Q&A: Observation Care for CAHs

Q. In last week’s question about the Medicare Outpatient Observation Notice (MOON) in critical access hospitals (CAH), you stated that CAHs capped at 48 hours of observation. My understanding is that under the 2-midnight rule CAHs cannot go past two midnights of observation care if the patient has Medicare as a payer.

A. You are correct. CAHs can’t go beyond two midnights for observation patients. For that matter, neither can IPPS hospitals. If you are wondering whether CAHs are exempt from the MOON notice, I don’t believe they would be since the issues for the patient are the same in CAHs as in IPPS hospitals.     

Deborah Hale, CCS, CCDS, president and CEO of Administrative Consultant Service, LLC, in Shawnee, Oklahoma, answered this question.

Need expert advice? Email your questions for consideration in the Revenue Cycle Daily Advisor. Note: We do not guarantee that all questions will be answered.