FAQs by Topic:
- General
- Eligibility
- Voluntary Opt-In Opportunity
- Episodes/Payment
- Learning System/Technical Assistance
- Portal and Points of Contact
- Care Delivery/Quality Strategy
- Financial Arrangements/TEAM Collaborators
- Model Overlap
General
What are the Transforming Episode Accountability Model (TEAM)’s goals?
The intent of TEAM is to improve beneficiary care through financial accountability for TEAM participants that initiate at least one of the included episode categories that begin with one of the following procedures: coronary artery bypass graft (CABG), lower extremity joint replacement (LEJR), major bowel procedure, surgical hip and femur fracture treatment (SHFFT), and spinal fusion.
TEAM focuses on improving quality of care and reducing Medicare expenditures for five surgical episode categories. These episode categories represent high-expenditure, high-volume care delivered to Medicare beneficiaries and are evaluable in an episode-based payment model. CMS anticipates that TEAM will:
- Benefit Medicare patients through improving the coordination of items and services paid for through Medicare fee-for-service (FFS)
- Encourage provider investment in health care infrastructure and redesigned care processes
- Incentivize higher value care across the inpatient and post-acute care settings
- How did CMS develop TEAM?
CMS created TEAM using lessons learned from earlier CMS Innovation Center episode-based payment models such as the Bundled Payments for Care Improvement Advanced (BPCI Advanced) and Comprehensive Care for Joint Replacement Models, feedback from a July 2023 Request for Information, and consultation with several stakeholders, including providers, health systems, and thought leaders in the field. Additionally, CMS will use public comments received during the rulemaking process to inform any modifications to future policies.
How will CMS address policies not yet finalized in a proposed rule for TEAM or make changes to policies in the future?
There may be times that a proposed policy is not finalized or requires a modification, such as needing to further analyze a proposed policy before it is finalized. CMS finalized the majority of TEAM’s policy proposals in the FY 2025 Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals (IPPS) and the Long-Term Care Hospital (LTCH) Prospective Payment Systems (PPS) Final Rule as proposed in the notice of proposed rulemaking and finalized others in the FY 2026 Hospital IPPS/LTCH PPS Final Rule. Additionally, any potential changes to finalized policies before or during the model performance period are subject to undergo notice and comment rulemaking.
When will additional updates regarding TEAM be available?
Those interested in remaining up-to-date on model announcements and resources may subscribe to TEAM's listserv.
Eligibility
Why is participation in TEAM mandatory for selected hospitals?
Mandatory models can improve the generalizability of model findings and capture a wider variety of providers from across the country, including many who have not participated in value-based payment models. Mandatory models also address participation challenges inherent in voluntary models, namely provider attrition and selection bias. As an episode-based payment model that builds on previous voluntary CMMI models, TEAM is well positioned to advance testing and evaluation with a mandatory episode-based payment model and aligns with recommendations from federal partners.A TEAM participant is defined as an acute care hospital that (1) initiates episodes and is paid under the IPPS and Outpatient Prospective Payment System (OPPS) with a CMS Certification Number (CCN) primary address located in one of the mandatory Core-Based Statistical Areas (CBSAs) selected for participation in TEAM in accordance with § 512.515; or (2) Makes a voluntary opt-in participation election to participate in TEAM in accordance with § 512.510 and is accepted to participate in TEAM by CMS.
Will hospitals that are newly opened be required to participate in TEAM if located in a mandatory CBSA?
CMS recognizes that new hospitals that open shortly before or during the model performance period, as well as hospitals that begin to satisfy the definition of TEAM participant shortly before or during the model performance period, and that would otherwise be required to participate in TEAM based on their receipt of payment under IPPS and their geographic location, may experience multiple disadvantages relative to other TEAM participants. Therefore, CMS will not immediately require any new hospital, as identified by Medicare ID (CCN) with an initial effective date after December 31, 2024, within the Medicare Provider Enrollment, Chain, and Ownership System (PECOS), excepting any new hospital that is created as part of a reorganization event as defined at § 512.505; these hospitals will have at least one full performance year of participation deferment before being required to participate in the model.
Specifically, any new hospital located in a mandatory CBSA, and any hospital located in a mandatory CBSA that begins to meet the definition of TEAM participant, are required to participate in TEAM starting on January 1st of the subsequent performance year. For example, if a hospital opened in a mandatory CBSA with a Medicare ID (CCN) initial effective date on June 1, 2026, then the hospital would not be required to begin participation until January 1, 2028 (PY 3). Likewise, if a hospital located in a mandatory CBSA terminated their participation in the Rural Community Hospital Demonstration (RCHD) effective on August 1, 2027, then they would not be required to begin participation in TEAM until January 1, 2029 (PY 4).
Where will TEAM be tested? What CBSAs have been selected for TEAM participation?
CMS has published a list of the selected mandatory CBSAs in section X.A.3.a.(4) of the preamble of the FY 2025 Hospital IPPS and LTCH PPS Final Rule. By using CBSAs as the unit of selection, CMS is ensuring that the model represents a wide range of markets and requires the participation of many hospitals with diverse characteristics.
Is there a list of hospitals selected for TEAM participation?
CMS published a list of acute care hospitals (XLSX), identified by CCN, located in one of the mandatory CBSAs selected for participation. This list also includes eligible hospitals that voluntarily opted in to TEAM participation. CMS will periodically update this list to accurately capture acute care hospitals in the mandatory CBSAs.
Will there be updates to the initial TEAM participant list?
