CMS provides shared space guidance for critical access hospitals

On Nov. 20, the Centers for Medicare & Medicaid Services (CMS) released guidance on expectations related to space sharing arrangements, including time-sharing and leased space agreements between critical access hospitals (CAHs) and other health care entities.

In QSO-25-08-CAH, CMS states, “Current access to care challenges in rural communities call for flexibility in health care partnerships, while simultaneously protecting the safety and quality of care for patients. In this guidance, CMS seeks to provide clarity on how a CAH may leverage space sharing arrangements with other health care entities to increase access to additional care and services within the community, while maintaining independent compliance with all applicable participation requirements.”

Within the guidance CMS details the following:

1. When CAHs choose to participate in space sharing arrangements, regardless of the arrangement, they are expected to demonstrate their independent compliance with the statutory and regulatory requirements outlined in the CMS Conditions of Participation (CoPs) at all times.
2. Under a time share arrangement, the CAH remains responsible for maintaining and demonstrating compliance with all applicable CoPs at all times, including the time established under the time-share arrangement.
3. Under a lease space arrangement, the CAH would not be operating within that leased space and it would not be responsible for demonstrating compliance with the CoPs within the leased space during the term of the lease except for the requirements for the physical structure/environment of the CAH and its building that may be contained within that space.

For additional information see QSO-25-08-CAH.