Georgia Medicare Hospital Outpatient Observation Coverage

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By Brevy Care Team · Last verified May 13, 2026

Hospital observation status is among the most consequential, most confusing, and most contested Medicare coverage issues affecting older adults today. The fundamental problem is this: a Medicare beneficiary admitted to a hospital from the emergency department may believe she is an "inpatient" based on the clinical reality of occupying a hospital bed, receiving intravenous medications, undergoing tests, and being seen by physicians and nurses around the clock, yet may be classified administratively as "outpatient observation" by the hospital. The classification has cascading financial and clinical consequences that often surprise beneficiaries and their families long after discharge.

Three consequences are most significant. First, skilled nursing facility coverage: Section 1861(i) of the Social Security Act requires a 3-day qualifying inpatient hospital stay before Medicare will cover post-acute skilled nursing facility care, and the implementing regulation at 42 CFR 409.30 makes clear that the 3 midnights must be spent as an inpatient, not in observation. A beneficiary who spends 3 nights in observation and is then transferred to a SNF for rehabilitation may face the SNF's full daily rate entirely out of pocket because Medicare will not cover the SNF stay. Second, cost-sharing structure: inpatient (Part A) admissions trigger a single inpatient deductible ($1,736 in 2026) that covers the first 60 days, while outpatient observation (Part B) triggers 20 percent coinsurance on each separate hospital service plus separate cost for self-administered drugs. For many beneficiaries, observation actually costs MORE than an inpatient admission would have. Third, drug coverage: patients in observation receive their home medications through the hospital pharmacy and these are typically billed at retail rates rather than through Medicare Part B coverage, leading to unexpected pharmacy charges that can run into hundreds of dollars for medications that would cost under $10 per month at the patient's regular pharmacy.

The regulatory framework governing observation status has evolved through three major milestones over the past decade. The Two-Midnight Rule, effective October 1, 2013, established a regulatory presumption that hospitalizations expected to span two midnights are appropriately billed as inpatient while those expected to span less than two midnights default to outpatient observation, with clinical judgment exceptions. The Notice of Observation Treatment and Implication for Care Eligibility Act of 2015 (NOTICE Act), with implementing requirements effective in 2017, requires hospitals to deliver the Medicare Outpatient Observation Notice (MOON, form CMS-10611) to Medicare beneficiaries who receive observation services for more than 24 hours, providing written notice of observation status and its SNF and cost-sharing consequences. The Alexander v Becerra class action established that Medicare beneficiaries have due process rights to appeal observation status when it affects SNF coverage, creating a post-discharge administrative appeal pathway that the Center for Medicare Advocacy and other advocacy organizations are now actively using to challenge observation classifications retroactively.

In Georgia, Medicare observation stays occur annually across the major hospital systems including Emory Healthcare's 11 hospitals, Wellstar Health System's 11 hospitals (the largest Georgia system), Piedmont Healthcare's 15-plus hospitals, Northside Hospital's Atlanta facilities, Atrium Health Navicent in Macon, Memorial Health in Savannah, Phoebe Putney Memorial Hospital in Albany, Augusta University Health, Grady Health System in Atlanta, and rural critical access hospitals across the state's 159 counties. The use of observation has expanded substantially since the Two-Midnight Rule took effect in 2013, driven by hospital utilization review committees applying clinical screening tools (InterQual, Milliman Care Guidelines) to admission decisions, the substantial difference between inpatient DRG payment and outpatient observation APC composite payment, and CMS audits of short-stay inpatient admissions that have made hospitals cautious about inpatient billing for stays under two midnights.

This guide is published by Brevy, the eldercare resource at brevy.com helping Georgia families understand and navigate Medicare observation status, the Two-Midnight Rule, MOON notification, the 3-day SNF qualifying stay requirement, Condition Code 44 in-hospital status escalation, post-discharge Alexander v Becerra appeals, the self-administered drug exclusion, and the practical realities of being classified as observation in Georgia hospitals. The information here is general educational content reflecting federal law and regulation as of May 2026. It is not personalized medical, legal, or financial advice. For specific Medicare observation questions, contact GeorgiaCares SHIP at 1-866-552-4464 for free Medicare counseling, the Center for Medicare Advocacy at 1-860-456-7790 for observation status appeals, or the Medicare Rights Center at 1-800-333-4114 for general Medicare advocacy support. :::

::: callout Key Takeaways

1. Section 1861(s)(2)(B) of the Social Security Act establishes Medicare Part B coverage for hospital services furnished to outpatients including observation services. 42 CFR 410.21 implements this provision. Observation is a hospital outpatient service paid under the Hospital Outpatient Prospective Payment System (OPPS) using the APC 8011 Comprehensive Observation Services composite payment methodology when the stay reaches the 8-hour threshold and meets other criteria.

2. The Two-Midnight Rule, effective October 1, 2013 and subsequently refined by CMS, establishes a regulatory presumption: hospitalizations expected to span two midnights are appropriately billed as inpatient, while those expected to span less than two midnights default to outpatient observation. Clinical judgment exceptions permit physicians to admit as inpatient when documented medical necessity supports it even with anticipated stays under two midnights. The CMS Inpatient Only List identifies procedures that are always inpatient regardless of length of stay.

3. The NOTICE Act of 2015 (Notice of Observation Treatment and Implication for Care Eligibility Act, with implementing requirements effective 2017) requires hospitals to deliver the Medicare Outpatient Observation Notice (MOON, form CMS-10611) to Medicare beneficiaries receiving observation services for more than 24 hours. The MOON must be delivered within 36 hours of beginning observation, must explain observation status and its consequences for SNF coverage and cost-sharing, and must be signed by the beneficiary or representative.

4. Section 1861(i) and 42 CFR 409.30 require a 3-day qualifying inpatient hospital stay before Medicare will cover post-acute skilled nursing facility care. The 3 midnights must be spent as inpatient, not in observation. Observation days do NOT count toward the 3-day requirement. A beneficiary who spends 3 nights in observation and then needs SNF rehabilitation will face the SNF's full daily rate entirely out of pocket because Medicare will not cover the SNF stay. The only exceptions are limited Skilled Nursing Facility 3-Day Rule Waivers for beneficiaries enrolled in qualifying Medicare Shared Savings Program ACOs.