CMS may update the TEAM participant list to reflect changes in hospital status (e.g., closures, mergers, and other reorganization events) and accurately capture acute care hospitals in the mandatory CBSAs. CMS will regularly review internal records to identify status changes. A hospital that no longer satisfies the definition of TEAM participant would end TEAM participation effective the date they no longer satisfy the definition. CMS will notify the hospital that no longer meets this definition within 30 days of the hospital no longer meeting the TEAM participant definition or as soon as is reasonably practicable.
Further, prior to each performance year, CMS intends to update the list to identify which hospitals satisfy the definition of a safety net hospital, rural hospital, or other selected hospital types, such as Medicare Dependent Hospitals (MDHs), Sole Community Hospitals (SCHs), and Essential Access Community Hospitals (EACHs) in TEAM, specified under § 512.505.
What are the safety net hospital criteria for the purposes of TEAM?
For the purposes of TEAM, a safety net hospital is defined as an IPPS hospital that meets at least one of the following criteria:
- Exceeds the 75th percentile of the proportion of Medicare beneficiaries considered dually eligible for Medicare and Medicaid across all PPS acute care hospitals in the baseline period. The numerator and denominator are as follows:
- Numerator: Number of Medicare beneficiaries considered fully eligible for Medicare and Medicaid.
- Denominator: Total number of Medicare beneficiaries across all Inpatient Prospective Payment System (IPPS) acute care hospitals that bill Medicare in the baseline period.
- Exceeds the 75th percentile of the proportion of Medicare beneficiaries partially or fully eligible to receive Part D low-income subsidies across all PPS acute care hospitals in the baseline period.
- Numerator: Number of Medicare beneficiaries partially or fully eligible to receive Medicare Part D low-income subsidies.
- Denominator: Total number of Medicare beneficiaries across all Inpatient Prospective Payment System acute care hospitals that bill Medicare in the baseline period.
CMS will make redeterminations of safety net hospital qualifications under TEAM annually, meaning that hospital safety net status could vary over the model’s duration. However, we do not expect a significant number of hospitals will experience status changes year over year.
- Exceeds the 75th percentile of the proportion of Medicare beneficiaries considered dually eligible for Medicare and Medicaid across all PPS acute care hospitals in the baseline period. The numerator and denominator are as follows:
What is the definition of a rural hospital in TEAM?
For the purposes of TEAM, ‘rural hospital’ refers to an IPPS hospital that is located in a rural area as defined under § 412.64 or is located in a rural census tract defined under § 412.103(a)(1).
Will hospitals are exempt from mandatory participation?
Acute care hospitals that do not satisfy the definition of TEAM participant are exempt from mandatory participation. For example, hospitals with a CCN primary address not located in a mandatory CBSA and all acute care hospitals in Maryland are exempt from mandatory participation.
Additionally, CMS has excluded Indian Health System (IHS)/Tribal hospitals from TEAM participation by updating the TEAM participant definition in the FY 2026 Hospital IPPS and LTCH PPS Final Rule to state that a TEAM participant must be paid under IPPS and OPPS.
What policies or flexibilities are available to safety net hospitals that participate in TEAM? Will the policies apply to rural hospitals?
TEAM is a mandatory model that offers a glide path to participation in downside risk for all hospitals, including safety net and rural hospitals. Safety net hospitals are eligible for a longer glide path and therefore will be permitted to participate in Track 1 for Performance Years 1 through 3, based on their timely notification of participation track selection before the start of each performance year. Track 1 limits upside risk with a 10% stop-gain limit, adjusts positive reconciliation amounts for quality performance up to 10%, and offers no downside risk for hospitals as they implement care redesign tactics and build capacity to use data to deliver high-quality care.
Safety net hospitals are also eligible to participate in Track 2 for Performance Years 2 through 5, based on their timely notification of participation track selection before the start of each performance year. Hospitals participating in Track 2 will have upside and downside risk, with a stop-gain and stop-loss limit of 5%. Positive reconciliation amounts will be adjusted for quality performance up to 10%, and negative reconciliation amounts will be adjusted for quality performance up to 15%. The higher adjustment for negative reconciliation amounts results in a lower repayment amount.
Rural hospitals, MDHs, SCHs, and EACHs located in a mandatory CBSA will participate and may select Track 1 for Performance Year 1. During Performance Years 2 through 5, these hospitals may select between Tracks 2 and 3, based on their timely notification of participation track selection before the start of each performance year. TEAM participants who are classified as MDHs will be eligible for Track 2 participation as long as the MDH program is active at the time that participation track selections are due to CMS.
Hospitals that do not fall into one of these categories will be required to participate in Track 3 for Performance Years 2 through 5. Hospitals participating in Track 3 will have upside and downside risk, with a stop-gain and stop-loss limit of 20%. Positive and negative reconciliation amounts will be adjusted for quality performance up to 10%.
When will hospitals select a participation track?
TEAM participants are required to notify CMS of their track selection prior to the start of Performance Year 1 on January 1, 2026. CMS will provide TEAM participants with additional information about the track selection process and deadline, as well as safety net hospital status, in 2025. Please note that participants’ track selections are subject to eligibility review and approval by CMS.
TEAM participants who fail to notify CMS in advance of the deadline will be automatically assigned to Track 1 for Performance Year 1.
In Performance Years 2 to 5, if a TEAM participant fails to notify CMS of their election to participate in Track 1 or Track 2 by the selection deadline for a given performance year, they will be assigned to Track 3 for that performance year by default.
Does a hospital have to perform all five episode categories to participate?
TEAM requires TEAM participants to take part in all five episode categories. However, if a TEAM participant does not perform a given episode category, then they will not initiate that episode category in the model.
Additionally, if a TEAM participant does not meet the low volume threshold of at least 31 episodes in a given episode category during the baseline period for a performance year, CMS will still reconcile their episodes but will not hold the TEAM participant accountable for any performance year spending that exceeded the reconciliation target price for each of the MS-DRG/HCPCS episode types in that given episode category during that performance year—effectively waiving downside risk for episode categories in which the TEAM participant did not meet the minimum baseline episode volume.
