DESIGN IMPACTS HOSPITAL LICENSED VS. NON-LICENSED …

FEBRUARY 14, 2018DEREK SELKE, AIA, ACHA | HEALTHCARE ARCHITECT

dselke@bsalifestructures.com

DESIGN IMPACTS –HOSPITAL LICENSED VS. NON-LICENSED SPACES

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21CMS | Co-location or “Shared” Space

What is Licensed & Non-licensed Space?

Building Entries | Common Space | Patient Flow

Waiting Space | Separation

Registration | Check-in Space

Staff Separation

Signage

Introduction & Agenda

• No formal guidance of requirements/regulations from CMS• Info gathered, learned from ISDH and CMS• Terminology – “Licensed, hospital space, certified, provider-based”

“Non-licensed, private practice, non-certified, independent”

Mixed Use• Physician Offices

- Private Practice or “Freestanding” (billing perspective)- Joint Ventures (Hospital | Physicians)- Developers leasing space to Healthcare Systems- Time share or time block arrangements- Shared reception/waiting areas

• Ambulatory Surgery Centers- Freestanding or Hospital Provider-based

• Rural Health Clinics (RHC)- Freestanding or Hospital Provider-based

• Hospital Outpatient Departments (HOPD)- Hospital Provider-based “Hospital Licensed Space”- HOPD’s on main campus or in remote locations

Co-location/Shared Space

• CMS Certification Number (CCN) | National Provider Identifier (NPI)

- CCN | NPI

- CCN is the new version of NPI, same thing

- Unique 10-digit identification number issued to health care providers in the U.S. by CMS.

- If a doctor/resident is billing under the hospital's CCN #, then they fall under the hospital's license.

- Nothing to do with physician’s professional license

- Hospital Provider Number = “HOSPITAL LICENSED SPACE”

Centers for Medicare and Medicaid Services (CMS) Identification Number

The hospital is not permitted to share space with another entity, and hospital space must be hospital space at all times.

Centers for Medicare and Medicaid Services (CMS)

Within your facility, will patient billing occur under the hospital's provider number or freestanding (private practice) provider number? Or both?

Hospital’s provider number

Your facility is hospital licensed space.

ISDH will review the design.

Both provider numbers

A portion of the facility will be considered hospital

licensed space.

ISDH will review the licensed portion only,

Separation of space is needed to meet CMS

requirements.

Private practice provider number

Your facility is not hospital licensed space.

ISDH will “likely” not review the design.

Indiana State Department of Health (ISDH)

If patient billing occurs under…

• Mixed Use Spaces

• Floor plans that do not clearly identify or define hospital space

• Clear Identifiable Signage

• CMS will focus on the following spaces:- Building Entries

- “Common Space”

- Registration Areas

- Waiting Areas

- Staff Work Space

- Treatment Spaces

- Corridors

What will CMS be looking for during a survey / review?

Takeaways

• Internal Audit: Evaluate each of your facilities in which you lease space. Understand how the leased space and the provider-based (hospital) space are related – they must remain separate.

• Ensure patients always know whether they’re in hospital space or private practice (non-licensed) space.

• Consider whether your space has changed utilization – is the space now being operated by a different provider? Are patients being billed under a different provider number than originally planned?

• Avoid “Risky Business” – Seek CMS and State review/approval early in the design process. The operational and financial benefits of co-locating can still be achieved with good planning!

D I S C O V E R D E S I G N T E S T I M P L E M E N T

FEBRUARY 14, 2018DEREK SELKE, AIA, ACHA | HEALTHCARE ARCHITECT

dselke@bsalifestructures.com

QUESTIONS?