Annual Reminder: Medicare Outpatient Observation Notice Required

Posted January 5, 2021

As of March 7, 2017, hospitals and Critical Access Hospitals (CAH) are required to give the standardized Medicare Outpatient Observation Notice (MOON) to people who receive Medicare benefits and are observed as outpatients for more than 24 hours. This includes people with Blue Cross Medicare Advantage (PPO)^SM, Blue Cross Medicare Advantage (HMO)^SM, Blue Cross Community MMAI (Medicare-Medicaid Plan)^SM, Blue Cross Group Medicare Advantage (HMO)^SM, Blue Cross Group Medicare Advantage (PPO)^SM and Blue Cross Group Medicare Advantage Open Access (PPO)^SM health plans. The notice explains why the members aren’t inpatients and what their coverage and cost-sharing obligations will be.

Steps for providers to complete the MOON

• Download the notice from the Centers for Medicare & Medicaid Services (CMS) website. 
• Fill in the reason the member is outpatient rather than inpatient.
• Explain the notice verbally to the member.
• Have the member sign to confirm they received and understand the notice. If the member declines, the staff member who provided the notice must certify that it was presented.

The notice must be completed no later than 36 hours after observation begins or sooner if the patient is admitted, transferred or released.

The MOON and what to do with it can be found here. 

The information provided here is only intended to be a summary of the law that have been enacted and is not intended to be an exhaustive description of the law or a legal opinion of such law. If you have any questions regarding the law mentioned here, you should consult with your legal advisor.

The material presented here is for informational/educational purposes only, is not intended to be medical advice or a definitive source for coding claims and is not a substitute for the independent medical judgment of a physician or other health care provider. Health care providers are encouraged to exercise their own independent medical judgment based upon their evaluation of their patients’ conditions and all available information, and to submit claims using the most appropriate code(s) based upon the medical record documentation and coding guidelines and reference materials. References to other third-party sources or organizations are not a representation, warranty or endorsement of such organization. Any questions regarding those organizations should be addressed to them directly.