(Nov. 27, 2024) – On Nov. 20, the Centers for Medicare & Medicaid Services released
QSO-25-08-CAH to state survey agency directors to provide greater clarity on how a Critical Access Hospital may provide leased space and timeshare arrangements to other health care entities, including private physician practice while maintaining compliance with the Social Security Act and the Conditions of Participation. When a CAH participates in space-sharing arrangements, it is expected the CAH will consistently demonstrate independent compliance with the applicable statutory and regulatory requirements, including the risk of implicating the physician self-referral law.
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Ron Marshall