ED Coding and Reimbursement Alert

Know the rules and how they apply to ED care.

CMS recently released more information on the Medicare Outpatient Observation Notice (MOON), including preliminary instructions and notice form as of mid-December 2016. Read on to learn about who needs to administer the notice and for tips on signature requirements.

Background: 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 critical access hospital (CAH). All hospitals and Critical CAHs are required to provide the MOON beginning no later than March 8, 2017.

Who Needs A MOON?

Because it is a “Medicare Outpatient” Observation Notice, it pertains to all Medicare eligible patients, including Managed Medicare patients. The language in the MOON form specifically mentions Medicare Part B services and Medicare coverage decisions. As such, MOON does not explicitly pertain to non-Medicare patients; however non-Medicare payers might adopt it as a policy. Additionally, facilities could decide they want a single process that applies to all relevant patients so it makes sense to be familiar with the regulations, says Todd Thomas, CPC, CCS-P, President of ERcoder, Inc, a coding company in Edmond, OK.

Patients who have received or will likely receive at least 24 hours of observation services must be given the MOON form and they must sign it within 36 hours of the observation services initiating. However, there is no apparent constraint on having a patient sign the MOON earlier than the 24-hour observation threshold so you may wish to start the MOON process as soon as you know observation services will be initiated and likely to last at least 24 hours. Of note, the form does contain language in the “additional information” section that a notation can be made that the patient refused to sign the MOON, says Thomas.

Explain the MOON to Your Patients

The form must be typed in 12 point font or legibly hand-written equivalent. Medicare makes the hospital responsible for having the MOON executed, but does not specify who must do so. The MOON form requires that “hospitals and CAHs” are required to explain the notice and its content, that an oral explanation was provided, preferably at the same time the notice is presented, and all questions were answered to the best of their ability.

The reason that the patient is in outpatient rather than inpatient status must be specifically noted as well. Don’t forget to have the patient, or an individual qualified to act on their behalf, sign and include the date and time that of their signature so that it can be proved the MOON was executed by the deadline, warns Thomas.