CMS may add additional episode categories in future performance years of the model. Any additional episode categories will only be added to TEAM pursuant to notice and comment rulemaking.
If a healthcare system has multiple hospitals under the same Tax Identification Number (TIN)/CCN, will hospitals outside the mandatory participation CBSA also be mandated to participate in TEAM?
Acute care hospitals paid under the IPPS and OPPS with a CCN primary address located in a mandatory CBSA are required to participate in TEAM. Therefore, it is possible for a hospital that is located outside of a mandatory CBSA to participate in TEAM if the CCN they use has a CCN primary address located in a mandatory CBSA. CMS has published a list of TEAM participant hospitals on TEAM’s webpage, which was updated to include hospitals that completed a voluntary participation election letter and were accepted for voluntary participation pending their continued fulfillment of the eligibility requirements.
Health systems or other organizations with multiple CCNs can reference the list linked above to understand which hospitals are required to participate in TEAM.
Are TEAM participants eligible to move between participation tracks?
Yes, TEAM participants are eligible to move between participation tracks as long as they meet track eligibility requirements and notify CMS of their track selection in the form and manner and by the deadline set by CMS.
Is there an appeal process to be excluded from participation?
No, there is not an appeal process for participation exclusion. In the context of a mandatory model such as TEAM, hospitals located in mandatory CBSAs that meet the TEAM participant definition are required to participate in the model even if they have not had previous episode-based payment model or value-based care experience.
Are Ambulatory Surgical Centers (ASCs) or joint venture ASCs located in mandatory participation CBSAs included in TEAM?
No, ASCs do not meet the TEAM participant definition and are not included in TEAM as TEAM participants. However, Medicare spending resulting from services performed at an ASC may be included in episode spending if the ASC services were performed during the episode window.
Voluntary Opt-In Opportunity
Who is eligible to voluntarily participate in TEAM?
CMS held a one-time opportunity for select hospitals to opt in to participate in TEAM from January 1-31, 2025. The deadline to submit a voluntary participation election letter was on January 31, 2025. Hospitals not located in a mandatory CBSA that participate until the last day of the last performance period in the Bundled Payments for Care Improvement Advanced (BPCI Advanced) Model or the last day of the last performance year of the Comprehensive Care for Joint Replacement (CJR) Model (December 31, 2025, and December 31, 2024, respectively) were considered eligible to opt-in to TEAM.
CMS updated TEAM’s participant list (XLSX) to include voluntary opt-in participants and shared it on April 7, 2025. CMS does not anticipate allowing additional voluntary opt-in opportunities at this time.
Can hospitals eligible to voluntarily participate in TEAM join at any point during the model?
No, CMS offered the voluntary opt-in period as a one-time opportunity for select hospitals to opt in to TEAM participation. CMS required that eligible hospitals notify them of their intent to participate by January 31, 2025.
CMS does not anticipate additional opt-in opportunities at this time.
When will previous CJR or BPCI Advanced participants that opted in to participate in TEAM (e.g., BPCI Advanced participant for Model Year (MY) 1-5) be required to participate?
CMS requires all hospitals that opted in TEAM to participate in all episode categories for the full five-year model performance period (January 1, 2026, through December 31, 2030).
Hospitals that participate until the last day of the last performance period in the BPCI Advanced Model or the last day of the last performance year of the CJR Model (December 31, 2025, and December 31, 2024, respectively) were considered eligible to opt in to TEAM; to remain eligible for TEAM participation, hospitals must participate in BPCI Advanced or CJR until the last day of the last performance period.
Can acute care hospitals who opt in to TEAM participation opt out of the model after implementation begins?
No, hospitals who opted into TEAM are not eligible to opt out of the model.
When and how were eligible hospitals that voluntarily applied to participate in TEAM notified of their participation status?
CMS emailed eligible hospitals and provided them with notification of their eligibility to participate in the model. CMS treats the voluntary participation election letter that hospitals submitted as the participation agreement for TEAM.
Episodes/Payments
When will CMS share target prices and baseline data with hospitals participating in TEAM?
TEAM participants that complete a TEAM Data Sharing Agreement (DSA) and a TEAM Data Request and Attestation (DRA) form are eligible to receive target prices and baseline data. These preliminary target prices are calculated using 3 years of baseline data, trended forward to the performance year, at the level of MS-DRG/HCPCS episode type and region, with updates to be made using the performance year data during the reconciliation process.
For Performance Year 1, CMS has distributed early preliminary baseline claims and target pricing data in Summer 2025 with TEAM participants that completed the required forms in the TEAM Portal by May 26, 2025. CMS also intends to share updated preliminary target prices and baseline data in Fall 2025 that will reflect any policies finalized in FY 2026 IPPS/LTCH PPS Final Rule.
In Performance Years 2-5, CMS intends to share preliminary target prices and baseline data prior to the start of each performance year.
Can you explain TEAM’s risk adjustment methodology?
TEAM’s risk adjustment methodology uses baseline data to calculate risk adjustment factors and hold them constant at reconciliation. Risk adjustment factors will be calculated and made available to TEAM participants prior to the start of each performance year, so TEAM participants will be able to use them to estimate their episode-level target prices. Risk adjustment factors include age group, Hierarchical Condition Category (HCC) count based on HCC version 28, and beneficiary economic risk adjusters, as well as episode category-specific HCC adjusters and provider-level adjusters.
CMS will conduct a 180-day lookback for each TEAM beneficiary that meets the beneficiary inclusion criteria during the entire 180-day lookback period, beginning with the day prior to the anchor hospitalization or anchor procedure to determine which HCC variables the beneficiary is assigned and determine the HCC episode-specific flags as well as the TEAM HCC count flag.
