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Structuring Healthcare Co-Location Arrangements: Legal and Regulatory Requirements

Recording of a 90-minute CLE 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 Wednesday, December 13, 2017

Recorded event now available

or call 1-800-926-7926

This CLE course will provide guidance to counsel for hospitals and other healthcare providers participating in, or considering, co-location arrangements. The panel will discuss the benefits of such arrangements as well as the regulatory hurdles. The panel will offer best practices for structuring co-location arrangements and ensuring compliance to protect Medicare payments and certification.


Under pressure to improve the quality and efficiency of patient care while cutting costs, hospitals and other healthcare providers are turning to co-location arrangements with other entities such as ambulatory surgery centers, radiology departments and outpatient rehab facilities.

These arrangements offer many benefits, including reduced overhead costs, increased convenience to patients, and enhanced continuity of care. However, these same arrangements can also put hospitals’ payments and status as a Medicare provider at risk. Parties to co-location arrangements must grasp the regulatory requirements to bill Medicare and maintain billing privileges.

With little formal guidance from CMS, healthcare counsel must rely on letters and other informal communications from CMS regional offices to identify and address the potential legal and regulatory hurdles facing parties to co-location arrangements.

Listen as our authoritative panel of healthcare attorneys examines the steps providers and counsel should take when considering a co-location arrangement and the regulatory hurdles involved. The panel will discuss the operational and financial benefits of such arrangements, review the potential penalties if done incorrectly, and offer best practices for structuring and managing compliant arrangements.



  1. Benefits of co-location arrangements
  2. Potential penalties
  3. Regulatory hurdles
  4. Best practices for structuring arrangements
  5. Best practices for ensuring compliance


The panel will review these and other key issues:

  • What constitutes shared space such that the healthcare provider’s Medicare payments or certification are jeopardized?
  • What informal guidance can be gleaned from the communications of CMS’ regional offices?
  • What steps should counsel take to ensure compliance with Medicare requirements?


Faccenda, Mark
Mark Faccenda

Norton Rose Fulbright US

As part of the firm’s Healthcare Transactional Group, Mr. Faccenda has represented healthcare industry...  |  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

McCarthy, Colin
Colin P. McCarthy, Esq.


Mr. McCarthy concentrates on healthcare compliance and reimbursement. He counsels hospitals, health systems, physician...  |  Read More

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