AHA provides comments on TEAM proposed rule, asks CMS to make voluntary

The AHA commented on proposed changes to the Transforming Episode Accountability Model, a new, mandatory, episode-based payment model scheduled to begin Jan. 1, 2026.

The five-year program will require acute care hospitals in selected geographic areas to participate in five surgical episodes. The AHA expressed concerns that the model would not meet its goals of improving quality and lowering costs due to its current design and may hamper access to care instead by overburdening providers who do not have the infrastructure or population to be successful. The AHA requested the Centers for Medicare & Medicaid Services to make TEAM voluntary.

“Mandatory participation is inappropriate given that many of the selected organizations are neither of an adequate size nor in a financial position to support the investments necessary to transition to mandatory bundled payment models,” AHA wrote. “Requiring hospitals to take on large, diverse bundles would require more risk than many can manage, threatening their ability to maintain access to quality care in their communities.”

The AHA also recommended other model design changes, including the establishment of a low-volume threshold of 200 cases for individual episode categories. Hospitals not meeting this threshold should be excluded from participation.