5. Cost-sharing structure differs dramatically between inpatient and observation. Inpatient (Part A) triggers a single inpatient deductible ($1,736 in 2026) covering the first 60 days with no additional daily cost-sharing. Observation (Part B) triggers 20 percent coinsurance on each separate hospital service after the annual Part B deductible ($283 in 2026), plus separate cost for self-administered drugs (oral medications patients take at home are NOT covered by Part B in the outpatient hospital setting and are billed at retail rates). Medigap plans cover Part B coinsurance, substantially reducing observation cost-sharing for beneficiaries with Medigap.

6. Condition Code 44 permits in-hospital status change from observation to inpatient when the hospital's Utilization Review committee, the physician of record, and documentation supporting inpatient medical necessity all align. Condition Code 44 must be applied BEFORE patient discharge. Once applied, the entire stay is billed and counted as inpatient, affecting cost-sharing, SNF qualifying stay, and DRG payment. After discharge, Condition Code 44 cannot be used; post-discharge status changes require other processes including the Alexander v Becerra appeal pathway.

7. The Alexander v Becerra class action established Medicare beneficiaries' due process right to appeal observation status when it affects SNF coverage. CMS has been implementing an administrative appeals process for these post-discharge observation status challenges. The Center for Medicare Advocacy (1-860-456-7790) is the lead advocacy organization on observation status appeals.

8. Common conditions classified as observation include chest pain rule-out for ACS, syncope evaluation, TIA/stroke rule-out, mild GI bleed, mild heart failure exacerbation, mild pneumonia, dehydration, falls without major injury, medication reactions, cellulitis, and mild COPD/asthma exacerbation. Common conditions classified as inpatient include ICU admissions, major surgical procedures (CABG, joint replacement, neurosurgery), acute MI requiring intervention, severe pneumonia requiring ICU, major trauma, acute stroke with intervention, DKA requiring ICU, and hip fracture requiring surgical repair. :::

The clinical case: Margaret 78 Atlanta chest pain rule-out at Emory University Hospital

Consider Margaret, a 78-year-old retired Atlanta pharmacist with hypertension and hyperlipidemia on standard medical management. While gardening at her Decatur home on a warm spring morning, Margaret develops substernal chest pressure rated 5 out of 10 in severity, radiating slightly to her left shoulder. The pressure persists for 20 minutes despite rest. Margaret's daughter, alarmed, drives her to the Emory University Hospital emergency department. Initial evaluation includes EKG (showing nonspecific ST-T wave changes, no acute ST elevation), troponin (0.04, just at the upper limit of normal), chest X-ray (no acute findings), and physical examination. The ED physician determines that Margaret requires further evaluation to rule out acute coronary syndrome but the clinical presentation does not suggest acute STEMI or NSTEMI requiring emergent catheterization. The plan is to admit Margaret for serial troponin measurements, telemetry monitoring, and stress echocardiography.

At this admission decision point, the Emory utilization review process applies. Based on the InterQual screening criteria, the clinical presentation of chest pain rule-out with normal initial troponin and stable vital signs, the anticipated length of stay (likely one to two midnights pending stress test results), and the Two-Midnight Rule presumption, Emory's UR coordinator recommends observation status to the ED physician. The ED physician writes the admission order as "Observation status, chest pain rule-out." Margaret is transported to the Emory observation unit, an 18-bed dedicated unit on the 5th floor where she will be cared for over the next 30 to 48 hours.

The clinical care Margaret receives over the next 38 hours is identical to what she would receive as an inpatient. She is in a hospital bed. She has continuous cardiac telemetry. She has serial troponins drawn at 0, 3, 6, and 12 hours, all returning normal. She receives her home medications (lisinopril, atorvastatin, baby aspirin) through the hospital pharmacy. She is seen by the hospitalist team in the morning, by a cardiology consultant, and by nursing staff every shift. She undergoes a stress echocardiogram on the second morning, which is interpreted as normal without inducible ischemia. She is discharged after 38 hours with a clinical diagnosis of "atypical chest pain, ACS ruled out" and instructions to follow up with her primary care physician and cardiology outpatient.

At hour 25 of observation, the Emory nursing staff delivered Margaret the MOON (Medicare Outpatient Observation Notice, CMS-10611) as required by the NOTICE Act of 2015. The MOON explained that Margaret was receiving observation services as an outpatient, not as an inpatient. It explained that observation does not count toward the 3-day qualifying inpatient stay required for Medicare to cover a subsequent skilled nursing facility admission. It explained that Margaret would be responsible for Part B cost-sharing (20 percent coinsurance) on hospital services. It explained that self-administered drugs (her home medications administered during observation) would not be covered by Part B and would be billed at retail rates. Margaret signed acknowledgment of receipt.

The financial reality of Margaret's observation stay: Emory will bill Medicare under HCPCS code G0378 for hours of observation, and because Margaret's stay exceeded 8 hours and met the comprehensive observation criteria, the OPPS payment will be under APC 8011 Comprehensive Observation Services composite payment. Margaret will be responsible for the Part B deductible ($283 in 2026 if not already met for the year) and 20 percent coinsurance on the APC payment, plus separate charges for self-administered drugs (lisinopril, atorvastatin, aspirin during the stay, perhaps $80 to $120 total at retail). For Margaret, who holds a Medigap Plan G policy with BlueCross BlueShield, the Plan G coverage absorbs the Part B coinsurance after a small Plan G deductible, and her net out-of-pocket cost is essentially the self-administered drug charges (~$80-$120). Without Medigap, Margaret would face several hundred dollars in out-of-pocket costs for the same stay.

If Margaret's clinical course had been different and she had required SNF rehabilitation after discharge (perhaps because she was deconditioned, fell, or developed a complication), her observation classification would have created a critical problem. Medicare would not cover SNF because Margaret did not meet the 3-day inpatient qualifying stay requirement. Margaret would face the SNF's full daily rate entirely out of pocket, with no Medicare coverage. This is the scenario that has motivated decades of advocacy on observation status, the NOTICE Act, and the Alexander v Becerra litigation.

Section 1861(s)(2)(B) and 42 CFR 410.21: the statutory and regulatory foundation

Section 1861(s)(2)(B) of the Social Security Act establishes Medicare Part B coverage for "hospital services... incident to physicians' services rendered to outpatients." This provision is the statutory foundation for outpatient hospital services including observation. The implementing regulation at 42 CFR 410.21 provides:

"Medicare Part B pays for hospital services furnished to a beneficiary as an outpatient... including diagnostic services, therapeutic services, observation services, emergency department services, and other services furnished by a hospital to outpatients."

