Q&A: Failure to Deliver MOON

Q: What is the consequence if we miss giving a patient who meets the Medicare Outpatient Observation Notice (MOON) criteria the notice? Has there been an update if the observation hours will need a modifier or the claim a value or condition code to show that the notice was given?

A: CMS has not stated the consequence of not issuing a MOON. CMS will be updating its survey tools in the future and may address it there. CMS stated in the IPPS final rule that, "all monitoring and enforcement of the MOON will be consistent with our oversight procedures for other hospital delivered notices."

Ronald Hirsch, MD, FACP, CHCQM, vice president of the Regulations and Education Group at Accretive Health in Chicago, answered this question.

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