Interested in training for your team? Click here to learn more

Co-Location Arrangements: Navigating New CMS Guidance

Complying With Legal and Regulatory Requirements When Structuring and Managing Arrangements

Recording of a 90-minute CLE video webinar with Q&A

This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Conducted on Tuesday, February 22, 2022

Recorded event now available

or call 1-800-926-7926

This CLE webinar will guide healthcare counsel on the new Centers for Medicare and Medicaid Services (CMS) guidance for co-location arrangements, discuss the considerations for entering a co-location arrangement and the regulatory hurdles, and offer best practices for structuring and managing compliant arrangements.


Hospitals and healthcare providers are entering into co-location arrangements with other entities, such as physician practices and departments of other hospitals, to improve the quality and efficiency of patient care. The CMS recently issued new guidance for ensuring compliance with co-location arrangements.

CMS provides guidance on how state surveyors evaluate hospital compliance with Medicare hospital conditions of participation (CoPs) in connection with hospital co-location arrangements with other hospitals and healthcare providers. The guidance removed most examples of compliant and noncompliant co-location arrangements. Instead, the CMS provides general statements that hospitals should ensure that co-location arrangements are compliant.

Further, CMS excluded critical access hospitals and private physician offices from the definition of "healthcare providers" in the context of the guidance. However, CMS was silent about whether this means that co-location arrangements with these entities are prohibited, thereby adding to the uncertainty.

Parties to co-location arrangements must grasp the regulatory requirements in order to continue to participate in the Medicare program and compliantly bill for services. Identifying and addressing potential legal and regulatory hurdles is critical.

Listen as our authoritative panel of healthcare attorneys examines the new CMS guidance for co-location arrangements. The panel will also discuss the considerations when entering a co-location arrangement and the regulatory hurdles involved. The panel will offer best practices for structuring and managing compliant arrangements.



  1. New CMS guidance
  2. Regulatory hurdles
  3. Compliance considerations
  4. Best practices
    1. Structuring agreements
    2. Ensuring compliance


The panel will review these and other key issues:

  • How does the new guidance both clear and muddy the waters for compliance when in co-location arrangements?
  • What informal guidance do the communications of CMS regional offices offer?
  • What steps should counsel and healthcare entities and providers take to ensure compliance despite the uncertainty created by the new guidance?


DiVarco, Sandra
Sandra M. DiVarco

McDermott Will & Emery

Ms. DiVarco focuses her practice on the representation of hospitals and health systems. She counsels healthcare...  |  Read More

Hollender, Alison
Alison Hollender, Esq.

Husch Blackwell

Ms. Hollender focuses on the licensure and certification of healthcare facilities, regulatory compliance and...  |  Read More

Access Anytime, Anywhere

Strafford will process CLE credit for one person on each recording. All formats include course handouts.

To find out which recorded format will provide the best CLE option, select your state:

CLE On-Demand Video