CMS releases MOON FAQs

CMS released eight frequently asked questions (FAQ) related to the Medicare Outpatient Observation Notice (MOON) March 8, the date by which all hospitals and critical access hospitals (CAH) were required to begin delivering the new patient notice.

The FAQs reinforce that psychiatric hospitals must comply with the Notice of Observation Treatment and Implication for Care Eligibility (NOTICE) Act and MOON.

Prior to the release of the FAQs, the last MOON update came February 2 when CMS released the revised MLN Matters 9935. However, the revision provided little new information for hospitals that were searching for answers to ease the burden of MOON compliance.

The FAQs provide guidance on many of the questions hospitals have asked Revenue Cycle Advisor this year. Much of the FAQ document is focused on how to complete the first field on the MOON form, which requires the hospital to state why the patient is not classified as inpatient. The FAQs state that this field is intended to provide clinical rationale for the patient’s observation status in terms that the patient can reasonably understand. It should explain that the physician ordered observation to evaluate the patient and that the physician will continue to assess whether the patient should be admitted as inpatient, transferred, or discharged.

CMS currently has no plans to provide specific language for the free-text field on the MOON. However, it will permit hospitals to develop their own pre-populated checkboxes for this field as long as part of the field is still dedicated to free text to be used in scenarios when the checkboxes do not apply. This field is the only portion of the MOON hospitals are permitted to modify, according to the FAQs.

MOON instructions, along with English and Spanish versions of the form, are available on the CMS Beneficiary Notices Initiative website.