No later than Wednesday of this week—March 8, 2017—hospitals (including critical access hospitals [CAH]) are required to meet the newest of Medicare’s numerous hospital notification requirements. Under the Notice of Observation Treatment and Implication for Care Eligibility (NOTICE) Act, hospitals must provide both written and oral notice regarding the outpatient nature of observation and the resulting implications to all Medicare beneficiaries who receive observation services for more than 24 hours. This notice must be provided in a prescribed form (the Medicare Outpatient Observation Notice [MOON]) within 36 hours of when observation care began and must meet certain additional requirements with respect to delivery, documentation, etc.
In several recent reports, the Office of Inspector General (OIG) determined that providers are, on average, variant from expected volumes on both short stay inpatient and long stay observation cases. What was not made clear in the OIG report is the reason why it believes such variances exist. The answer to this question likely rests within the details of how hospitals have adjusted (or not adjusted) to the use and application of “new criteria” in their daily and ongoing Medicare billing compliance processes.
This week’s Medicare updates include the April 2017 Update of the Hospital Outpatient Prospective Payment System; the April 2017 Update of the Ambulatory Surgical Center Payment System; an National Coverage Analysis for Supervised Exercise Therapy (SET) for Symptomatic Peripheral Artery Disease (PAD); and more!
Distributed denial of service (DDoS) attacks are one of the oldest cyberattacks in the books, but they’re still common and can knock out vital services, leaving patients and providers unable to access EHRs and other systems.
On February 2, CMS Revised its Medicare Outpatient Observation Notice (MOON) instructions in MLN Matters 9935, but the document provided little new information, primarily reiterating much of what was already said in the 2017 IPPS final rule.
“CMS went into great detail on delivery of the MOON when the patient is not competent, but completely ignored providing details on the amount of specificity needed in completing the box specifying ‘the reason the patient is outpatient,’ ” says Ronald Hirsch, MD, FACP, CHCQM, vice president of the Regulations and Education Group at R1 Physician Advisory Services in Chicago. “This was one of the least helpful publications I have seen from CMS.”
For case management professionals, keeping up with the MOON revisions has been a challenge.
This week's note from the instructor discusses implementation of the Medicare Outpatient Observation Notice (MOON) and the implementation deadline, which is just a week away.
