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New Medicare Hospital Provider-Based Guidance

Date: 06/26/2019

12:30 PM - 1:30 PM

Course Curriculum
This program will provide a comprehensive update on significant legal and regulatory changes, including the following:

On May 3, 2019, CMS published draft guidance regarding space sharing between co-located hospitals and hospitals co-located with other health care entities. This new guidance answers a number of longstanding provider questions regarding co-location and co-mingling of services between co-located providers. At the same time, this new guidance leaves open a number of ongoing issues for hospital provider-based facilities, building construction, rural facility compliance, and other operational hurdles.

Join us for this discussion of CMS’ new guidance and interpretation of space-sharing restrictions, operational hurdles for provider operations, and opportunities for ongoing provider input as CMS policy develops.



Ross Sallade, Colleen Faddick, and Ryan Thurber

Ross Sallade, Shareholder, focuses his practice on a variety of state and federal health care regulatory and reimbursement matters, such as provider and supplier reimbursement; Medicare and Medicaid enrollment, survey and certification; federal anti-kickback and physician self-referral (or “Stark”) laws; state licensure; Medicare and Medicaid regulatory compliance; health care operational and transactional matters; and fraud and abuse.

Colleen Faddick, Shareholder, advises clients regarding the structure of and relationships among health care providers and entities within the complex federal and state regulatory environment. As chair of the firm's Health Care Operations practice, she focuses on Medicare and Medicaid reimbursement and enrollment issues and appeals, fraud and abuse and self-referral law issues, licensing and certification of health care entities. Colleen works with hospitals, large physician groups, dialysis suppliers, medical device companies, pharmacies, clinical laboratories, DME companies, and other health care entities.

Ryan Thurber, Associate, focuses on helping providers achieve their business objectives in a manner that clears these regulatory hurdles and allows providers to do what they do best: care for their patients. As part of Polsinelli’s vibrant health care practice, Ryan assists providers with resolving complex regulatory compliance issues, responding to government and third party investigations and identifying, structuring, and implementing provider-focused business arrangements.

The speakers do not have any real or perceived conflicts of interest related to this presentation.

Learning Objectives
At the conclusion of this session, participants will be able to:

  1. Understand CMS’ new interpretation of space sharing restrictions and prohibitions for hospitals and co-located providers;
  2. Evaluate existing and proposed co-location arrangements for compliance with the new guidance;
  3. Review areas where CMS guidance is still unclear; and
  4. Review opportunities for provider engagement with CMS through the comment process.