CMS will use a beneficiary economic risk adjustment factor for beneficiary-level risk adjustment. This variable is a single binary variable with a value of yes=1 if the TEAM beneficiary meets one or more of the following measures: national-level Community Deprivation Index (CDI) above the 80th percentile, eligibility for the low-income subsidy, and eligibility for full Medicaid benefits.
The risk adjustment factors will be calculated at the MS-DRG/HCPCS level on baseline episodes, using a weighted linear regression where episodes are weighed differentially based on whether they belong in relation to year 1, 2, or 3 of the baseline periods. Episodes from baseline year 1 will be weighed at 17 percent, baseline year 2 at 33 percent, and baseline year 3 at 50 percent. The risk adjustment factors will be held fixed and applied to performance year episodes at reconciliation based on the realized case mix of the TEAM Participant in the performance year.
CMS has finalized a list of risk adjustment variables to include in TEAM’s risk adjustment methodology which are described in § 512.545(a).
How are TEAM’s preliminary target prices constructed?
Target prices will be calculated using 3 years of baseline data, trended forward to the performance year, at the level of MS-DRG/HCPCS episode type and region, where region is defined by the U.S. Census Divisions, with updates to be made using the performance year data during the reconciliation process. Episode spending will be capped using the high-cost outlier cap at the level of MS-DRG/HCPCS episode type and region, resulting in 261 benchmark prices.
Benchmark prices are calculated using all hospitals in a region, regardless of TEAM participation status. CMS will apply a prospective trend factor, constructed from five years of data, and a discount factor to benchmark prices, as well as a prospective normalization factor to calculate preliminary target prices. More information about preliminary target prices is available in § 512.540(b) as well as the target price specifications shared with participants via email and the TEAM eDFR platform.
During preliminary target price dissemination, CMS will provide TEAM participants with resources, such as target price and episode construction specification documents, to help support TEAM participants' understanding of the pricing methodology.
What is the prospective normalization factor that will be applied to preliminary target prices?
The prospective normalization factor refers to the multiplier incorporated into the preliminary target price to ensure that the average total risk-adjusted benchmark price does not exceed the average total unadjusted benchmark price.
CMS will calculate the prospective normalization factor for each regional MS-DRG/HCPCS episode type in each performance year as the sum of the average unadjusted benchmark prices divided by the sum of the average risk-adjusted benchmark prices.
What is the prospective trend factor that will be applied to preliminary target prices?
The prospective trend factor refers to the multiplier incorporated into the preliminary target price to account for year-to-year fluctuations in spending that may result from factors including new technologies, medical advancements, and unexpected changes in health care utilization. To avoid amplifying short-term regional trends that do not represent longer-term cost trends for TEAM participants, the prospective trend factor applied to preliminary target prices is the average (arithmetic mean) of a regional trend factor and a national trend factor.
The prospective trend factor is calculated as an annual percentage change using a log-linear model to fit the logarithmically transformed values of average regional MS-DRG spending for each of the baseline years. Where data is available, CMS will use two additional years of episode spending data (two years immediately prior to the 3-year baseline period) in their calculation of the prospective normalization factor for preliminary target prices that are shared with TEAM participants prior to the start of each PY. The national MS-DRG trend factor would be calculated in the same manner as the regional MS-DRG trend factors using a linear regression of logarithmically transformed national average MS-DRG spending.
What is the percentage discount factor that will be applied to each of the five episode categories?
Discount factors by episode category:
- 1.5% discount factor for the CABG episode category.
- 1.5% discount factor for the Major Bowel Procedure episode category.
- 2% discount factor for the Spinal Fusion episode category.
- 2% discount factor for the LEJR episode category.
- 2% discount factor for the SHFFT episode category.
What is the high-cost outlier cap?
The high-cost outlier cap is the amount at which episode spending would be capped for the purposes of determining baseline and performance year episode spending. CMS defines the high-cost outlier cap at § 512.505 to mean the 99th percentile of regional spending for a given MS-DRG/HCPCS episode type, region, and baseline year.
How will TEAM impact Medicare FFS payments?
Episode-based payment models such as TEAM aim to move away from a FFS payment structure by including pay-for-performance methodologies that incentivize improvements in patient outcomes while lowering Medicare spending. TEAM participants and all Medicare providers and suppliers associated with an episode will continue to bill Medicare FFS. All the spending for items and services that are included in an episode attributed to the TEAM participant will be included in an annual reconciliation process.
TEAM may benefit Medicare beneficiaries by improving the coordination of items paid for through Medicare FFS payments, encouraging provider investment in health care infrastructure and redesigned care processes, and incentivizing higher value care settings for the episode.
What types of data will CMS share with hospitals participating in TEAM?
CMS will share preliminary target prices and baseline data with hospitals in TEAM, pursuant to a complete data sharing agreement (DSA) and data request and attestation form (DRA). Additionally, certain beneficiary-identifiable claims data and regional aggregate data will be available. The DRA Form will support a formal data request allowing the TEAM Participant to indicate data type preference, like receiving raw or summary level beneficiary identifiable claims data for TEAM beneficiaries who would be in an episode during the baseline period and performance years. The DSA will ensure TEAM participants comply with applicable laws and safeguards for obtaining the data.
How often and in what format will claims data be shared?
Baseline period data will be shared with TEAM participants prior to each performance year. CMS will use a 3-year rolling baseline period as described in § 512.540(b)(2). For example, for PY1, covering the period from January 1, 2026, to December 31, 2026, TEAM participants may be eligible to receive baseline period claims data from January 1, 2022, to December 31, 2024.
