AHA Comments on CMS TEAM Payment Model in FY 2026 Proposed Inpatient Payment Rule

June 10, 2024

The Honorable Mehmet Oz, M.D.
Administrator
Centers for Medicare & Medicaid Services
Hubert H. Humphrey Building
200 Independence Avenue, S.W., Room 445-G
Washington, DC 20201

Submitted Electronically

RE: CMS-1833-P, Medicare Program; Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and the Long Term Care Hospital Prospective Payment System and Policy Changes and Fiscal Year 2026 Rates; Requirements for Quality Programs; and Other Policy Changes, (Vol. 90, No. 82), April 30, 2025.

Dear Administrator Oz,

On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations, our clinician partners - including more than 270,000 affiliated physicians, 2 million nurses and other caregivers - and the 43,000 health care leaders who belong to our professional membership groups, the American Hospital Association (AHA) appreciates the opportunity to provide comment on the Centers for Medicare & Medicaid Services' (CMS) proposed changes to the Transforming Episode Accountability Model (TEAM). We are submitting separate comments on the agency's proposed changes to the inpatient and long-term care hospital prospective payment systems (PPSs).

TEAM is a new, mandatory, episode-based payment model scheduled to begin on Jan. 1, 2026. The five-year program will require acute care hospitals in selected geographic areas to participate in five surgical episodes, including coronary artery bypass graft (CABG), lower extremity joint replacement (LEJR), major bowel procedure, surgical hip/femur fracture treatment (SHFFT) and spinal fusion. TEAM will hold acute care hospitals accountable for the quality and cost of all services provided during select surgical episodes, from the date of inpatient admission or outpatient procedure through 30 days post-discharge. Similar to other bundled payment models, TEAM participants will reconcile performance year spending against a target price to determine if a hospital is eligible for a reconciliation payment or repayment.

View the detailed letter below.