Implementation of a System Process to Improve Compliance with the NOTICE Act

Abstract

Problem: The current practice at a large urban medical center did not include a standardized process for the use of the new Medicare Outpatient Observation Notification (MOON) form; patients were not being informed about the implications of the cost of care related to being placed in observation status (OBS). Objective: The aim of this scholarly project was to implement and evaluate a standardized process for implementing the Notice of Observation Treatment and Implication for Care Eligibility Act, or NOTICE Act including a policy and procedure (P&P) and a teaching plan to deliver the MOON form. Design: This quality improvement project evaluated the implementation of a standardized process including the use of a policy and procedure to formally direct how the MOON form was delivered at a large urban academic medical center. Sample: A convenience sample of 346 Medicare beneficiaries who arrived at the medical center through the emergency department and were placed in OBS during a four week data-collection period. Methods: The DNP Project Leader (PL) developed a P&P and used one-on-one sessions to train and evaluate each of the Clinical Resource Specialists (n=12) to deliver the MOON form to these patients. The PL collected data for four weeks using chart audits on the rates of completion for the MOON. Additional reports were generated to identify when the MOON was not delivered or not delivered within 36 hours, the time mandated by Medicare. Results: There were 346 Medicare beneficiaries placed in OBS during the four weeks; 43 patients were changed to inpatient status or discharged before 24 hours, leaving 303 patients placed in OBS. Of those, 253 (83.5%) had a completed MOON form documented, 241 (95.6%) of which were delivered to the patient before 36 hours. Fifty (16.5%) patients did not receive a MOON form. Implications: Putting a standardized P&P into use could facilitate the standardization of the teaching of all providers and can help to ensure compliance with the NOTICE Act. It is anticipated that if providers are taught the standard and its implications for both the patient and the organization, providers will be better prepared to communicate this information to the patients in a consistent manner.