• Consider rebranding the facility, including changing its name, if
necessary, so that it includes the designation of simply "hospital"
instead of "surgical hospital," "clinic" or "center."
Facilities that are concerned about meeting the requirements should
draft a plan of action now, as CMS's random surveys can occur at any
time. After all, the best defense against negative survey results is
preparation today.
OSM
Mr. Patterson (lorin.patterson@bipc.com) is a shareholder in the healthcare
section and Mr. Holland (robert.holland@bipc.com) is an associate at
Buchanan, Ingersoll & Rooney in Washington, D.C.
Legal Update
LU
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