Premier Urges Changes to Proposed Mandatory Bundled Payment Model

Premier submitted comments on the proposed mandatory bundled payment model, the Transforming Episode Accountability Model (TEAM), which CMS proposed in its FY 2025 Medicare IPPS/LTCH PPS proposed rule.

Under its proposal, CMS will require selected acute care hospitals to participate in a five-year mandatory episodic payment model starting in calendar year (CY) 2026. Premier believes that voluntary models with the appropriate incentives are ideal as they allow providers to select participation based on their mission, abilities and market realities. However, if CMS chooses to move forward with the mandatory episodic models, Premier strongly urges the agency to consider the following key design principles:

• Provide opportunities for upside financial gains, as well as gradual risk options;
• Allow all participants the opportunity participate under an upside-only track for the first two performance years and allow certain safety net and rural hospitals to remain in upside only for entirety of the model;
• Establish appropriate provider exclusion criteria and flexibilities that recognize the challenges that rural and low-volume providers face with mandatory participation;
• Provide sufficient information and data in advance of model test starts;
• Provide flexibilities and options for those participants who are mandated to participate;
• Create an opportunity for providers to opt-in to the mandatory model to maintain momentum in value-based care and continue a patient-centric focus; and

Continue to engage with the provider community on this model after its launch to address any operational challenges and to ensure providers have meaningful opportunities to advance delivery system transformation.