Observation services are paid under the Hospital Outpatient Prospective Payment System (OPPS) established by Section 1833(t) of the Social Security Act. Under OPPS, hospital outpatient services are grouped into Ambulatory Payment Classifications (APCs) and paid at predetermined APC rates. For observation services, the relevant APC is APC 8011 Comprehensive Observation Services, a composite APC that bundles the observation hours with associated visit and ancillary services into a single payment when the stay reaches the 8-hour threshold and meets other criteria.

Hospital observation must be physician-ordered, must include active medical care (not just bed and food), must include appropriate documentation supporting the observation service, and must be billed using HCPCS code G0378 for each hour of observation service. The order for observation should specify the clinical reason for observation (e.g., "Observation, chest pain rule-out, monitor serial troponins and telemetry") and the anticipated duration. Direct admission to observation (without ED presentation) is reported with HCPCS G0379.

The Two-Midnight Rule and the inpatient/outpatient distinction

The historical Medicare distinction between inpatient and outpatient hospital admissions was clear in principle but ambiguous in practice. The principle: inpatient admission means the physician has determined that the patient requires hospital-level care expected to extend beyond a single calendar day, typically involving overnight stay. Outpatient services include emergency department care, same-day surgery, observation, and other hospital services not requiring inpatient admission. In practice, however, the distinction between a "short inpatient stay" and an "observation stay that exceeds 24 hours" became increasingly contested as hospitals' utilization patterns shifted and CMS audits identified short-stay inpatient admissions as a focus of recovery audit contractor (RAC) review.

CMS responded with the Two-Midnight Rule, effective October 1, 2013. The Two-Midnight Rule established a regulatory presumption:

Inpatient presumption: A hospitalization is appropriately billed as inpatient when the admitting physician expects the patient to require hospital care that crosses two midnights.

Outpatient observation presumption: A hospitalization expected to span less than two midnights is appropriately billed as outpatient observation.

Clinical judgment exception: The Two-Midnight Rule does not require a rigid two-midnight calendar test. Physicians can admit as inpatient when documented medical necessity supports inpatient care even with anticipated stays under two midnights. CMS subsequently refined this flexibility in 2015 to provide additional clarity.

Inpatient Only List exception: CMS publishes an Inpatient Only List of procedures that are always billed as inpatient regardless of length of stay. The list historically included approximately 1,700 procedures including most major cardiac surgery, joint replacement (with some exceptions added in recent years that have moved certain joints to outpatient), neurosurgery, and other major procedures. CMS announced plans to phase out the Inpatient Only List in 2021, with phased removal of procedures over several years; some of these phase-outs have been reversed.

Documentation: The admitting physician must document the rationale for inpatient admission when ordering inpatient status. The documentation should reference the expected length of stay (two-midnight expectation), the clinical reasons supporting inpatient-level care, and any factors that would justify clinical judgment exception.

RAC and audit implications: After the Two-Midnight Rule took effect, CMS structured its audit approach to focus on the two-midnight expectation at the time of admission. Hospitals that document the two-midnight expectation appropriately are presumed correct in their inpatient billing.

The NOTICE Act of 2015 and the MOON requirement

The Notice of Observation Treatment and Implication for Care Eligibility Act of 2015 (NOTICE Act) requirements took effect in 2017. The Act addressed a long-standing problem: Medicare beneficiaries often did not know they were in observation status until they tried to access SNF coverage post-discharge and were denied. The NOTICE Act requires hospitals to deliver formal written notice of observation status during the hospital stay.

MOON requirements (Medicare Outpatient Observation Notice, form CMS-10611):

Trigger: A hospital must deliver the MOON to a Medicare beneficiary receiving observation services for more than 24 hours.

Timing: The MOON must be delivered within 36 hours of beginning observation, or upon discharge if discharge occurs earlier.

Content: The MOON must include:

• A statement that the beneficiary is receiving observation services as an outpatient
• An explanation that observation does not count toward the 3-day qualifying inpatient stay required for Medicare SNF coverage
• An explanation of the cost-sharing implications of observation status (Part B 20 percent coinsurance, self-administered drug charges)
• An oral explanation by hospital staff
• A signature line for the beneficiary or representative acknowledging receipt

Languages: The standard CMS MOON form is available in multiple languages including Spanish.

Implementation challenges: Many hospitals have struggled to consistently deliver MOON within the 36-hour window, particularly for short observation stays that conclude before 36 hours. CMS has provided guidance that MOON delivery should occur upon discharge for short stays even when discharge precedes the 36-hour mark.

Limitation of the MOON: The MOON provides written notice but does not change the underlying coverage problem. A beneficiary informed via MOON that observation does not count toward the 3-day SNF qualifying stay still faces the same coverage gap if SNF is needed post-discharge. The MOON's value is informational and procedural rather than substantive.

Section 1861(i) and 42 CFR 409.30: the 3-day SNF qualifying stay

Section 1861(i) of the Social Security Act defines "extended care services" (Medicare's statutory term for SNF care) and includes the requirement that Medicare-covered SNF stays follow a qualifying inpatient hospital stay of at least 3 consecutive days, not counting the day of discharge. The implementing regulation at 42 CFR 409.30 establishes:

• The 3-day inpatient stay must precede the SNF admission
• The hospital stay must be inpatient (not observation)
• The 3 midnights must be spent as inpatient
• The SNF admission must be within 30 days of hospital discharge (with limited extensions for medically necessary delay)
• The SNF care must be for a condition treated during the hospitalization or that arose during the SNF stay

The 3-day rule's interaction with observation: A beneficiary who spends 3 nights in observation does NOT meet the 3-day qualifying stay requirement. The midnights spent in observation do not count regardless of clinical similarity to inpatient care. Even if the beneficiary is then admitted to a SNF for medically necessary skilled care, Medicare will not pay. The beneficiary faces the SNF's full daily rate out of pocket, depending on facility, geographic location, and level of care.

Three-Day Rule Waiver under MSSP ACOs: The Medicare Shared Savings Program permits qualifying Accountable Care Organizations to apply for and receive the SNF 3-Day Rule Waiver, which allows their attributed Medicare beneficiaries to access SNF coverage without the 3-day inpatient qualifying stay. This affects beneficiaries enrolled in ACOs that have applied for and received the waiver. Most Medicare beneficiaries are not in such ACOs, and the waiver is unevenly available. Beneficiaries should ask their primary care practice or ACO whether the waiver applies.

Why the 3-day rule exists: Section 1861(i) was drafted in 1965 when SNF care was conceived as a post-hospitalization extended care benefit. The 3-day qualifying stay was intended to ensure that SNF care was for genuinely post-acute conditions requiring hospital-level workup first, not for elective post-acute placements that should be paid by other mechanisms. The clinical landscape has evolved substantially since 1965, but the statutory 3-day requirement persists.

