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CMS Offers Medicare Outpatient Observation Notice Guidance

The Centers for Medicare & Medicaid Services (CMS) has updated the Medicare claims processing manual to include guidance for using the Medicare Outpatient Observation Notice (MOON) form.

The form was developed to inform all Medicare beneficiaries when they are an outpatient receiving observation services, and are not an inpatient of the hospital. In December 2016, CMS posted the final MOON form and accompanying form instructions, which hospitals must provide to Medicare beneficiaries who receive outpatient observation services for longer than 24 hours. All hospitals and critical access hospitals will be required to provide the MOON to applicable patients beginning March 8.

The new guidance outlines:

  • the scope of the requirements;
  • how and when hospitals must deliver the notice;
  • how to handle a beneficiary refusing to sign the notice, or needing a representative to sign;
  • ensuring beneficiaries comprehend the notice;
  • what can be included in the “additional information” field on the notice;
  • retention requirements; and
  • how the notices intersect with state laws.

Contact Director of Policy Erin O’Malley at or 202.585.0127 with questions.



About the Author

Michelle Rosenfeld is manager of communications at America's Essential Hospitals.

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