The Task Force Provides Input to CMS on the Transforming Episode Accountability Model (TEAM)

The Health Care Transformation Task Force submitted input to the Centers for Medicare & Medicaid Services (CMS)  on the Transforming Episode Accountability Model (TEAM), as proposed in the CY2025 Inpatient Prospective Payment Systems Proposed Rule. The Task Force commented on all aspects of the proposed model design, with emphasis on the financial methodology, quality measurement, and mandatory risk for rural and safety net hospitals. Key recommendations include:

  1. No downside risk for rural and safety net hospitals. Ideally, rural and safety net hospitals would not be mandated to take on downside risk for the duration of the model. At minimum, rural and safety net hospitals should have lower financial risk than CMS proposes.
  2. More accurate, less aggressive targets for all hospitals. As proposed, TEAM has more aggressive targets than any previous mandatory or voluntary episode-based model, in addition to using less accurate risk adjustment methodologies. CMS should make the financial risk no higher than for previous models. In addition, CMS should apply adequate risk adjustment, especially related to patients experiencing clinical emergencies or those living in nursing homes.
  3. Clinically appropriate quality measures. Only one of the proposed quality measures is specific to TEAM episodes, while the other measures relate to all Medicare patients treated at a given hospital. This will prevent CMS from appropriately evaluating the clinical results of TEAM. Instead, CMS should identify clinically meaningful measures for TEAM episodes, such as those available in registries.

Read the Letter Here