CMS posts final hospital MOON for implementation by March 6

The Centers for Medicare & Medicaid Services today posted its updated version of the Medicare Outpatient Observation Notice, a standard notice that all hospitals and critical access hospitals must provide effective March 6, 2017 to all Medicare beneficiaries who receive outpatient observation services for more than 24 hours. Under the Notice of Observation Treatment and Implication for Care Eligibility Act, hospitals must provide oral and written notice to beneficiaries within 36 hours after observation services are initiated, or sooner if the individual is transferred, discharged or admitted as an inpatient. The notice informs them that they are an outpatient receiving observation services, not an inpatient, and the associated implications for cost-sharing and eligibility for Medicare coverage of skilled nursing facility services. CMS issued the final policies for implementing the NOTICE Act in August with the inpatient prospective payment system final rule, but delayed implementation until 90 days after the updated MOON was posted on its website. The CMS website includes a downloadable copy of the MOON and its accompanying instructions. CMS notes that manual instructions will be made available in the coming weeks.