CMS has shared early preliminary baseline claims data with TEAM participants who submitted their DSA and DRA form by May 26, 2025. CMS also intends to share baseline period claims data, along with updated preliminary target prices, with TEAM participants in Fall 2025.
Performance year data may be shared with TEAM participants on a monthly basis depending on DRA form submission. It’s important to note that TEAM participants will be required to complete, sign, and submit a TEAM DSA and DRA form at least annually to receive data from CMS.
Please explain TEAM's reconciliation process?
CMS will reconcile, on an annual basis, all the episode spending from the episodes attributed to a TEAM participant against the reconciliation target price. TEAM participants that spend less than the reconciliation target price may earn a reconciliation payment from CMS, which is subject to quality and other adjustments. TEAM participants that spend more than the reconciliation target price may owe CMS a repayment amount, which is subject to quality and other adjustments.
The reconciliation process will begin approximately 6 months after the end of each performance year. Each performance year will undergo one reconciliation cycle.
Please explain how TEAM episodes will be initiated and any cut-off dates for how CMS will calculate reconciliation.
Episodes are initiated when a beneficiary is admitted to a TEAM participant hospital for an anchor hospitalization, as identified by a Medicare Severity Diagnosis Related Group (MS-DRG), or when a beneficiary receives an anchor procedure from a TEAM participant hospital, as identified by a Healthcare Common Procedure Coding System (HCPCS) code, described in § 512.525.
CMS will use the anchor hospitalization or anchor procedure start date and discharge date to determine how an episode is attributed to a performance year. For example, episodes with anchor hospitalization start dates or anchor procedure dates beginning on or after January 1, 2026, and anchor hospitalization discharge dates or anchor procedure dates between January 1, 2026, and December 31, 2026 will be attributed to performance year 1.
In regard to reconciliation, will all TEAM participants that bill a service to a TEAM beneficiary in an episode be paid through a single bundled payment?
While TEAM is considered an episode-based payment model, TEAM participants, nor any provider or supplier that cares for a TEAM beneficiary, are not paid a single bundled payment for all the items and services provided to a TEAM beneficiary. All Medicare providers and suppliers that care for a TEAM beneficiary, inclusive of the TEAM participant, continue to bill Medicare FFS, as usual.
How were episodes chosen for the model?
Based on the feedback received from its 2023 Request For Information (RFI), CMS selected episodes with sufficient volume that are clinically similar, have well-defined beginnings and endings, and have demonstrated success in reducing episode payments and achieving net Medicare savings (for instance, in BPCI Advanced). While the episodes that are included in TEAM are surgical, CMS may explore adding additional episode categories to TEAM in the future. Any episode categories added to TEAM would be done through notice and comment rulemaking.
What are the codes that would initiate an episode for each of the included TEAM surgical procedures?
Lower extremity joint replacement (LEJR):
• MS-DRG 469, 470, 521, 522
• HCPCS 27447, 27130, 27702Surgical hip and femur fracture treatment (SHFFT):
• MS-DRG 480, 481, 482Spinal fusion:
• MS-DRG 402, 426, 427, 428, 429, 430, 447, 448, 450, 451, 471, 472, 473
• HCPCS 22551, 22554, 22612, 22630, 22633Coronary artery bypass graft:
• MS-DRG: 231, 232, 233, 234, 235, 236Major bowel procedure:
• MS-DRG 329, 330, 331Any changes to the codes that would initiate a clinical episode would be updated through notice and comment rulemaking.
What is included in the TEAM episode?
CMS will provide hospitals participating in TEAM with a target price that will represent most Medicare spending during an episode of care, which will include the surgery (including the hospital inpatient stay or outpatient procedure) and items and services in the 30 days following hospital discharge, such as skilled nursing facility stays or provider follow-up visits.
As described in § 512.525(e), episodes include but are not limited to, the following items and services: physicians’ services, inpatient hospital services (including services paid through IPPS operating and capital payments), inpatient psychiatric facility (IPF) services, long-term care hospital (LTCH) services, inpatient rehabilitation facility (IRF) services, skilled nursing facility (SNF) services, home health agency (HHA) services, hospital outpatient services, outpatient therapy services, clinical laboratory services, durable medical equipment (DME), Part B drugs and biologicals, hospice services, and Part B professional claims date in the 3 days prior to an anchor hospitalization if a claim for the surgical procedure for the same episode category is not detected as part of the hospitalization because the procedure was performed by the hospital on an outpatient basis, but the patient was subsequently admitted as an inpatient.
What items or services are excluded from TEAM episodes?
As described in § 512.525(f), TEAM will exclude from episodes all Part A and B items and services, for both the baseline period and performance years, for hospital admissions and readmissions for specific categories of diagnoses, such as oncology, trauma medical admissions, organ transplant, and ventricular shunts determined by MS-DRGs, as well as all the following excluded Major Diagnostic Categories (MDC):
- MDC 02 (Diseases and Disorders of the Eye)
- MDC 14 (Pregnancy, Childbirth, and Puerperium)
- MDC 15 (Newborns and other neonates with conditions originating in perinatal period)
- MDC 25 (Human immunodeficiency virus infections)
Additionally, there are exclusions of new technology add-on payments for drugs, technologies, or services approved for add-on payments from episodes. Drugs or biologicals that are paid outside of the MS-DRG, specifically hemophilia clotting factors, identified through HCPCS code, diagnosis code, and revenue center on IPPS claims for episodes in the baseline period and performance years.
Does TEAM have a low-volume episode policy?
If a TEAM participant does not meet the low volume threshold of at least 31 episodes in a given performance year’s baseline period for a given episode category, CMS will still reconcile their episodes. However, the TEAM participant will not be held accountable for any performance year episode spending that exceeded the reconciliation target price for each of the MS-DRG/HCPCS episode types in that given episode category during the applicable performance year.
