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The Centers for Medicare & Medicaid Services (CMS) has added the Medicare Outpatient Observation Notice (MOON) to an already confusing array of documents that hospitals are required to give patients — and it’s up to case managers to make sure patients receive the right documents at the right time so the hospital stays compliant.
Now patients receiving observation services for more than 24 hours must be given the MOON to inform them of potential out-of-pocket expenses; admitted patients must receive the Important Message (IM) from Medicare, notifying them of their right to appeal their discharge; and when a patient is about to receive services that are not covered, the hospital should deliver one of the Hospital-Issued Notices of Noncoverage (HINNs).
“Case managers should be conscious of the fact that delivery of these forms is more than just another task,” says Jackie Birmingham, RN, BSN, MS, clinical leadership for naviHealth, a Cardinal Health Company based in Newton, MA, that specializes in transition management. Not following the CMS guidelines could affect the hospital’s reimbursement, increase the risk of audit, and impede the patient’s ability to understand what his or her rights are and what the hospital expects of the patient, she adds.
The only documents that CMS requires hospitals to deliver to patients are the MOON and the IM, Birmingham points out. The other notices (HINNs) are used when the circumstances arise.
“HINNs notify patients that they may get a bill if the care is denied. If patients have a financial risk and the hospital doesn’t give them a HINN, the hospital can’t bill the patient,” she says. (For more information on HINNs and how and when to deliver them, see related article in this issue.)
Delivering the IM, the MOON, or a HINN when appropriate is more than just following the rules and regulations, says Beverly Cunningham, RN, MS, consultant and partner at Oklahoma-based Case Management Concepts. “It’s doing the right thing for patients as well as keeping the hospital compliant,” she adds.
Compliance issues have become extremely complicated and confusing, adds Mindy Owen, RN, CRRN, CCM, principal owner of Phoenix Healthcare Associates in Coral Springs, FL, and senior consultant for the Center for Case Management.
“When healthcare professionals have trouble understanding the...