This week's note discusses the order and certification requirement for critical access hospitals (CAH), including the proposal in the FY 2018 IPPS proposed rule to reprioritize the review of CAH inpatient admissions.
Just before the MOON requirement became effective March 8, CMS added another hoop to jump through in an open door forum held February 28.The discussion in that forum forced many organizations to change course at the last minute as CMS announced it would not allow pre-populated check boxes in the free-text field of the MOON designated for describing clinical reasons for the service the patient receives. Organizations that had listened to experts touting the value of adding check boxes with specific rationale to the MOON were forced to revamp the form shortly before implementation.
Do we give a MOON letter to a patient who was originally assigned to inpatient status, but then reassigned to observation services when the utilization review committee determined that he or she did not meet inpatient criteria. In this instance, condition code 44 was used and the patient’s status was changed to observation. If we are required to deliver the MOON form in this situation, should it be given to the patient at the same time as the patient is given information on condition code 44?