January 17, 2019
Medicare Outpatient Observation Notice (MOON)
As a reminder, in 2017 the Centers for Medicare and Medicaid Services (CMS) issued a ruling regarding notification procedures for Medicare patients receiving outpatient observation services for more than 24 hours. The rule requires hospitals and critical access hospitals to provide notice (known as a Medicare Outpatient Observation Notice, or MOON) to patients classified as observation and not inpatient. Outpatient Observation Services are provided in a hospital, but without the patient being admitted as an inpatient.
Why?
The new rule helps Medicare patients understand their care and related costs. Medicare Part A covers inpatient costs, while Medicare Part B covers outpatient observation care. As a result, Medicare patients receiving outpatient observation care could be responsible for higher out-of-pocket costs.
How?
The notice must be delivered to the patient or their representative within 36 hours after observation services are initiated. While the patient may read the notice on an electronic screen, CMS requires that hospitals give patients the option of reading the information on paper.
If the patient has a representative who isn’t physically present, CMS allows hospital staff to give the notice by telephone, but they must deliver a hard copy to the representative.
Information about MOON is available on the CMS website at CMS.gov. A courtesy patient notice form is available on our website and instructions to help you fill out the form.
Billing regulations for dual eligible Medicare patients
As a reminder, dual eligible patients are those who receive both Medicare and Medicaid benefits. It’s important to know that The Balanced Budget Act of 1997 prohibits all providers from directly billing Qualified Medicare Beneficiaries (QMB) for additional fees or cost shares. Providers caring for these patients must accept the payment received from Medicare, the Medicare Advantage plan, or bill Medicaid for additional costs associated with the care provided. Providers who directly bill a QMB patient for additional cost shares are at risk for sanctions from the Centers for Medicare and Medicaid Services (CMS).
To learn more about dual eligible patients, go to the CMS website for helpful resources.
You can find information for both rulings on our Medicare Advantage home page. Look for CMS updates and Provider news.