The self-administered drug exclusion

A particularly painful aspect of observation status billing is the self-administered drug exclusion. When a Medicare beneficiary is in observation status, the hospital pharmacy supplies medications including the beneficiary's home medications (lisinopril, metformin, levothyroxine, etc.) for administration during the hospital stay. Under Medicare Part B rules for hospital outpatient services, self-administered drugs (oral medications patients normally take at home) are NOT covered by Part B in the outpatient hospital setting.

The legal basis: Medicare Part B covers drugs that "cannot be self-administered," intended to cover injectables and infusions administered by clinical staff. Oral medications that patients take at home are presumed to be self-administered even when administered in the hospital. Part B excludes them from coverage in the outpatient setting.

The practical consequence: hospital pharmacies charge patients directly for self-administered drugs at retail rates. A diabetes medication that costs the patient $5 per month through Medicare Part D at their regular pharmacy may be billed at $40 to $60 per pill in the hospital. Across a 36-hour observation stay with multiple medications, charges of $100 to $300 are common, and longer stays with more medications can run into the high hundreds or low thousands of dollars.

Practical workaround: Beneficiaries can bring their own home medications to the hospital and ask the hospital pharmacy to verify and administer those medications rather than hospital pharmacy supplies. Many hospitals have policies permitting this with pharmacist verification. The practice avoids the retail markup but requires that patients (1) bring their medications in original prescription bottles, (2) inform hospital staff at admission, and (3) follow hospital protocols for verification. Some hospitals refuse to administer patient-brought medications and require pharmacy-supplied medications regardless; in those cases, beneficiaries can ask their hospitalist or primary care physician to hold elective medications during the short stay if clinically appropriate.

Note for Part D plans: Some Part D plans will reimburse self-administered drug costs incurred during observation stays after the fact through manual claim submission. Beneficiaries should retain itemized hospital pharmacy bills and submit them to their Part D plan for potential reimbursement.

Condition Code 44: in-hospital status change from observation to inpatient

Under specific circumstances during the hospital stay, the patient's status can be changed from outpatient observation to inpatient via Condition Code 44. This is the regulatory mechanism for in-stay status escalation when the clinical course indicates the patient should have been admitted as inpatient initially.

Condition Code 44 requirements:

1. Before discharge: The change must be made BEFORE the patient is discharged from the hospital
2. UR committee initiation: The change must be initiated by the hospital's Utilization Review committee
3. Physician concurrence: The physician of record must agree with the change
4. Documentation support: Documentation must support inpatient medical necessity (typically requiring the Two-Midnight Rule expectation to be met retroactively or clinical severity escalation)
5. Patient communication: The change must be communicated to the patient

Effect of Condition Code 44: After Condition Code 44 is applied, the entire stay is billed and counted as inpatient from the admission, which affects:

• Cost-sharing: Now Part A inpatient deductible ($1,736 in 2026) instead of Part B 20% coinsurance on each service
• SNF qualifying stay: Now counts toward the 3-day inpatient requirement
• DRG payment: Hospital receives inpatient DRG payment instead of OPPS APC payment

Family advocacy for Condition Code 44: Family members and patients can advocate for UR review and potential Condition Code 44 application when the clinical course suggests inpatient status would be appropriate. Specifically:

• Ask the hospital case manager or social worker about admission status
• Request UR review if the patient's condition has been more severe or prolonged than initial observation expectations
• Request UR review if SNF placement post-discharge is anticipated (to ensure 3-day qualifying stay)
• Document conversations with hospital staff

Limitation: Once the patient is discharged, the hospital can no longer use Condition Code 44 to change status. Post-discharge changes require the Alexander v Becerra appeal pathway or other administrative processes.

Alexander v Becerra: the post-discharge appeal right

For decades, Medicare beneficiaries whose hospitalization was classified as observation had no formal right to appeal that status determination after discharge. The status was the hospital's coding decision and not subject to formal Medicare appeal in the way that coverage denials of specific services could be appealed. Beneficiaries whose observation status had foreclosed SNF coverage faced the financial consequences without recourse.

The class action lawsuit Alexander v Becerra was filed in 2011 by the Center for Medicare Advocacy and co-counsel on behalf of Medicare beneficiaries adversely affected by observation status classifications. The plaintiffs argued that beneficiaries had a protected property interest in inpatient status (because it determined SNF coverage) and were entitled to formal appeal rights under the Due Process Clause of the Fifth Amendment.

After years of litigation including class certification, summary judgment briefing, and trial, the District Court ruled for the plaintiffs, holding that Medicare beneficiaries have due process rights to appeal observation status when it affects SNF coverage. The Second Circuit Court of Appeals subsequently affirmed the district court's holding.

Current appeals process (implementing the court ruling):

CMS has been developing the administrative process for these post-discharge observation status appeals. Beneficiaries who were classified as observation and were denied SNF coverage based on the lack of 3-day inpatient qualifying stay can appeal through the standard Medicare appeals process (redetermination, reconsideration, ALJ, Council, federal court). The grounds for appeal include:

• The hospitalization clinically met the Two-Midnight Rule expectation for inpatient status
• The clinical severity warranted inpatient status under the documented physician judgment
• The hospital's UR process incorrectly classified the stay

Documentation supporting appeals:

• Hospital records demonstrating clinical severity
• Physician orders and notes documenting the clinical course
• Length of stay (especially if exceeded two midnights)
• Procedures performed and intensity of care
• Subsequent SNF coverage denial documentation

Help with observation status appeals:

• Center for Medicare Advocacy: 1-860-456-7790 (lead organization on observation appeals)
• Medicare Rights Center: 1-800-333-4114
• GeorgiaCares SHIP: 1-866-552-4464 (free Medicare counseling for Georgia residents)
• Atlanta Legal Aid: 404-377-0701
• Georgia Legal Services: 1-800-498-9469

Common conditions classified as observation in Georgia hospitals

The following clinical scenarios are commonly classified as observation rather than inpatient in Georgia hospitals, particularly when the expected length of stay is under two midnights:

Cardiology-related:

1. Chest pain rule-out for ACS: serial troponins, telemetry, stress testing
2. Syncope evaluation: telemetry, orthostatic vitals, cardiac workup
3. Mild heart failure exacerbation: IV diuresis with rapid response
4. Atrial fibrillation with rate control: rate adjustment and monitoring

