Medicare Outpatient Observation Notice (MOON)

CMS Releases Updated Medicare Outpatient Observation Notice (MOON)

The Centers for Medicare and Medicaid Services has released its updated version of the Medicare Outpatient Observation Notice (MOON).  The MOON is a standardized notice to inform beneficiaries (including Medicare health plan enrollees) that they are an outpatient receiving observation services and are not an inpatient of the hospital or (CAH).

The MOON is mandated by the Federal Notice of Observation Treatment and Implication for Care Eligibility Act (NOTICE Act), passed on August 6, 2015.  The NOTICE Act requires hospitals and CAHs to provide notification to individuals receiving observation services as outpatients for more than 24 hours explaining the status of the individual as an outpatient, not an inpatient, and the implications of such status.

• Hospitals and CAHs are required to furnish the MOON to a Medicare beneficiary who has been receiving observation services as an outpatient for more than 24 hours. Under the final rule, hospitals and CAHs may deliver the MOON to individuals receiving observation services as an outpatient before such individuals have received more than 24 hours of observation services.  The notice must be provided no later than 36 hours after observation services are initiated or, if sooner, upon release.

• An oral explanation of the MOON must be provided, ideally in conjunction with the delivery of the notice, and a signature must be obtained from the individual, or a person acting on such individual’s behalf, to acknowledge receipt.  In cases where such individual or person refuses to sign the MOON, the staff member of the hospital or CAH providing the notice must sign the notice to certify that notification was presented.

The MOON will inform more than one million beneficiaries annually of the reason(s) they are an outpatient receiving observation services and the implications of such status with regard to Medicare cost sharing and coverage for post-hospitalization skilled nursing facility (SNF) services.

Hospitals and critical access hospitals (CAHs) are required to provide the MOON beginning no later than March 8, 2017.