Q&A: Missed patient notification

Q: If our organization failed to provide the Medicare Outpatient Observation Notice (MOON) or the Important Message from Medicare (IM) form to a patient during the chaos of the novel coronavirus (COVID-19) pandemic, should we avoid submitting a Medicare claim for the case?

A: Although CMS issued a plethora of waivers, it did not waive the need to proive patients with new versions of the MOON, IM, and the Detailed Notice of Discharge (DND). It did, however, delay the effective date of the new versions of these forms from April 1 to May 1. Additionally, case managers are permitted to discuss the information over the phone instead of in person.

But a delivery to the patient needs to be made. If your organization failed to provide these notifications to patients, you should still submit a Medicare claim for the case, says Ronald Hirsch, MD, FACP, CHCQM, vice president at R1 Physician Advisory Services in Chicago.

“I don’t see how CMS will hold you at fault in a situation like this,” he says.

Editor's Note: This topic was originally addressed in the June issue of Case Management Monthly.