Neurology-related: 5. TIA/stroke rule-out: MRI, carotid imaging, echocardiography, antiplatelet initiation 6. Mild headache or vertigo workup: imaging and observation

Gastroenterology-related: 7. Mild GI bleed: serial hemoglobins and stable observation 8. Mild diverticulitis: IV antibiotics 9. Cholecystitis with non-urgent surgery: pre-operative observation

Pulmonary-related: 10. Mild pneumonia: IV antibiotics 11. Mild COPD/asthma exacerbation: bronchodilators and steroids

Other medical: 12. Dehydration with electrolyte disturbance: IV fluids 13. Falls without major injury: evaluation 14. Medication reactions/intoxications: monitoring 15. Cellulitis without severe systemic illness: IV antibiotics 16. Outpatient surgery recovery beyond routine: extended PACU observation

Common conditions classified as inpatient

Conversely, the following are typically classified as inpatient under the Two-Midnight Rule expectation and clinical severity:

1. ICU admissions for any reason
2. Major surgical procedures: CABG, joint replacement (most), neurosurgery, abdominal surgery with anticipated multi-day stay
3. Acute MI requiring intervention: STEMI, NSTEMI requiring catheterization with intervention
4. Severe pneumonia requiring ICU or extended IV antibiotics
5. Major trauma
6. Acute stroke with intervention: thrombectomy, tPA with neurologic complications
7. DKA requiring ICU
8. Hip fracture requiring surgical repair
9. Cancer with chemotherapy admission for complications
10. Severe infections requiring multi-day IV therapy
11. Procedures on the CMS Inpatient Only List

Worked example two: Robert 81 Savannah syncope at Memorial Health

Robert 81 retired shipyard worker, hx HTN, AFib on apixaban. While at his son's house, Robert experiences a brief loss of consciousness lasting approximately 30 seconds, with rapid return to baseline. No injury. Family drives Robert to Memorial Health Savannah ED. Initial evaluation: EKG showing controlled AFib, vital signs normal, neurologic exam normal, BMP normal. The ED physician determines that Robert requires observation for syncope workup including telemetry, orthostatic vital signs, head CT, carotid doppler, and echocardiogram.

Memorial Health admits Robert to observation status. Over 22 hours, all workup is unremarkable. The cardiology consultant attributes the syncope to vasovagal etiology. Robert is discharged after 22 hours with no medication changes and outpatient cardiology follow-up.

Billing: Outpatient observation. Memorial Health bills Medicare under HCPCS G0378 and the OPPS APC composite payment. Because the stay was under 24 hours, MOON not formally required by NOTICE Act, though Memorial Health's policy is to deliver MOON to all observation patients.

Robert's costs with Medigap Plan G: Approximately $50 to $100 self-administered drug charges (apixaban and home medications). Otherwise $0 due to Plan G coverage of Part B coinsurance.

Robert's costs without Medigap: Approximately $480 (20% Part B coinsurance) plus $50 to $100 self-administered drug charges. Total approximately $530 to $580.

SNF impact: None because Robert discharged home with no SNF need.

Worked example three: Linda 75 Macon TIA rule-out with SNF need denied

Linda 75 retired teacher, transient right-sided weakness and aphasia lasting 20 minutes one afternoon. Family drives her to Atrium Health Navicent ED. Evaluation includes urgent neurology consultation, MRI brain (small acute infarct in left MCA distribution), carotid imaging (50 percent stenosis bilaterally), echocardiogram, and hypercoagulable workup. Linda is admitted to observation for TIA workup.

Over 42 hours of observation, the workup is completed, antiplatelet therapy is initiated (clopidogrel added to her existing aspirin), neurology consultation recommends statin optimization, and Linda is judged stable for discharge. However, Linda is noticeably weaker than at baseline and has mild residual right-sided weakness affecting her gait.

Linda is discharged after 42 hours. Two days later, after falling at home, her family arranges for SNF admission at a Macon facility for rehabilitation. The SNF processes Linda's Medicare paperwork and discovers that Linda did NOT meet the 3-day inpatient qualifying stay requirement. The SNF admission is processed as self-pay.

Linda's SNF cost: 15 days of SNF self-pay entirely out of pocket. Linda's daughter pays through Linda's savings.

Appeal pathway: Through the Alexander v Becerra appeals process, Linda's family files an appeal of the observation classification. The basis: Linda's stay (42 hours, two midnights) met the Two-Midnight Rule criteria for inpatient status; the clinical severity (acute MCA infarct on MRI) warranted inpatient classification; the residual neurologic deficit and SNF requirement reflect the clinical seriousness that should have been reflected in inpatient admission. Linda's appeal proceeds through redetermination by Palmetto GBA, with potential further levels if unsuccessful. The Center for Medicare Advocacy provides pro bono assistance.

This case illustrates the critical importance of advocating for inpatient status escalation via Condition Code 44 during the hospital stay, particularly when there is any concern that SNF placement may be needed post-discharge.

Worked example four: Charles 79 Augusta GI bleed Condition Code 44 success

Charles 79 retired electrician, presents to Augusta University Health ED with several days of melena and hematochezia. Hemoglobin 8.2 on arrival, down from baseline of 13. Hemodynamics stable. The ED physician admits to observation for serial hemoglobin monitoring with plan to transfuse if necessary.

• Night 1 observation: Transfused 2 units packed RBCs. Hemoglobin response to 10.4. Telemetry monitoring.
• Day 2 morning: Recurrent bleeding with melenic stool, hemoglobin drop to 8.5. EGD performed showing duodenal ulcer with active bleeding, cauterized with epinephrine injection. Patient stable post-EGD.
• Day 2 afternoon: AU Health UR committee reviews the case in real time. The clinical course (recurrent bleeding requiring EGD intervention, expected continued observation at least one more midnight for hemoglobin stability) supports inpatient status. UR committee recommends Condition Code 44. The attending physician of record (a hospitalist) agrees and documents inpatient justification. Condition Code 44 applied, status changed from observation to inpatient retroactively from admission.
• Night 3 inpatient: Hemoglobin stable at 10.4, no further bleeding.
• Discharge day 4 as inpatient.

Billing: After Condition Code 44, the entire stay is billed and counted as inpatient. AU Health receives inpatient DRG payment (DRG 378-380 GI Hemorrhage with MCC). The stay is counted as 3 inpatient midnights for SNF purposes.

Charles's costs with Medigap Plan G: Part A inpatient deductible $1,736 covered by Plan G. Approximately $0 to $100 out of pocket.

