The Two-Midnight Rule was supposed to be settled. It was finalized more than a decade ago. CMS extended it to Medicare Advantage plans starting January 1, 2024. On November 25, 2025, CMS issued further clarifying updates in the CY 2026 OPPS Final Rule. By every reasonable measure, this should be a closed chapter. It isn't. Status determination errors — the wrong choice between inpatient and observation, the downgrade after the fact, the denial that should never have been issu