“Finally Friday!” CMS Proposes the MOON & Other Changes for the NOTICE Act

FRIDAY May 13, 2016:

CMS Proposes the MOON
& Other Changes
to Implement the NOTICE Act

A Proposed Rule Inside A Proposed Rule

OR

How CMS can defy Congress with a straight face

CMS, when challenged by US Senators about never studying the effect their 2MN Rule had on beneficiaries, CMS did nothing. Now, they actually develop a program that directly negates the purpose of a law passed by Congress.

CMS, when challenged by US Senators about never studying the effect their 2MN Rule had on beneficiaries, CMS did nothing. Now, they actually developed a program that directly negates the purpose of a law passed by Congress.

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THIS WEEK, our panelists will go over the MOON, but not literally. Hardly. Since CMS published the MOON, a form they propose to use to notify certain beneficiaries of their status as Outpatients receiving OBS services, we’ve not heard of any providers or provider support organizations who are very supportive of its use. So, we thought we’d go over the proposal and the use of the form.

Frankly, the rules for MOON’s use seem to show once again, the difficulty – if not the lack of foresight – CMS faces in their attempts to reduce reimbursements without a concomitant negative effect on beneficiaries. And as we all know, while the US Senate may complain about such short-sightedness, CMS has a habit of taking no actions to address complaints or suggestions made by the Congressional branch of the government.

We will be discussing:

  • Why is OBS such a hangup for CMS?
  • Why MOON is only required if you bill Medicare for OBS
  • Why MOON is really only about CMS, not the beneficiary
  • Why MOON does not explain the reason a patient is Outpatient
  • How MOON is not appealable, unlike all other such notices
  • How MOON directly thwarts the purpose of the NOTICE Act

And you should review our latest article on all this:

CMS Offers the MOON to fulfill NOTICE requirements

 

So join us, share your own insights and bring your questions for us!

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