SNF impact: Charles's family has been concerned about post-discharge weakness. With inpatient status established via Condition Code 44, Charles meets the 3-day qualifying stay if SNF rehab is needed. As it happens, Charles recovers well and goes home with home health, but the inpatient classification provides the safety net of potential SNF coverage.

This example demonstrates the value of family advocacy combined with hospital UR committee responsiveness. Without the Condition Code 44 process, Charles would have faced significant out-of-pocket exposure if SNF had been needed.

Worked example five: Patricia 73 Columbus HF exacerbation, observation then self-pay SNF

Patricia 73 retired retail manager, hx HFpEF on furosemide. Develops progressively worsening dyspnea and bilateral leg edema over a week. Presents to Piedmont Columbus ED with NYHA III symptoms. Initial workup: BNP elevated, chest X-ray with mild pulmonary congestion, troponin normal, BMP with stable creatinine. The ED physician admits to observation for IV diuresis and stabilization.

• Night 1 observation: IV furosemide 80 mg, diuresed 2 liters with symptomatic improvement.
• Night 2 observation: Continued IV diuresis, additional 1.5 L. Patient feels significantly better. Discharge planning initiated for day 3.
• Discharge after 40 hours with adjusted oral diuretic regimen, instructions to follow up with cardiology in 1 week.

Post-discharge, Patricia is significantly deconditioned from the aggressive diuresis and acute illness. She has lost 4 pounds of fluid weight but is weak and unsteady. Her daughter arranges for SNF admission at a Columbus facility for rehabilitation.

The SNF processes Medicare paperwork and discovers Patricia does NOT meet the 3-day inpatient qualifying stay. SNF admission is self-pay.

Patricia's SNF cost: 8 days of SNF self-pay entirely out of pocket. Patricia's daughter pays through Patricia's savings.

Lessons:

1. Patricia and family should have inquired about admission status during the stay
2. Family should have raised the SNF possibility with hospital case manager to potentially trigger Condition Code 44 review
3. Post-discharge appeal through Alexander v Becerra pathway is available but slow and uncertain
4. Future stays should include proactive advocacy on admission status

Worked example six: Henry 84 rural Tifton elective hip surgery overnight observation

Henry 84 retired farmer, elective total hip arthroplasty for severe osteoarthritis at Tift Regional Medical Center. Per current CMS Inpatient Only List rules, total hip arthroplasty has been removed from the Inpatient Only List (effective in recent years), permitting outpatient performance with observation when the clinical course supports it. Henry's surgery is scheduled as outpatient with overnight observation per Tift Regional protocol.

• Surgery day morning: Procedure performed (right total hip arthroplasty).
• Surgery day afternoon and evening: Recovery in PACU then transferred to observation unit. Pain control, mobilization with physical therapy.
• POD 1 morning: Cleared by PT for discharge with home health.
• Discharge POD 1 as outpatient with observation.

Billing: Outpatient surgery + observation. Henry pays Part B coinsurance on the surgical APC and observation services. Medigap Plan G covers his coinsurance.

SNF impact: Henry discharges home with home health (not SNF). Home health under Section 1861(m) does not require a 3-day inpatient qualifying stay. Home health PT and skilled nursing for incision care are covered.

This example illustrates that outpatient surgery with observation is a legitimate clinical pathway when SNF coverage is not anticipated and home health can support post-discharge recovery. For patients who do anticipate SNF need, the calculus changes substantially.

Fourteen common mistakes in observation status navigation

Mistake 1: Not asking about admission status (inpatient vs observation) during the hospital stay. The question must be asked explicitly. Ask the nurse, case manager, social worker, or physician. The answer affects everything from cost-sharing to SNF coverage.

Mistake 2: Not reading or understanding the MOON when delivered. The MOON is the formal notice required by NOTICE Act. Read it carefully. If anything is unclear, ask hospital staff for explanation.

Mistake 3: Assuming "admission" means inpatient. A beneficiary may be "admitted" to a hospital bed and yet be classified as outpatient observation. The clinical experience is identical; the administrative classification is different.

Mistake 4: Not advocating for inpatient status escalation via Condition Code 44 when clinically warranted. The hospital UR committee can change status mid-stay. Family advocacy can prompt UR review.

Mistake 5: Assuming Medicare will cover SNF after any hospital stay. Medicare SNF coverage requires a 3-day inpatient qualifying stay. Observation days do not count.

Mistake 6: Failing to track midnights in inpatient status. Keep a written log of admission status changes during the hospital stay.

Mistake 7: Not understanding self-administered drug charges. Observation patients pay retail for home medications dispensed by the hospital pharmacy. Consider bringing own medications in original prescription bottles.

Mistake 8: Not appealing observation status post-discharge when SNF coverage was denied. The Alexander v Becerra appeal rights exist. The Center for Medicare Advocacy (1-860-456-7790) provides assistance.

Mistake 9: Discharging from observation without understanding SNF implications. Discuss potential post-discharge SNF need with hospital case management before discharge.

Mistake 10: Not pursuing home health (covered) when SNF (not covered) is barrier. Home health under Section 1861(m) does not require a 3-day inpatient stay. For many post-acute needs, home health is a viable alternative.

Mistake 11: Not enrolling in Medigap to cover 20% Part B coinsurance. Observation Part B charges add up across multiple services. Medigap initial enrollment is the best window for guaranteed-issue.

Mistake 12: Assuming Medicare Advantage plan has different observation rules. MA plans must follow Medicare rules including the 3-day SNF qualifying stay, though some MA plans offer supplemental SNF benefits not requiring 3-day stays.

Mistake 13: Not coordinating with Medicaid for dual-eligibles. Medicaid can cover Part B observation coinsurance and SNF costs for full-benefit dual-eligibles.

Mistake 14: Not pursuing the 3-day rule waiver if enrolled in qualifying ACO. Some Medicare Shared Savings Program ACOs have the SNF 3-Day Rule Waiver. Ask your primary care practice or ACO.

Medicare Advantage and observation status

Medicare Advantage plans (Part C) must follow Medicare rules for observation status and the 3-day SNF qualifying stay. However, MA plan-specific UR programs may apply, and some MA plans offer supplemental benefits that ease the observation/SNF gap:

Some MA plans waive the 3-day requirement: MA plans have flexibility to offer supplemental benefits including SNF coverage without 3-day qualifying stay. Some MA plans market this as a benefit for older beneficiaries who may need SNF after observation stays.

