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PUBLIC POLICY UPDATES

CMS Issues Updates on the MOON, Important Message and Detailed Notice Discharge


Posted on: 1/17/2020

The MOON, Important Message and Detailed Notice of Discharge are three CMS required forms well known to hospitals and health systems case management practice. These three forms were recently updated. Please find below a brief synopsis of those changes and what you need to be aware of for your practice.

On January 7, 2020, the Office of Management and Budget (OMB) also renewed the Medicare Outpatient Observation Notice (MOON) (CMS-10611). No significant change to the form or process to note with this update. Per CMS, ‘please note the MOON is unchanged from its current version and only the expiration date is different on this renewed notice’. Hospitals are required to use the new MOON beginning April 1, 2020. Both the previous and new versions of the notice are acceptable for use through March 31, 2020. CMS.gov MOON >>>

The changes to the next two forms are more impactful. On January 7, 2020, the Office of Management and Budget (OMB) renewed the Important Message (IM) (CMS-10065) and the Detailed Notice of Discharge (DND) (CMS-10066). Case Managers should note that the IM has been revised and has a new CMS Form number (CMS-10065), it was formerly the CMS-R-193. Hospitals are required to use the new IM and DND beginning April 1, 2020. Both the previous and new versions of the notices are acceptable for use through March 31, 2020. CMS.gov Discharge Appeal Notices >>>

The update to the IM includes updated form and instructions. The IM form now includes a space to add the beneficiary/patient’s Medicare health plan name and telephone number. The IM form instructions for ‘Bullet 6’ indicates that ‘The plan’s name and contact information must be displayed here for the enrollee’s use in case an expedited appeal is requested or in the event the enrollee or QIO seeks the plan’s identification.’

The update to the DND now requires the hospital to provide additional detail on ‘facts used to make the decision’, ‘detailed explanation why the hospital stay is no longer covered’, ‘specific Medicare coverage rules and policy used to make this decision’, and finally the ‘plan policy provision or rationale used in making the decision’ if a Medicare health plan involved. This form also has been updated to include a space for the Medicare health plan (MAP) if appropriate.

These changes could have a significant impact to the day-to-day case management practice and the administrative burden to comply with these new requirements. CMS has not provided additional clarity with the release of the updated forms and instructions to address the challenges a hospital or health system case management may face in trying to comply with these new updates.

We encourage you to visit the ACMA Learning Link Forum in the ‘Communities’ section of your membership site to discuss challenges your organization is facing as well as to learn what others are doing to overcome these challenges. You can also share your concerns with this rule change by emailing CMS >>>.

ACMA will continue to monitor these CMS updates and keep you informed as CMS unfolds additional guidance for implementation. We will also continue to assess the impact of these changes as we hear your concerns about this change.

--- ACMA Public Policy Committee

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