Use of an observation status notice will be required beginning March 8.
As we reported in
November, Congress has required hospitals to explain to patients the implications of being an outpatient in observation status versus being an inpatient. The notice must be given in writing using a form known as the Medicare Outpatient Observation Notice (MOON).
That
form was awaiting review by the Office of Management and Budget but has recently been approved. Hospitals and critical access hospitals must begin using the MOON no later than
March 8, 2017.
The MOON form includes a free-text field that requires filling in the specific reason the individual is an outpatient and has not been admitted as an inpatient. As discussed in the November article, depending on the circumstances that explanation could begin with something like the following: “Because your physician needs more time to decide whether you need inpatient services or can be discharged from the hospital.” Alternatively, a check-box form could be developed by which the most common reasons are explained.
Related tool:
MOON Sample Check-Box Language
The reasons given should be as patient-specific as possible. And when delivering the MOON, staff must explain the notice and its content, document that an oral explanation was given, and answer all beneficiary questions to the best of their ability.
J. Stuart Showalter, JD, MFS, is a contributing editor for HFMA.
