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Second Opinion

Learn about policy issues important to medical schools and teaching hospitals, with Executive Vice President Atul Grover, M.D., Ph.D.

Washington Highlights

CMS Posts FAQs for the Medicare Outpatient Observation Notice to Website

March 17, 2017—The Centers for Medicare and Medicaid Services (CMS) March 8 posted frequently asked questions (FAQs) for the Medicare Outpatient Observation Notice (MOON) to its website. The MOON is a standardized notice to inform Medicare beneficiaries that they are outpatients receiving observation services and are not inpatients of a hospital or critical access hospital.  

CMS provides guidance regarding the free-text field, which is used to provide a clinical rationale for why the beneficiary is receiving observation care as an outpatient. CMS will not provide specific language or examples for the free-text field; however, the MOON should explain that:

  • The physician has ordered outpatient observation services in order to evaluate the beneficiary’s symptom(s) and diagnosis if known; and

  • The beneficiary’s condition and symptoms will continue to be evaluated to assess whether they will need to be admitted as an inpatient or whether they will be transferred or discharged from the hospital.

Additionally, providers may use pre-populated check boxes with common clinical explanations as long as a free-text field is provided for circumstances that do not fit within the pre-populated check boxes.

Finally, CMS allows providers to adjust or modify the MOON document text as permitted by CMS guidance. However, the OMB-approved standardized formatting of the document may not be modified.

The implementation date for the MOON was March 8.

Contact:

Ayeisha Cox, J.D.
Hospital Policy & Regulatory Specialist
Telephone: 202-282-0482
Email: aycox@aamc.org

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Jason Kleinman
Sr. Legislative Analyst, Govt. Relations
Telephone: 202-903-0806
Email: jkleinman@aamc.org