MA plan UR processes: MA plans typically apply their own utilization review screening tools. Hospital UR teams must coordinate with MA plan UR for inpatient vs observation classification decisions.

Appeals through MA plans: MA plan denials of SNF coverage based on observation status follow the MA appeals process (different from Original Medicare appeals): expedited and standard organization determination, reconsideration, IRE, ALJ, Council, federal court.

Dual-eligible Medicare/Medicaid and observation

For Georgia dual-eligibles (Qualified Medicare Beneficiary, Specified Low-Income Medicare Beneficiary, Qualifying Individual, or full-benefit dual-eligibility), Georgia Medicaid (DCH 1-866-211-0950) provides important supplementary coverage:

Part B coinsurance: Medicaid covers Medicare Part B coinsurance for dual-eligibles including the 20 percent on observation services.

SNF costs after observation: Full-benefit Medicaid covers SNF costs when Medicare denies based on observation status, for beneficiaries who meet Medicaid SNF coverage criteria (asset and income limits, level of care criteria).

Self-administered drug charges: Medicaid may cover some self-administered drug charges through pharmacy benefit coordination.

Appeals process for observation status decisions

Medicare appeals of observation status decisions follow the standard 5-level Medicare appeals process:

Level 1 Redetermination: Within 120 days of the initial determination (SNF coverage denial), beneficiary can request redetermination by Palmetto GBA Jurisdiction J at 1-877-567-9230.

Level 2 Reconsideration: If unfavorable, within 180 days request reconsideration by Qualified Independent Contractor.

Level 3 Administrative Law Judge: Within 60 days of unfavorable Level 2, if the amount in controversy meets the applicable threshold, request ALJ hearing through Office of Medicare Hearings and Appeals.

Level 4 Medicare Appeals Council: Within 60 days of unfavorable ALJ.

Level 5 Federal District Court: If unfavorable and the amount in controversy meets the applicable threshold.

For Alexander v Becerra appeals specifically, the Center for Medicare Advocacy at 1-860-456-7790 provides direct legal assistance and amicus support.

How Brevy helps Georgia families navigate observation status

Brevy (brevy.com) is the eldercare resource helping Georgia families understand and navigate the consequential nuances of Medicare hospital observation status. The Two-Midnight Rule, the NOTICE Act MOON requirement, the 3-day SNF qualifying stay, Condition Code 44, the Alexander v Becerra appeal pathway, the self-administered drug exclusion, and the strategic advocacy approaches during hospitalization are not intuitive, and most families learn about observation status only after they have been adversely affected by it. Brevy's mission is to translate this regulatory complexity into actionable understanding so that Georgia beneficiaries and their families can advocate effectively during hospitalizations and pursue appropriate remedies when observation classifications have foreclosed expected coverage.

Find personalized help navigating Georgia Medicare observation status at brevy.com.

::: accordion Q1: What is observation status in a Medicare hospital admission?

Observation status is an outpatient hospital service classification under Section 1861(s)(2)(B) of the Social Security Act and 42 CFR 410.21. A beneficiary in observation occupies a hospital bed, receives clinical care, and may stay one to several days, but is classified as an outpatient rather than an inpatient. The classification affects cost-sharing (Part B 20 percent coinsurance vs Part A deductible), SNF coverage eligibility (observation does not count toward 3-day qualifying stay), and self-administered drug charges.

Q2: What is the Two-Midnight Rule?

The Two-Midnight Rule, effective October 1, 2013, establishes a regulatory presumption that hospitalizations expected to span two midnights are appropriately billed as inpatient, while those expected to span less than two midnights default to outpatient observation. Clinical judgment exceptions permit physicians to admit as inpatient with documented medical necessity even with anticipated stays under two midnights.

Q3: What is the MOON and when is it delivered?

The Medicare Outpatient Observation Notice (MOON, form CMS-10611) is the written notice required by the NOTICE Act of 2015 to be delivered to Medicare beneficiaries receiving observation services for more than 24 hours. The MOON must be delivered within 36 hours of beginning observation or upon discharge if earlier, must explain observation status and its consequences, and must be signed by the beneficiary or representative.

Q4: How does observation status affect Medicare SNF coverage?

Section 1861(i) and 42 CFR 409.30 require a 3-day qualifying inpatient hospital stay before Medicare will cover post-acute SNF care. The 3 midnights must be spent as inpatient, not in observation. Observation days do NOT count. A beneficiary who spends 3 nights in observation does not qualify for Medicare SNF coverage and would face the SNF's full daily rate out of pocket.

Q5: How can I find out whether I am in observation or inpatient status during my hospital stay?

Ask the nurse, case manager, social worker, or physician directly. The question is simple: "Am I admitted as an inpatient or as outpatient observation?" Document the answer. If observation status is concerning given clinical severity, ask about Condition Code 44 review by the hospital UR committee.

Q6: What is Condition Code 44?

Condition Code 44 is the regulatory mechanism for in-hospital status change from outpatient observation to inpatient. The change must be initiated by the hospital UR committee, agreed to by the physician of record, supported by documentation of inpatient medical necessity, and applied BEFORE patient discharge. Once applied, the entire stay is billed and counted as inpatient, affecting cost-sharing, SNF qualifying stay, and DRG payment.

Q7: Can I appeal observation status after discharge?

Yes, through the Alexander v Becerra appeals pathway. The courts have affirmed that Medicare beneficiaries have due process rights to appeal observation status when it affects SNF coverage. The Center for Medicare Advocacy at 1-860-456-7790 is the lead organization on these appeals. Standard Medicare appeals process applies: redetermination, reconsideration, ALJ, Council, federal court.

Q8: How much does observation cost vs inpatient admission?

Inpatient (Part A) triggers a single inpatient deductible ($1,736 in 2026) covering the first 60 days. Observation (Part B) triggers 20 percent coinsurance on each separate hospital service after the annual Part B deductible ($283 in 2026), plus separate cost for self-administered drugs. For a typical 36-hour observation stay, the patient's out-of-pocket cost without Medigap is approximately $500 to $700 (similar to or sometimes exceeding the Part A deductible for an equivalent inpatient stay).

Q9: What is the self-administered drug exclusion?

Under Medicare Part B rules for hospital outpatient services, self-administered drugs (oral medications patients normally take at home) are NOT covered by Part B in the outpatient hospital setting. Hospital pharmacies charge patients directly for these medications at retail rates, often $20 to $100+ per pill. Practical workaround: bring own home medications in original prescription bottles and ask hospital pharmacy to administer those instead.

Q10: Does Medigap cover observation status costs?

