CMS revisiting guidance on “shared space” arrangements

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In many South Dakota communities, hospitals have developed “shared space” arrangements with other providers, such as visiting specialists, to ensure access to care. These arrangements have come under increased scrutiny by the Center for Medicare and Medicaid Services (CMS) during the past few years.

The association has been actively working with the American Hospital Association (AHA) requesting CMS provide more transparency about the agency’s expectations involving this issue and to allow greater flexibility, especially in rural areas where visiting specialist are needed. Fortunately, this issue has not caused significant hardship in SD; however in 2015, CMS terminated a Montana hospital’s provider-based status for all its clinics, with an immediate effective date. CMS then required the hospitals to re-apply for provider-based status and re-attest once it could verify it no longer allowed non-hospital employed physicians to practice in “shared space” within any of its provider-based clinics.

This week, leaders from AHA received encouraging updates from meetings with CMS officials, including David Wright, the director of the Survey and Certification Group, CMS, Center for Clinical Standards and Quality. CMS shared that new guidance has been drafted and is in review. AHA asked CMS to make the new guidance a priority and to update policies to align as much as possible with the agency’s broader mission to promote coordinated, patient-centered care across the continuum.

Additional information will be shared as it becomes available.