This policy, finalized in the FY 2026 Hospital IPPS and LTCH PPS Final Rule, effectively waives downside financial risk for the TEAM participant for episode categories in which they did not meet the considered low volume threshold in the baseline period.
Learning System/Technical Assistance
What education or learning resources will CMS provide to selected hospitals? Is there a calendar of learning resources that will be available?
CMS is taking multiple steps to assist hospitals participating in TEAM with understanding both TEAM’s pricing methodology, and how they can use data to help them succeed in the model. During 2025, CMS has provided TEAM participants with resources on various aspects of TEAM including target prices, episode construction and exclusions, participation tracks, collaboration with ACOs, and comparisons with BPCI Advanced and CJR.
Additionally, since the mandatory CBSA selection was finalized in the FY 2025 IPPS/LTCH PPS Final Rule in August 2024, and since any hospitals in mandatory CBSAs that open or become eligible for TEAM after December 31, 2024 will have a limited deferment period, all hospitals will have at least one year to prepare before the model start date. During this time, CMS will continue to engage with hospitals and provide learning resources and opportunities to help them further understand TEAM policies, including the construction of target prices.
When will CMS share a template for the beneficiary notification letter and TEAM collaborator notice?
TEAM participants are required to share a written beneficiary notification, as described in § 512.582(b), to all TEAM beneficiaries prior to discharge from the anchor hospitalization or anchor procedure. CMS anticipates sharing the beneficiary notification template with TEAM participants prior to Performance Year 1. The beneficiary notification letter is intended to inform TEAM beneficiaries about the model, specifically how it will impact their care, their freedom of choice, their ability to report concerns, and other requirements.
In addition, TEAM will require every TEAM collaborator to provide a written TEAM collaborator notice to TEAM beneficiaries of the existence of its sharing arrangement with the TEAM participant and the basic quality and payment incentives under the model. The notice must be provided no later than the time at which the beneficiary first receives an item or service from the TEAM collaborator during an episode. CMS recognizes that due to the patient’s condition, it may not be feasible to provide notification at such time, in which case the notification must be provided as soon as is reasonably practicable. CMS anticipates sharing the TEAM collaborator notification template with TEAM participants prior to Performance Year 1.
How will the beneficiary notification letter and TEAM collaborator notice be monitored for evaluation? Will TEAM participants be required to maintain copies for auditing purposes?
CMS may audit the medical records and claims of TEAM participants in order to ensure that beneficiaries receive medically necessary services and ensure TEAM participants’ compliance with model requirements, as described under the § 512.590. CMS may also monitor arrangements between TEAM participants and their TEAM collaborators to ensure that such arrangements do not result in the denial of medically necessary care, or other areas that could compromise beneficiary safety and protections.
How can I sign up for updates about TEAM?
CMS will share updates regarding TEAM via the listserv. If you are not already subscribed, please use this link and input your email address to receive updates about the model.
How can I contact the TEAM model team?
You can reach out to TEAM via email (CMMI_TEAM@cms.hhs.gov).
Portal and Points of Contact (POC)
What are the different portals for TEAM participants, and how can I access them?
The TEAM Portal is an online collaboration platform through CMS.gov|IDM. TEAM participants will be invited to register for the portal.
The TEAM Expanded Data Feedback Reporting (eDFR) is an online application through CMS.gov|Enterprise Portal. Within TEAM’s eDFR there is the Custom Export Tool (CET), which will be the mechanism for TEAM participants to receive target prices and data. CMS will invite the Data Custodians to register for TEAM’s eDFR to obtain access to the platform and the CET. Please note that the data will not be shared until the TEAM participant has completed a DSA and DRA Form.
What are the different Point of Contact (POC) types in the TEAM Portal, and what is the role of each type?
TEAM participants may have up to two primary POCs. Primary POCs will receive CMS communications about TEAM, may submit deliverables in the TEAM portal, and have the ability to add and remove POCs from the TEAM portal, including designating POCs as Data Custodians and as an Authorized Signatories.
TEAM participants may have multiple Secondary POCs. Secondary POCs will receive CMS communications about TEAM, may submit deliverables in the TEAM portal, and edit their own contact information in the TEAM portal.
Data Custodians are individuals that a TEAM participant will identify to ensure compliance with all privacy and security requirements and for notifying CMS of any incidents relating to unauthorized disclosures of beneficiary-identifiable data. Data Custodians are also the only individuals allowed to access the TEAM eDFR platform where CMS will share target prices and data via the CET. A Data Custodian designation is not mutually exclusive and therefore individuals with this POC designation can also be identified as a primary or secondary POC.
The Authorized Signatory is the only point of contact who can view, complete, and submit the DRA Form and DSA. The Authorized Signatory designation is not mutually exclusive and therefore individuals with this POC designation can also be identified as a primary or secondary POC.
Can hospital systems designate the same POC for multiple hospitals within a system?
Yes. CMS is requesting at least one Primary POC for each hospital participating in TEAM. Multiple hospitals that are affiliated with each other may select the same Primary POC for TEAM-related communications as appropriate.
How can TEAM participants verify their POCs?
TEAM participants can verify their POCs by logging into the TEAM portal and navigating to the Contacts section. Additionally, TEAM participants can also submit an email to CMMI_TEAM@cms.hhs.gov to confirm their POCs.
How can I update the POC for our hospital?
