The Medicare Outpatient Observation Notice, or MOON, is a standardized notice developed to inform Medicare patients that they are an outpatient receiving observation services and are not an inpatient of the hospital.
Here are 10 things to know about the notice.
1. CMS released a revised version of the MOON for OMB review and comment on August 1. That form requires a 30-day comment period before approval.
2. CMS has made substantive changes to the MOON from the first iteration. The old MOON cannot be used.
3. Because the new MOON must go through the approval process, use of the MOON will not be required for at least 120 days (the 30-day comment period and unknown time for comment review and release of the final MOON then a 90-day implementation period.) CMS is aware that the law requires implementation by August 6, 2016 but presents a legislative argument why that deadline is being waived.
4. The MOON will require a narrative of why the patient is being placed in outpatient status with observation services. CMS says that in the future it will consider model language for use in this section.
5. The MOON "additional information" section may be used to add information to meet any state law observation notification requirements that differ from the MOON federal requirements but the MOON may not be used for non-Medicare/Medicare Advantage patients.
6. The MOON is required for any Medicare/Medicare Advantage patient who receives 24 hours of observation and must be given by 36 hours but CMS allows the MOON be given to any Medicare/MA patient who receives observation services. On the other hand, CMS "encourages hospitals not to deliver the MOON at the initiation of observation services," at which point patients may be overwhelmed and confused.
7. Observation hour counting should begin with the order for observation. The 24 hour period is consecutive and "carved out hours" should not be considered.
8. There is no specific requirement as to what staff members can deliver the MOON, stating that the hospital or CAH is in the best position to determine the appropriate staff member to deliver the MOON."
9. Patients do not have the right to appeal their placement in outpatient status with observation services. CMS removed the QIO quality complaint reference on the MOON to avoid confusion about this.
10. The MOON is required for patients in whom Medicare is a second payer and for all patients with Medicare Advantage plans even though the copayments and SNF requirements for those patients may differ from those described on the MOON.
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