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Hospitals must use new Medicare Outpatient Observation Notice
March 13, 2026

This article is for acute care hospitals and critical access hospitals caring for Medicare Advantage members under observation

Hospitals and Critical Access Hospitals (CAHs) are now required to use an updated version of the Medicare Outpatient Observation Notice (MOON) for Medicare Advantage members under outpatient observation for more than 24 hours.

The MOON explains why members aren’t inpatient and what their coverage and cost-sharing obligations will be.

Effective immediately,
use the updated MOON (CMS-10611) form, valid until February 28, 2029. You may use existing stock of the previous MOON form until April 20, 2026.

To
comply, hospitals must deliver the MOON to eligible Medicare Advantage patients no later than 36 hours after observation services begin and sooner if the patient is admitted, transferred, or discharged. To do so:

  1. Download the notice from the CMS website. It’s available in English and Spanish.
  2. List the reason why the patient is under outpatient observation rather than being admitted inpatient.
  3. Deliver a hard copy of the MOON to beneficiaries and enrollees.
  4. Explain the notice verbally to the member if observation exceeds 24 hours.
  5. Have the patient or representative sign and the notice to indicate that he or she has received it and understands its contents.
  6. Document all communications in the member’s record.

Resources

For more information, please refer to:

PC_022726-1F-1-ART