Medicare Outpatient Observation Notice (MOON) Requirements Took Effect March 8, 2017

Last Updated: Feb 23, 2017

Effective March 8, 2017, all hospitals and critical access hospitals (CAHs) are required to provide notice informing Medicare beneficiaries who receive observation services as outpatients for more than 24 hours that they are an outpatient receiving observation status, NOT an inpatient of the hospital or CAH.

The notice, called the Medicare Outpatient Observation Notice (MOON), is required as a result of the Federal Notice of Observation Treatment and Implication for Care Eligibility Act (NOTICE Act) which was passed on Aug. 6, 2015. The NOTICE Act requires all hospitals and CAHs to provide written and oral notification under specified guidelines.

The Centers for Medicare and Medicaid Services (CMS) offers forms and instructions for complying with Moon requirements on its website here.

According to CMS, additional MOON requirements include:

  • Hospitals and CAHs may deliver the MOON to individuals receiving observation services as an outpatient before such individuals have received more than 24 hours of observation services. The notice must be provided no later than 36 hours after observation services are initiated or, if sooner, upon release.
  • An oral explanation of the MOON must be provided, and a signature must be obtained from the individual, or a person acting on such individual's behalf, to acknowledge receipt. If the beneficiary or individual acting on their behalf refuses to sign the MOON, the staff member of the hospital or CAH providing the notice must sign the notice to certify that notification was presented.

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