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New regulations governing integrated care are affording health care providers and facility operators a cost-effective opportunity to expand the range of treatment services they offer. As is true in the early stages of any significant regulatory shift, it is vital for providers and operators to stay aware of the complex regulatory developments that affect integrated care facilities.

New York and New Jersey recently adopted facility models that allow some integration of primary care, mental health, and chemical dependency services under a single roof – a departure from the traditional model, in which these services needed to be provided in separate facilities.

New York State recently began implementing regulatory approval of Integrated Outpatient Services ("IOS") facilities.This would allow New York operators, depending on the type and volume of services, to offer integrated services covered under a combination of individual facility licenses: Article 28 (New York State Department of Health), Article 31 (New York State Office of Mental Health), and Article 32 (New York State Office of Alcoholism and Substance Abuse Service).Once approved to do so, the operator would be permitted to offer a combination of the services at a single "host site," subject to inspection from the "host agency".

New Jersey recently issued a global "Shared Space Waiver," which allows New Jersey operators to provide primary and behavioral care in the same space.Similar to New York, an operator must possess multiple licenses to qualify for the Waiver, but depending on the circumstances and subject to the operator's continued compliance with the relevant regulations, additional regulatory approval to provide integrated care may not be necessary.

In both states, all existing regulations pertaining to individual facility licensure remain in force, so integrated facility operators must ensure compliance with multiple sets of relevant regulations.At the same time, providers and operators have a unique opportunity to offer a broad range of services, while simultaneously enjoying more efficient, streamlined regulatory oversight.

If you have any questions or require legal guidance with respect to integrated care or individual facility licensure or any other legal issues facing your facility, please do not hesitate to call one of our experienced healthcare attorneys at 212.668.0200 or email the firm at Our healthcare partners have years of experience representing New York and New Jersey health care facilities in obtaining licensure approval as well as numerous transactions including mergers & acquisitions, buy-ins/buy-outs, partnership formations/dissolutions, general commercial litigation matters, and defense of physicians and other healthcare providers in civil, administrative, disciplinary and criminal proceedings.



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Sunday, June 26, 2022