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CHA Issues Comments on MOON Proposed Form, Instructions

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CHA has submitted the attached draft comment letter on the proposed Medicare Outpatient Observation Notice (MOON) form and its instructions. The MOON fulfills the Notice of Observation Treatment and Implication for Care Eligibility (NOTICE) Act’s requirement that hospitals and critical access hospitals provide written and oral notification to all Medicare-eligible beneficiaries receiving observation services as outpatients for more than 24 hours. The Office of Management and Budget (OMB) is accepting comments on the updated MOON and instructions through Sept. 1.

In the letter, CHA strongly urges several changes, including changing the free-text box that requires hospitals to complete the statement “you are not an inpatient because…” to a standardized statement about observation status. In addition, CHA urges a delay in implementation and/or enforcement to ensure hospitals have ample time to train staff, update procedures and integrate the form into electronic health records.

The delay would also give CMS adequate time to provide guidance to the state survey agencies, as well as additional guidance to hospitals. CHA suggests the MOON be translated into additional languages beyond English and Spanish (e.g., Chinese, Tagalog, Korean and Vietnamese) to meet the needs of the diverse community of Medicare beneficiaries.

The updated MOON and its instructions can be found on the CMS website.