Q&A: Who should fill out the MOON?

Q. Do you have any recommendations as to who is best suited to fill out the Medicare Outpatient Observation Notice (MOON)? Why?

A. We are expecting additional guidance from CMS on this. As it stands now, I feel a registration clerk can present the form provided case managers and financial counselors are available if the patient has questions about the form.

The reason the patient is not inpatient is typically due to the fact that the patient does not meet the requirements spelled out in the 2-midnight rule to be admitted as inpatient. It is not likely that CMS would expect the physician to have to indicate a clinical reason, such as “your asthma attack is only mild and should get better in a day,” in instances when a patient does not meet admission criteria.

Editor’s note: This question was answered by Ronald Hirsch, MD, FACP, CHCQM, of R1 Physician Advisory Services in Chicago.

Need expert advice? Email your questions for consideration in the Revenue Cycle Daily Advisor. Note: We do not guarantee that all questions will be answered.