Hospitals Must Provide Medicare Outpatient Observation Notice

Dec. 8, 2021

Hospitals and Critical Access Hospitals (CAH) are required to give the standardized Medicare Outpatient Observation Notice (MOON) to our Blue Cross Medicare AdvantageSM members who are under outpatient observation for more than 24 hours. The notice explains why the members aren’t inpatient and what their coverage and cost-sharing obligations will be.

Steps for Providers to Complete the MOON

  • Download the notice from the Centers for Medicare and Medicaid Services (CMS) website Learn more about third-party links
  • Fill in the reason the member is outpatient rather than inpatient
  • Explain the notice verbally to the member if they are in observation more than 24 hours
  • Have the member sign to confirm they received and understand the notice. If the member declines, the staff member who provided the notice must certify that it was presented.
  • Document all member communications regarding the MOON process in members’ records

If the patient is admitted, transferred, or released, the notice must be completed no later than 36 hours after observation begins or sooner.

Learn more from CMS' notice instructions Learn more about third-party links


The information provided here is only intended to be a summary of the law that have been enacted and is not intended to be an exhaustive description of the law or a legal opinion of such law. If you have any questions regarding the law mentioned here, you should consult with your legal advisor.