TEAM Model Frequently Asked Questions

1. How did CMS develop TEAM?
   
   TEAM is informed by lessons learned from earlier CMS Innovation Center episode-based payment models, feedback from a July 2023 Request for Information, and consultation with several stakeholders, including providers, health systems, and thought leaders in the field.
    
2. How does TEAM support the CMS Innovation Center’s Strategic Direction?
   
   TEAM would help to advance several policy goals outlined in the Innovation Center’s 2021 Strategy Refresh, including having all Medicare beneficiaries and most Medicaid beneficiaries in an accountable care relationship by 2030. TEAM is also a component of the Center’s comprehensive specialty care strategy, launched in 2022, a plan that prioritizes testing models and policy innovations supporting access to high-quality, integrated specialty care across the patient journey. Among the goals of the specialty care strategy is to advance lessons learned from episode-based payment models and support care transformation following acute medical events.
    
3. Why is participation in TEAM mandatory for selected hospitals?
   
   Building on lessons learned from previous voluntary models, TEAM would be a mandatory model to advance testing and evaluation of financial accountability for episode-based care as an approach to improve quality of care for patients and lower costs. 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. Recommendations from federal partners, including a September 2023 Congressional Budget Office (CBO) report, and a June 2022 Medicare Payment Advisory Commission (MedPAC) report support testing mandatory episode-based payment models.
    

4. Can hospitals eligible to voluntarily participate in TEAM join at any point during the model?

   No, voluntary opt-in is a one-time opportunity limited to hospitals 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, which are December 31, 2025, and December 31, 2024, respectively. Eligible hospitals interested in voluntary opt-in will be required to submit a written participation election letter to CMS in a form and manner specified by CMS during the voluntary election period of January 1, 2025-January 31, 2025. The participation election letter will serve as the participation agreement, which will bind and subject the eligible hospitals to the same terms, conditions, and requirements in TEAM as hospitals mandated to participate. This includes being required to participate for the full model performance period and being accountable for all episode categories tested in the model.
    

5. 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.
    
6. Where would TEAM be tested?
   
   CMS would implement TEAM in certain selected geographic areas to evaluate the effects of an episode-based payment approach on patient outcomes and Medicare expenditures. To ensure generalizability of evaluation results, CMS would select Office of Management and Budget (OMB)-delineated Core-Based Statistical Areas (CBSAs) across the United States. All acute care hospitals, with limited exceptions, within selected CBSAs would be required to participate in the model. To expand the reach of value-based care, CMS would oversample certain CBSAs, such as those with no or limited exposure to similar previous models and those with safety net hospitals located in them.
    
7. How were episodes chosen for the model?
   
   Based on the feedback received feedback 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 will be 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 future notice-and-comment rulemaking. 
    
8. Will this model qualify as an Advanced Alternative Payment Model (APM)?
   
   TEAM would have two APM options— an Advanced APM option, in which TEAM individuals would attest to meeting the Certified Electronic Health Record Technology (CEHRT) criteria for Qualifying APM Participant (QP) determinations, and a non-Advanced APM option, for those TEAM individuals who do not meet the CEHRT criteria. Since Advanced APMs must also have financial risk, we anticipate TEAM would qualify as an Advanced APM for TEAM individuals in Track 2 and Track 3 who participate in the Advanced APM option. 
    
9. How will CMS address policies not finalized in TEAM or potential changes to future policies?
   
   CMS is finalizing the majority of TEAM's proposals in the FY 2025 Inpatient and Long-Term Care Hospital Prospective Payment System Final Rule and finalizing others with modifications. However, there are certain proposals that are not finalized, and CMS will undergo notice and comment rulemaking to propose new policies in the future before the model start date. Additionally, any potential changes to finalized policies would also undergo notice and comment rulemaking. 

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