The New Moon in Healthcare

The Medicare Outpatient Observation Notice (MOON) came out earlier this year and this is something that always comes up as a question and not many know where to find the answers.

Medicare put out a MLN article in February for Critical Access Hospitals (CAHs) that provide observation services to Medicare Beneficiaries. The main point of this article was to identify and drive home a clear and concise message covering how providers in CAH facilities should utilize the MOON to educate Medicare beneficiaries. CAH providers should use the MOON to inform any Medicare beneficiary who is an outpatient in their facility that happens to be receiving observation services and are not an inpatient in the CAH or hospital.

Hospitals and CAHs must provide the MOON to beneficiaries who receive observation services in a CAH or hospital for more than 24 hours. This form must be provided to the Medicare beneficiary no later than 36 hours after observation services begin in the outpatient setting. Now, this is not only for the traditional Medicare Part A and Part B patient, but those beneficiaries that do not have Part B coverage, as this is optional, and when a patient is admitted prior to the required delivery of the MOON.

Now, one may think, let’s give these to all of our Medicare patients receiving outpatient services. This will not work as the MOON should not go to all beneficiaries receiving outpatient services. It is intended only for patients that exceed 24 hours of observation services. But here is a good twist, the CAH or hospital can deliver the MOON to Medicare beneficiaries that are receiving observation services in a CAH or hospital, but have not exceeded the 24 hour rule. As long as they are receiving observation services the CAH or hospital can deliver the MOON to the patient, but no later than 36 hours after observation services have started.

Some other points:

• The MOON must remain two pages
• Additional information may be attached, per individual state regulations
• Hospitals and CAHs can put their logo on the top of the MOON
• In completing the MOON, hospitals or CAHs must type or write (clearly) the patient name, patient number, and reason for outpatient in the blanks of the MOON.
• CAHs and hospitals must provide, not only the written MOON, but an oral notification as well. This must consist of an explanation of the standard written MOON.
• To show proof of delivery, the patient or representative must sign and date the MOON to show delivery and understanding of the information contained in the form.
• An electronic form of the MOON is permitted with an electronic signature capture pad.
• With an electronic form of the MOON, the patient must receive a paper copy as well.

If a patient or their representative refuses to sign the MOON, the facility representative can sign the document, state their title, date and time presented to the patient, and the staff member will note in the “Additional Information” portion of the MOON that the form was delivered and the patient refused to sign, then date and time of refusal will be noted as well.

This is very similar to other forms for CMS, such as an Advance Beneficiary Notice (ABN), and the same care must be taken to remain in compliance with CMS and to make sure you are keeping your patients educated.

Submitted by Kevin Harrington, MS, RHIA, CHP, Faculty, Saint Joseph's College