Yes. Medigap plans cover Part B cost-sharing including the 20 percent coinsurance on observation services. Medigap initial enrollment period (6 months starting when you turn 65 and enroll in Part B) is the best window for guaranteed-issue Medigap. Self-administered drug charges are typically not covered by Medigap (those are not Part B services subject to Medigap coverage).

Q11: What is the 3-day qualifying inpatient stay for SNF coverage?

Section 1861(i) of the Social Security Act and 42 CFR 409.30 require a 3-day qualifying inpatient hospital stay (3 midnights spent as inpatient, not counting day of discharge) before Medicare will cover post-acute SNF care. The SNF admission must be within 30 days of hospital discharge.

Q12: Are there any waivers of the 3-day rule?

Yes, the Medicare Shared Savings Program permits qualifying Accountable Care Organizations to apply for and receive the SNF 3-Day Rule Waiver, allowing their attributed beneficiaries to access SNF coverage without the 3-day inpatient qualifying stay. Most Medicare beneficiaries are not in such ACOs. Ask your primary care practice whether the waiver applies.

Q13: Does home health require a 3-day inpatient stay?

No. Home health coverage under Section 1861(m) does NOT require a 3-day inpatient qualifying stay. For beneficiaries who need post-acute care that can be delivered at home (skilled nursing visits, physical therapy, occupational therapy, speech therapy), home health is a viable alternative regardless of inpatient/observation classification.

Q14: How long can a beneficiary be in observation?

There is no fixed maximum, though observation is conceptually intended for short stays (typically under 48 hours). The Two-Midnight Rule presumption is that stays expected to span two midnights should be inpatient. In practice, observation stays exceeding 48 hours occur, particularly when clinical course is unclear or workup is extended.

Q15: What conditions are commonly classified as observation?

Chest pain rule-out, syncope evaluation, TIA/stroke rule-out, mild GI bleed, mild heart failure exacerbation, mild pneumonia, dehydration, falls without major injury, medication reactions, cellulitis, and mild COPD/asthma exacerbation are commonly observation. Major surgery, ICU admissions, acute MI with intervention, severe pneumonia requiring ICU, major trauma, and procedures on the Inpatient Only List are typically inpatient.

Q16: What is the OPPS APC composite payment for observation?

Hospital observation services that reach an 8-hour threshold and meet other criteria are paid under APC 8011 Comprehensive Observation Services composite payment, which bundles observation hours with associated visit and ancillary services into a single payment.

Q17: What is the difference between observation and admission as inpatient?

The clinical experience is often identical (hospital bed, IV medications, monitoring, physician visits, nursing care). The difference is administrative: inpatient is a Part A benefit triggering DRG payment and the Part A deductible; observation is a Part B outpatient service triggering APC payment and 20% coinsurance.

Q18: How does Medicare Advantage handle observation?

MA plans must follow Medicare rules including the 3-day SNF qualifying stay. Some MA plans offer supplemental SNF benefits that waive the 3-day requirement. Verify with your specific MA plan.

Q19: Can a hospital change status from observation to inpatient during the stay?

Yes, through Condition Code 44, which requires UR committee initiation, physician concurrence, documentation support, and application before discharge.

Q20: What if I need SNF and was in observation?

Options include (1) appealing observation status through Alexander v Becerra pathway, (2) pursuing home health if appropriate (no 3-day rule), (3) self-pay SNF, (4) Medicaid for dual-eligibles, (5) checking if MA plan has SNF waiver, (6) checking if ACO has 3-day rule waiver.

Q21: How do I bring my own medications to the hospital?

Bring medications in original labeled prescription bottles. Inform hospital staff at admission. Hospital pharmacy will typically verify the medications and may permit administration of patient-brought supplies to avoid self-administered drug charges. Policies vary by hospital.

Q22: Where can I get help with observation status questions in Georgia?

GeorgiaCares SHIP at 1-866-552-4464 for free Medicare counseling. Center for Medicare Advocacy at 1-860-456-7790 for observation status appeals. Medicare Rights Center at 1-800-333-4114 for general Medicare advocacy. Atlanta Legal Aid at 404-377-0701 or Georgia Legal Services at 1-800-498-9469 for legal assistance.

Q23: How do I prepare for a hospital admission to minimize observation-related costs and risks?

(1) Carry a list of home medications with current doses; (2) Have Medicare card, Medigap card, and any Medicare Advantage card available; (3) Have a family member who can advocate during the stay; (4) Ask about admission status as soon as possible after admission; (5) Document conversations about status; (6) Request UR review if status seems incorrect; (7) Ask about potential SNF needs early to facilitate Condition Code 44 if appropriate.

Q24: Is observation status appropriate sometimes?

Yes. For genuinely short stays under two midnights with stable clinical courses, observation is the appropriate classification. The problem is observation classification for stays that should be inpatient under clinical severity or Two-Midnight Rule expectation, particularly when SNF coverage is foreclosed.

Q25: Where can I learn more about my specific situation?

Contact GeorgiaCares SHIP at 1-866-552-4464 for free Medicare counseling specific to your circumstances. Contact your hospital's case manager or social worker for stay-specific questions. Contact Brevy at brevy.com for educational content on Medicare hospital coverage. :::

::: cta Georgia and federal contacts for Medicare hospital outpatient observation

• Medicare: 1-800-MEDICARE (1-800-633-4227); 24/7
• Palmetto GBA Jurisdiction J MAC: 1-877-567-9230
• GeorgiaCares SHIP (free Medicare counseling): 1-866-552-4464
• Georgia DCH Medicaid Member Services: 1-866-211-0950
• Center for Medicare Advocacy (Alexander v Becerra appeals): 1-860-456-7790
• Medicare Rights Center: 1-800-333-4114
• Kepro QIO (Beneficiary and Family Centered Care): 1-844-455-8708
• Georgia Hospital Association: 770-249-4500
• Emory Patient Financial Services: 404-686-5599
• Wellstar Patient Financial Services: 470-644-0419
• Piedmont Patient Financial Services: 855-788-1212
• Northside Patient Financial Services: 404-851-8950
• Grady Patient Financial Services: 404-616-1000
• AU Health Patient Financial Services: 706-721-2381
• Atlanta Legal Aid: 404-377-0701
• Georgia Legal Services: 1-800-498-9469
• Social Security: 1-800-772-1213
• HHS OCR (civil rights complaints): 1-800-368-1019
• Eldercare Locator: 1-800-677-1116
• 211 Georgia: 211
• VA Benefits: 1-800-827-1000 :::