Develop Policies and Procedures to Overcome the Challenges Surrounding the Issuance of the MOON Form
The NOTICE Act requires the development of the MOON (Medicare Outpatient Observation Notice) form, and subsequent implementation by hospitals has raised a number of different questions particularly the exact difference in determining inpatient status versus outpatient observation. The issuance of the MOON form is normally routine, but at times challenges can arise. In this session, expert speaker Duane C. Abbey, Ph.D. will address the development of policies and procedures surrounding the issuance of the MOON form based upon challenges in implementation.
Of particular concern is the development of the knowledge base for competent personnel to present the form and to then have the ability to answer any and all questions surrounding the distinctions between being an inpatient versus being an outpatient. Proper compliance in this area is a difficult goal, and litigation at some level should be anticipated in the future, however, this session will provide all the information pertinent to the MOON form needed for compliance with the NOTICE Act
- Review the differences between inpatient status and observation in outpatient status
- Review of the MOON form and the information that must be provided
- Review and discuss the provisions within the NOTICE Act – What does the NOTICE Act mandate that hospitals do?
- Why did Congress get into this specific area?
- Discuss and assess the guidance given by CMS relative to notifying Medicare beneficiaries as to their status including formal and sub regulatory guidance
- Analyze form, format and signature requirements
- Are there any challenges with the MOON form?
- Appreciate the consideration for SNF coverage in this process
- Does this have anything to do with the ‘Over 2-Midnight Rule’?
- What is this ‘Over 3-Midnight Rule’ and how does this affect SNF coverage?
- Review the use of and impact of Condition Code 44
- Assess how the patients, physicians, and hospital are affected by this notice process
- Discuss special issues surrounding inpatient versus observation services – Are there differences in admission criteria for inpatient versus observation?
- What if we place a patient in a bed overnight in preparation for a therapeutic service?
- What if we simply provide a post-surgery bed overnight?
- Discuss the need for well-trained individuals to present the MOON form in order to address questions and challenges for admission status
- Will the Medicare beneficiary (family, representatives) understand what is going on?
- Will physicians need to be involved in the NOTICE requirements?
- Appreciate the need to develop written policies and procedures surrounding the MOON form as well as the proper determination of outpatient versus impatient status
- What if there is an appeal of the denial of an inpatient admission?
- What if the patient and/or patient’s family objects to the patient not be classified as an inpatient?
- Learn about the development of a team effort between nursing staff, physicians and Utilization Review
- Observation versus Inpatient Admissions
- The NOTICE Act and MOON Form
- Over 2-Midnight Rule
- Coding, billing and payment issues
- Development of policies and procedures
- NOTICE Act and MOON Form
- Requirements in the Act
- Notification of Observation versus Inpatient Services
- Explanation of Differences
- Verification of Understanding and Receipt
- Using the MOON Form
- Possible conflicts between physicians and UR
- Developing written policies and procedures
- Development of team effort between nurses, physicians and UR
- CMS Guidance
- Form and format
- Signature requirements
- Processes and procedures
- Retention of MOON Forms
- Compliance issues
- Special Concerns
- Beneficiary impact
- Utilization review involvement
- Over 2-Midnight Rule – Inpatient Admission
- Self-Administrable Drugs
- Condition Code 44
- Over 3-Midnight Rule – SNF Services
- Inpatient Admission Criteria – Commercial Products
- Appeal Situations
- Beneficiary Education
- MAC and QIO Involvement
- Transfer cases
- Case studies
Who Should Attend
All personnel involved with patient status including:
- Clinical personnel
- Utilization review personnel
- Compliance and management personnel
- Coding/billing personnel
- All others involved with inpatient admission and observation services
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