may be using, your IP address, and the URL address you came from upon visiting our Website and the URL you next visit (even if those URLs are not on our Website). We also utilize email web beacons to monitor whether our emails are being delivered and read. We also use these tools to help deliver reader analytics to our authors to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

Analytics/Performance Cookies. JD Supra also uses the following analytic tools to help us analyze the performance of our Website and Services as well as how visitors use our Website and Services:

  • HubSpot - For more information about HubSpot cookies, please visit legal.hubspot.com/privacy-policy.
  • New Relic - For more information on New Relic cookies, please visit www.newrelic.com/privacy.
  • Google Analytics - For more information on Google Analytics cookies, visit www.google.com/policies. To opt-out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout. This will allow you to download and install a Google Analytics cookie-free web browser.

Facebook, Twitter and other Social Network Cookies. Our content pages allow you to share content appearing on our Website and Services to your social media accounts through the "Like," "Tweet," or similar buttons displayed on such pages. To accomplish this Service, we embed code that such third party social networks provide and that we do not control. These buttons know that you are logged in to your social network account and therefore such social networks could also know that you are viewing the JD Supra Website.

Controlling and Deleting Cookies

If you would like to change how a browser uses cookies, including blocking or deleting cookies from the JD Supra Website and Services you can do so by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It's also easy to delete cookies that are already saved on your device by a browser.

The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser's "Help" function or alternatively, you can visit http://www.aboutcookies.org which explains, step-by-step, how to control and delete cookies in most browsers.

Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

Contacting JD Supra

If you have any questions about how we use cookies and other tracking technologies, please contact us at: privacy@jdsupra.com.

- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.