Q&A: Managing the Distribution of MOON

Q. How do you suggest we manage the need to give the MOON notice after 24 hours of care?

A. That’s going to be a challenge and certainly you're going to have to be watching the clock, because you're counting for the 2-midnight rule based upon the time the patient began to receive outpatient services to determine when the patient needs to be admitted—you're also counting based on when the patient first began to receive observation services to determine the number of hours to be billed.  But when you're counting for the time frame to issue the MOON, you're counting from the date and time the physician gave the order to provide observation services. The 2-midnight rule is talking about midnights and the MOON is talking about hours, so we really have some conflicting time frames here that could be incredibly confusing. Don’t get those three issues confused. You still want to count, not from the beginning of the order, but from the beginning of the service for your inpatient determinations. For the determination that a patient needs to receive a MOON, you start counting toward or at the time of the order.

First of all, you have to decide who is going to be responsible for issuing the notice and counting the various time requirements. Your electronic record may be able to alert you at 24 hours from the time of the observation order that the MOON must be given and then perhaps it could also warn you when the 36-hour time period is about to expire and the MOON must be given if it has not already been. I think you're going to need some electronic notices and if you're going to rely on the nursing, case management, or utilization review staff to issue these MOONs, then I recommend doing some roleplay to ensure that they understand how and when to deliver the notice.

Deborah Hale, CCS, CCDS, president and CEO of Administrative Consultant Service, LLC, in Shawnee, Oklahoma, answered this question.

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