This episode explores the proposed changes to the hospital within a hospital (“HwH”) rules, which were published in the Federal Register on April 14, 2017 as part of the Fiscal Year 2018 Medicare Hospital Inpatient Prospective Payment System and Long Term Acute Care Hospital Prospective Payment System Proposed Rule. This episode describes proposals by the Centers for Medicare & Medicaid Services (“CMS”) to limit the application of “separateness and control” requirements and performance criteria because CMS believes these issues are sufficiently covered by Medicare conditions of participation.

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