CMS to Finalize Medicare Observation Notification Form

September 8, 2016

WSHA is in the process of preparing materials to help member hospitals meet federal observation notification requirements. As part of its inpatient final rule , the Centers for Medicare and Medicaid Services (CMS) delayed the implementation of requirements under the Notice of Observation Treatment and Implication for Care Eligibility (NOTICE) Act until a date after the standard Medicare Outpatient Observation Notification (MOON) form completes the process required under the public records act.  The comment period ended September 1.  The American Hospital Association provided helpful recommendations to CMS regarding the form’s format and content, to avoid unnecessary burden to hospitals and ensure the form serves its primary function as a patient notification. WSHA supports the recommendations made by the AHA.

Next, CMS will finalize the form and provide a specific implementation date for hospitals on the CMS Beneficiary Notices Initiative Web site.  That implementation date will likely be three to four months from now.

After the MOON form is finalized, WSHA will provide a bulletin outlining the requirements of hospitals under the NOTICE Act.   We also plan to schedule a webinar to allow hospitals an opportunity to share best practices for implementation. (Andrew Busz,


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