Observation Services Notification — New State and Federal Requirements
Complying with CMS’ MOON and California’s SB 1076


As of Jan. 1, SB 1076 requires hospitals to provide a written notice to certain patients receiving observation services. Beginning March 8, CMS will require hospitals to provide the Medicare Outpatient Observation Notice (MOON) and verbal notification to Medicare beneficiaries receiving outpatient observation services.

Both state and federal notice requirements pose significant challenges. What to include in your P&Ps, documentation, and management of patient questions and disagreements are a few of the issues hospitals must address to comply. Listen and learn how to manage these and other facets of the new requirements.

Recommended for:
Health care professionals including: chief medical officers, chief nursing officers, in-house general counsel, compliance officers, case managers, emergency department staff, discharge planners, and licensing and accreditation professionals.


CMS’ Medicare Outpatient Observation Notice (MOON) and
New State Law SB 1076

  • Defining observation services
  • Written and verbal notifications
  • State vs. federal timelines for informing patients
  • Which patients must receive notification
  • Requirements of dedicated observation units

Crosswalk: State vs. Federal Requirements      

The Law in Practice — Operational Considerations

  • Developing policies and procedures
  • Who provides notification
  • Responding to patient questions, disagreements
  • Documentation and recordkeeping
  • Translation and interpreter requirements
  • Combining state and federal forms, or keep separate
  • MOON form and free text area


Debby Rogers, RN, MS, FAEN, is vice president of clinical performance and transformation at the California Hospital Association. In this role, Rogers strengthens policy and regulatory leadership on quality and performance issues. In addition, she provides clinical and regulatory expertise in the transformation of health care delivery. Most recently, Rogers served as the health care reform consultant to the Assembly Republican Caucus. Prior to working for the Assembly, she was the deputy director for the Center for Health Care Quality at the California Department of Public Health, served as CHA’s vice president for quality and emergency services, and was associate secretary for legislative affairs for the California Health and Human Services Agency. Rogers spent 10 years with the Legislature as a consultant on health and human services issues and has many years of experience as a registered nurse, base hospital coordinator, emergency clinical nurse specialist and nurse manager.

Patricia Blaisdell, FACHE, is vice president of the Continuum of Care for the California Hospital Association. Ms. Blaisdell provides membership support and advocacy for hospital-based medical rehabilitation and skilled-nursing services, policy analysis and interpretation, communication with regulatory bodies and third-party payers, and planning and implementation of educational programs. Patricia has more than 25 years of experience in hospital and health care management in acute and post-acute settings. She has particular expertise in clinical operations and reimbursement across the post-acute continuum of care and is a Fellow of the American College of Healthcare Executives. Patricia received her bachelor’s degree from the University of New Hampshire, a master’s degree in speech/language pathology from the University of Connecticut, and a master’s degree in health care management from Rensselaer at Hartford.

Virginia B. Yamashiro, RN
Chief, Field Operations — Non Long Term Care
Licensing and Certification Program
California Department of Public Health

Chelsea Driscoll
Policy Manager
Licensing and Certification Program
California Department of Public Health

Jackie Lincer
Branch Chief
Licensing and Certification Program
California Department of Public Health