As a case manager or case management leader, it is important for you to stay in touch with how CMS continues to roll out the two-midnight rules as well as the manner of auditing on a go-forward basis. It is also important that your department continue to have a close working relationship with the billing department in your hospital to ensure that the hospital remains compliant with this new rule. Finally, it is also critical that your emergency department and its physicians are kept up to date on the rule and its implications for hospital admissions. Having a case management presence in the emergency department will help to ensure a sound review process at this important route of entry to the hospital. A working team should be created to review the cases that fall outside of the rule, and these cases should also be presented to the utilization review committee so that the hospital can continue to learn and move forward. Finally, listen to the CMS National Provider Calls (www.cms. gov/NPC) to gain additional and updated information as it becomes available! For additional information on the two-midnight rule go to www.cms.gov and search for CMS-1599-F.

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