Primary POCs for a TEAM participant can log into the TEAM portal, navigate to the Contacts section and update the TEAM participant’s POCs. In the event a TEAM participant does not have any active Primary POCs, TEAM participants may submit an email to CMMI_TEAM@cms.hhs.gov with the subject line “Primary Point of Contact”, that contains hospital information (e.g., name, CCN), and the contact information (e.g., name, email address, phone number) of the individuals to be added, removed, or changed. It may take up to two weeks for requests to be reflected in the TEAM portal and in TEAM-related communications.
Care Delivery / Quality Strategy
Will TEAM qualify as an Advanced Alternative Payment Model (APM)?
Yes, TEAM will qualify as an Advanced APM. TEAM offers two APM options — an Advanced APM (AAPM) option, which requires TEAM participants in Track 2 and Track 3 to attest that they meet the Certified Electronic Health Record Technology (CEHRT) criteria, and a non-Advanced APM (non-AAPM) option, for those who do not meet the CEHRT criteria or participate in Track 1. Only TEAM participants in Track 2 and Track 3 may qualify for the AAPM option, while TEAM participants in Track 1 only qualify for the Non-AAPM option. CMS will provide TEAM participants with instructions to select their APM option on a form within the TEAM Portal prior to Performance Year 1. TEAM participants will be asked to make their APM option selection along with their participation track selection prior to each performance year.
What are quality measures included in TEAM?
TEAM’s quality measures focus on care coordination, patient safety, and patient reported outcomes (PROs) which we believe represent areas of quality that are particularly important to patients undergoing acute procedures. CMS will use data that hospitals already report through existing CMS quality reporting programs (the Hospital Inpatient Quality Reporting (IQR) Program, the Hospital-Acquired Condition Reduction Program, and the Hospital Outpatient Quality Reporting Program), to avoid duplicative reporting requirements.
The table below summarizes the quality measures, applicable episodes and performance years, and baseline periods that CMS has finalized:
Measure Episodes Performance Years Baseline Period Hybrid Hospital-Wide All Cause Readmission measure (CMIT ID #356) All 1-5 CY 2025 CMS Patient Safety and Adverse Events Composite (CMS PSI) (CMIT ID #135) All 1 CY 2025 Hospital-Level Total Hip and/or Total Knee Arthroplasty (THA/TKA) Patient-Reported Outcome-Based Performance Measure (PRO-PM) (CMIT ID #1618) LEJR 1-5 CY 2025 Hospital Harm – Falls with Injury (CMIT ID #1518) All 2-5 CY 2026 Hospital Harm – Postoperative Respiratory Failure (CMIT ID #1788) All 2-5 CY 2026 Thirty-Day Risk-Standardized Death Rate among Surgical Inpatients with Complications (Failure-to-Rescue) (CMIT ID #134) All 2-5 CY 2026 Information Transfer PRO-PM LEJR, Spinal Fusion 3-5 CY 2027 How will CMS evaluate quality measure data for newly established or opened hospitals located in mandatory CBSAs?
TEAM participants that may have insufficient quality measure data, such as hospitals that are newly opened, will be given a neutral quality measure score for a given quality measure. Specifically, if a TEAM participant does not have a raw quality measure score for a given quality measure during a performance year, CMS will assign a scaled quality measure score of 50, which is the midpoint on the CQS scale of 0-100.
Please explain TEAM’s data sharing process.
CMS will make certain beneficiary-identifiable claims data and regional aggregate data available to hospitals in TEAM regarding Medicare FFS beneficiaries who may initiate an episode and be attributed to them in the model for the purposes of evaluating their performance, conducting quality assessment and improvement activities, conducting population-based activities relating to health or reducing health care costs, or conducting other health care operations. For the baseline period, hospitals will only receive beneficiary-identifiable claims data for beneficiaries that initiated an episode in their hospital or hospital outpatient department in the 3-year baseline period. CMS will limit the data to items and services included in the episode.
Hospitals participating in TEAM may request to receive summary or raw beneficiary-identifiable claims data for a 3-year baseline period prior to the performance year as well as on a monthly basis during the performance year to help them engage in care coordination and quality improvement activities for TEAM beneficiaries in an episode.
To receive beneficiary-identifiable data from CMS, TEAM participants must annually submit a DSA and a DRA form.
Does TEAM qualify as a value-based program? Will it be on QualityNet?
TEAM will qualify as an Advanced APM which falls under the Quality Payment Program (QPP). QPP establishes a process to reward clinicians who provide high-quality patient-centered care. QPP aims to improve the quality and safety of care for all individuals and to reduce the administrative burden on clinicians, allowing more time to focus on person-centered care and improving health outcomes.
At this time, CMS will not include TEAM on QualityNet, but plans to post TEAM participant quality measure performance on the TEAM webpage.
Which quality measures included in TEAM are electronic clinical quality measure(s) (eCQMs)?
TEAM uses the following quality measures as eCQMs:
- Hybrid Hospital-Wide All-Cause Readmission Measure with Claims and Electronic Health Record Data (CMIT ID #356)
- Hospital Harm—Falls with Injury (CMIT ID #1518)
- Hospital Harm—Postoperative Respiratory Failure (CMIT ID #1788)
What patient-reported outcome measures (PROMs) need to be collected in addition to the LEJR PRO-PM requirements?
TEAM does not require participants to report additional quality measures beyond those they already submit to CMS for other programs. This is because the quality measures used in TEAM, inclusive of the Hospital-Level Total Hip and/or Total Knee Arthroplasty (THA/TKA) Patient-Reported Outcome-Based Performance Measure (PRO-PM) (CMIT ID #1618) and Information Transfer PRO-PM, are measures that TEAM participants must already report to CMS for other quality reporting programs.
Please explain the referral to primary care services requirement under TEAM.
