Notification of Observation Status Presented to AAHAM, September 22, 2016 Sharon Scruggs, Manger Revenue Cycle Fairfield Medical Center

The Act of Notifying Patients of Observation Status Not New The process of first notifying a patient of Observation Status was initiated at Fairfield Medical Center in 2009. Collaboration with Registration Staff, Case Management and Financial Representatives was a key that led to the success of providing Notification of Observation to patients. The front line staff defined how the process could work 24 X 7. Scripting even role playing with all stake holders provided a fairly seamless process based on the guidelines we know today, but will change with the implementation of MOON. We built Standard of Operation guidelines that was shared across departments. We first focused on Medicare patient’s but expanded to all patients.

Process To Provide Information on Observation Status UR/CASE MANAGEMENT COORDINATOR Screens all admissions to FMC for Admission Status and starts the process to notify patient. Notify and discuss with patient and present observation handouts. FINANCIAL COUNSELOR Is contacted by UR Coordinator or Patient Has all financial discussions with patient and offers assistance. Each Rep is also a Certified OSHIIP Counselor for CMS and ODI.

Tools Utilized To Communicate We developed an easy to read brochure and a fact sheet titled “Are you a Hospital Inpatient or Outpatient? Information and various publications available on CMS website www.medicare.gov/publications, i.e. “Medicare & You” Handbook. “How Medicare Covers Self-Administered Drugs Given in Hospital Settings”.

Current Sample of Notification Being Updated to Meet The MOON Requirements

What Do I Pay as an Inpatient? Are You a Hospital Inpatient or Outpatient? If You Have Medicare – Ask! Did you know that even if you stay in the hospital overnight, you might still be considered an “outpatient”? Your hospital status (whether the hospital considers you an “inpatient” or “outpatient”) affects how much you pay for hospital services (like X-rays, drugs, and lab tests) and may also affect whether Medicare will cover care you get in a skilled nursing facility (SNF). An inpatient admission begins the day you are formally admitted to the hospital with a doctor’s order. The day before you’re discharged is your last inpatient day. You’re an outpatient if you’re getting emergency department services, observation services, outpatient surgery, lab tests, or X-rays, and the doctor hasn’t written an order to admit you to the hospital as an inpatient. You may be in a bed on a Nursing Unit; stayed overnight and still be considered an OUTPATIENT. If you’re in the hospital more than a few hours, always ask a Financial Representative or Case Manager if you’re an inpatient or an outpatient... ★★★ What Do I Pay as an Inpatient? Medicare Part A covers inpatient hospital services. Generally this means that you will only have the Inpatient Deductible regardless if you are Medicare or Medicare Managed Care. Those patients who have Medicare Managed Care Plans should check their Plan document. What Do I Pay as an Outpatient? Medicare Part A covers inpatient hospital services. Generally this means that you will only have the Inpatient Deductible regardless if you are Medicare or Medicare Managed Care. Those patients who have Medicare Managed Care Plans should check their Plan document. If you have questions about observation status or your outpatient insurance benefits, you may ask to speak with a Case Manager at (740) 687-8060 or a Financial Counselor at (740) 687-8371 or 687-6743.

MOON Medicare Outpatient Observation Notice (“MOON” )

Notice of Observation Treatment Initially on August 6, 2016, the Notice of Observation Treatment and Implication for Care Eligibility Act (NOTICE Act) was to go into effect which requires hospitals to provide written and oral notice, within 36 hours, to patients who are in observation or other outpatient status for more than 24 hours.  The notice must explain the reason that the patient is an outpatient (and not an admitted inpatient) and describe the implications of that status both for cost-sharing in the hospital and for subsequent “eligibility for coverage” in a skilled nursing facility (SNF).  In final regulations for inpatient hospital reimbursement that were put on display at the Office of Federal Register on August 2, 2016, the Centers for Medicare & Medicaid Services (CMS) announces that the final rules, including rules to implement the NOTICE Act, become effective October 1, 2016 and that the required written notice to patients – the Medicare Outpatient Observation Notice (“MOON”) – will not become effective until 90 days following approval of the MOON by the Office of Management and Budget (OMB).  As of August 4, OMB had not approved the MOON.  What the CMS final rules mean is that the NOTICE Act will not be implemented until the late Fall of 2016, at the earliest

Notice of Observation Treatment With respect to the timing of notice, the final rules require that notice be given within 36 hours after observation services are initiated, or sooner, if the patient is transferred, discharged, or admitted.  The hospital can give the notice before the patient has received observation services for 24 hours, but CMS cautions that hospitals should not generally deliver the MOON at the initiation of observation services because “patients may be completely preoccupied with concern for their safety and well-being, as they may be unsure of their diagnosis at a time when the signs and symptoms of their presenting condition(s) may be at the height of their clinical acuity” and “also may be overwhelmed and confused by notices and hospital paperwork that are presented at the time, often simultaneously.”]

CHANGES WITH THE MOON Currently the changes that will impact our process with MOON is the regulations that surround the timing of the notification and the recommended template to be utilized by hospitals. Our process of Case Management presenting the notification and collaborating with the Financial Representative will not change.

Questions ??