CMS' new mandatory payment model, the Transforming Episode Accountability Model (TEAM), is only a few months away from launching, but healthcare analysts say that many hospitals still aren't ready and have fallen behind in their preparations, in part due to ongoing policy changes, financial difficulties, and more.
TEAM is a five-year mandatory bundled payment program that will take effect Jan. 1, 2026. According to CMS, TEAM aims to improve quality and reduce costs by promoting care coordination.
"People with traditional Medicare who undergo a surgical procedure in a hospital or hospital outpatient department may experience fragmented care that can lead to complications in recovery, avoidable hospitalization and increased spending," a CMS spokesperson said.
Under TEAM, selected acute-care hospitals will coordinate care for Medicare beneficiaries who undergo one of five common procedures and will assume responsibility for the cost and quality of care, from surgery through the first 30 days after the patient leaves the hospital. The five procedures are lower extremity joint replacements, surgical hip femur fracture treatments, spinal fusions, coronary artery bypass grafts, and major bowel procedures.
According to the Center for Medicare & Medicaid Innovation, TEAM will be mandatory for selected hospitals based on core-based statistical areas (CBSAs), covering over 200,000 episodes annually. Other hospitals will be able to voluntarily participate in TEAM if they are current participants in the BPCI-A or CJR models. Overall, roughly 750 hospitals are expected to participate in the model.
Although TEAM is just a few months away from implementation, healthcare analysts say that many hospitals may still not be ready, with some not having even started assessing data to prepare for the model.
According to Brian Fuller, a managing director in ATI Advisory's value-based care design and delivery practice, some hospitals may have hoped that the Trump administration would cancel, postpone, or modify the model, which originated from the Biden administration. However, CMS only finalized a few minor changes, such as removing downside risk for low-volume hospitals that do not record at least 31 episodes of care in a category.
"Whether or not addressing TEAM is a priority for your organization, documentation of medical necessity for inpatient care and stratifying patient risks with accurate capture of underlying comorbidities should always be a priority. "
Robert Nation, VP of provider actuarial services at Optum Advisory*, said hospitals "know there are things [they] should be doing, but [they] have more pressing concerns with the new Trump bill impact, tariffs, and broader financial margin concerns."
Trump's sweeping tax bill, also known as the One Big Beautiful Bill Act, includes over $1 trillion in cuts to federal healthcare programs, including Medicaid and Medicare, and could lead millions of people losing their health insurance. Trump has also said that planned pharmaceutical tariffs could eventually reach 250%.
"All of that just increasingly subsumes the attention of hospital leaders," Fuller said. "We've definitely been surprised — particularly as we've gotten further into the year and we're now four months away from 'go live' — that we haven't seen kind of more readiness across the marketplace."
"Leaders should not neglect the implications of TEAM even if the impact of the model isn't feeling as impactful today," said Advisory Board's Daniel Kuzmanovich. "The model 1) is a new mandatory model, which is something value-based care enthusiasts have been calling for 2) engages hospitals, not just physicians 3) is going to have financial consequences more quickly than previous models, which keeps with CMS' goals, and 4) was quickly followed by the Ambulatory Specialty Model, which speaks to a focus on engaging specialists and hospitals in VBC, not just primary care," he added.
Fuller also noted that CMS could add new care episodes to the model as soon as next year. Hospitals who are not ready for the first five TEAM models will face even more difficulty if the agency decides to include more procedures
David Shulkin, former Veterans Affairs Secretary and a member of Sanford Health's board, said that CMS' decision to carry over TEAM from the Biden administration shows that the agency is serious about pushing providers to take on greater clinician and financial responsibility.
"Hospitals that did not get selected in this program should not be ignoring this," Shulkin said. "This is a signal of things to come. These are skills and toolsets that hospitals should be thinking about developing and sharpening up, whether they're in the TEAM model or not, because this is really where healthcare is headed."
However, in the end, Sally Hart, clinical senior director at Optum Advisory, said, "whether or not addressing TEAM is a priority for your organization, documentation of medical necessity for inpatient care and stratifying patient risks with accurate capture of underlying comorbidities should always be a priority. Well trained and informed clinical documentation improvement teams and documenting providers are essential to accurately representing patient complexity for reimbursement and quality measures."
*Advisory Board is a subsidiary of Optum. All Advisory Board research, expert perspectives, and recommendations remain independent.
(Early, Modern Healthcare, 8/14)
By Anne Schmidt and Jennifer Puzziferro
As hospitals and health systems prepare for TEAM, they face a landscape crowded with competing priorities, from workforce stabilization and access challenges to ongoing regulatory shifts. TEAM’s bundled payment structure demands not only cost containment but also measurable improvements in care quality, discharge planning, and post-acute outcomes.
Importantly, for organizations selected to participate, inaction is not a neutral stance — it carries real consequences. TEAM is a mandatory model, and failure to engage can result in financial losses due to unmanaged cost variation, readmissions, and inefficient discharge planning. It may also signal to CMS and other stakeholders a lack of commitment to value-based care, which could impact future participation in innovation models or funding opportunities. In short, doing nothing risks financial exposure, reputational damage, and diminished strategic influence.
To fortify financial success and patient-centered results, organizations must move beyond compliance and embrace strategic transformation. Hospitals and health systems should:
As hospitals and health systems prepare for TEAM, they face a landscape crowded with competing priorities, from workforce stabilization and access challenges to ongoing regulatory shifts. TEAM’s bundled payment structure demands not only cost containment but also measurable improvements in care quality, discharge planning, and post-acute outcomes.
Importantly, for organizations selected to participate, inaction is not a neutral stance — it carries real consequences. TEAM is a mandatory model, and failure to engage can result in financial losses due to unmanaged cost variation, readmissions, and inefficient discharge planning. It may also signal to CMS and other stakeholders a lack of commitment to value-based care, which could impact future participation in innovation models or funding opportunities. In short, doing nothing risks financial exposure, reputational damage, and diminished strategic influence.
To fortify financial success and patient-centered results, organizations must move beyond compliance and embrace strategic transformation. Hospitals and health systems should:
By taking these steps, organizations can position themselves not only to meet TEAM requirements, but also to lead in value-based care delivery. With strategic foresight, operational discipline, and commitment to patient-centered outcomes, TEAM can catalyze lasting transformation to strengthen care quality, financial resilience, and system-wide alignment.
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