Since a TEAM episode only lasts 30 days after the TEAM beneficiary is discharged from the hospital, CMS aims to integrate care during the transition from an acute event – an episode – back to longitudinal care relationships, such as primary care. CMS requires TEAM participants to include in hospital discharge planning a referral to an established supplier of primary care services for a TEAM beneficiary, on or prior to discharge from an anchor hospitalization or anchor procedure. TEAM participants must also comply with beneficiary freedom of choice requirements, as codified in § 512.582(a), and not limit a TEAM beneficiary’s ability to choose among Medicare providers or suppliers.
Financial Arrangements/TEAM Collaborators
What is the financial impact on TEAM collaborators performing the procedure or coordinating care if funds are owed?
Hospitals participating in TEAM may choose to enter into financial arrangements with certain providers and suppliers participating in TEAM activities to share their reconciliation payment amount or repayment amount resulting from participation in TEAM. Specifically, TEAM participants may enter into a sharing arrangement with a TEAM collaborator in order to make a gainsharing payment and/or receive an alignment payment. The board or other governing body of the TEAM participant must have responsibility for overseeing the TEAM participant’s participation in the model, its arrangements with TEAM collaborators, its payment of gainsharing payments, its receipt of alignment payments, and its use of beneficiary incentives in the model. The TEAM participant and TEAM collaborator must document this agreement in writing and provide it to CMS upon request as part of TEAM’s monitoring and compliance activities (also described in § 512.590).
Practitioners will continue to bill Medicare as normal under fee-for-service. At the end of the performance year, CMS reconciles total episode spending against the retrospectively adjusted final target price. CMS adjusts reconciliation amounts for quality performance and applies stop-gain and stop-loss limits (stop-loss limits only apply to Track 2 and Track 3).
A TEAM collaborator in a sharing arrangement with a TEAM participant may enter into a distribution arrangement with a collaboration agent in order to distribute any gainsharing payments it receives. A collaboration agent in a distribution arrangement with a TEAM collaborator may enter into a downstream distribution arrangement with a downstream collaboration agent in order to distribute any distribution payments it receives. The final rule in § 512.565 (b)-(c) provides additional details about eligibility requirements and restrictions for financial arrangements in TEAM.
How can hospitals manage gainsharing or alignment payments with TEAM collaborators that are not tied to the volume of episodes?
TEAM is designed to encourage participants to make primary care referrals and engage with a patient’s aligned total cost of care (or shared savings model), if applicable. In determining the amount of any gainsharing payments, a TEAM participant’s gainsharing methodology may take into account the amount of such TEAM activities provided by a TEAM collaborator relative to other TEAM collaborators, however, gainsharing payments and alignment payments should not be based directly on volume or value of referrals. CMS believes this requirement allows flexibility in the determination of gainsharing payments to TEAM collaborators, who have differing contributions to TEAM activities. We understand that this may result in greater differences in the funds available for gainsharing payments and believe that this allows for gainsharing payments to be made appropriately, without tying them directly or indirectly to the volume or value of referrals.
How can post-acute care (PAC) providers become part of a TEAM participant’s PAC network?
TEAM’s financial incentives are designed to incentivize innovative care delivery methods that focus on improving care and reducing Medicare spending. CMS anticipates TEAM participants and PAC providers, such as skilled nursing facilities and home health agencies, to form partnerships that share financial risk and collaborate on care design strategies. When TEAM participants complete their DSA and DRA forms, CMS provides them with hospital-specific and regional aggregate data. TEAM participants can use this data to guide decision making about PAC providers for TEAM.
TEAM participants may use data and resources to create financial arrangements with TEAM collaborators, such as physicians, PAC providers, and other clinical care providers, to ensure the best quality of care in a cost-effective manner. Depending on the terms of the financial arrangement, TEAM participants may hold other providers and suppliers accountable for upside and downside financial risk.
Model Overlap
- How would TEAM overlap with other CMS models or initiatives?
TEAM would not overlap with the CMS Innovation Center’s current episode-based payment models because they are scheduled to end before the start of TEAM. Specifically, the Comprehensive Care for Joint Replacement (CJR) Model is scheduled to end in December 2024, and the Bundled Payments for Care Improvement Advanced (BPCI Advanced) Model is scheduled to end in December 2025.
TEAM would allow provider and individual overlap with most CMS models and initiatives, including advanced primary care models and ACO initiatives. For example, a person with traditional Medicare receiving care from (aligned to) providers in an ACO may be in an episode if they receive one of the surgeries included in TEAM at a hospital required that is selected to participate in TEAM. CMS would not perform any adjustments to a TEAM participant’s reconciliation payment amount or repayment amount when there are patients who overlap TEAM and ACO initiatives. Allowing model overlap provides an opportunity for an ACO and TEAM participant to collaborate on shared patients and ensure a smooth transition of care between the TEAM participant and the ACO.
How does TEAM impact the shared savings of a Medicare Accountable Care Organization (ACO) initiative when there is model overlap?
A hospital that participates in a Medicare ACO initiative, such as ACO REACH or the Medicare Shared Savings Program, and that also participates in TEAM will be accountable for the quality and cost of care for ACO-aligned beneficiaries who have surgeries that would initiate an episode tested in TEAM. TEAM will not adjust a TEAM’s participant’s target prices or reconciliation payment amounts and repayment amounts based on model overlap with ACO REACH or the Medicare Shared Savings Program.
TEAM will not include ACO REACH or the Medicare Shared Savings Program’s shared savings payments or shared loss recoupments when determining episode spending and target pricing calculations.
ACO REACH and the Medicare Shared Savings Program will not take into consideration TEAM’s reconciliation payment amounts or repayment amounts when determining ACO REACH or the Medicare Shared Savings Program’s benchmarks or performance year spending because the timing of TEAM’s reconciliation process occurs after ACO REACH and the Medicare Shared Savings Program conducts their calculations.
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