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Hospitals will need adequate time to develop and operationalize policies and procedures for implementing requirements under the Notice of Observation Treatment and Implication for Care Eligibility Act, AHA told the Centers for Medicare & Medicaid Services in comments submitted today. The agency recently solicited comments from stakeholders as it works to prepare rulemaking to implement the 2015 , which requires hospitals to provide Medicare beneficiaries with written notification and a related oral explanation at discharge or within 36 hours, whichever is sooner, if they receive more than 24 hours of outpatient observation services. “We believe that allowing hospitals a six-month implementation period after the final rule is issued would provide the time necessary to operationalize this new policy,” wrote Ashley Thompson, AHA senior vice president for public policy analysis and development. AHA also encouraged CMS to describe in its proposed rule how it intends to enforce the Act’s provisions and the penalties for non-compliance, adding that defaulting to terminating a hospital’s provider agreement would be “too egregious a penalty to impose.” AHA said the rulemaking also should clarify how timing of the required notification would apply to certain beneficiaries; permit hospitals to use a standard written notification and determine which staff are best equipped to provide the oral explanation; and clarify whether federal or state requirements would take precedence in states with similar laws or regulations.