With CMS’ Transforming Episode Accountability Model (TEAM) set to begin January 1, 2026, selected hospitals have limited time to prepare for compliance with the model and successful performance in the five high-volume surgical episodes it includes. If your hospital was selected, here are five key things to pay attention to now.
1. Required Submissions Due December 31, 2025
To comply with the model’s requirements, selected hospitals must complete several key submissions by the end of calendar year 2025. These include:
- Selection of the risk track for 2026 – The choice between Tracks 1, 2, and 3 impacts the length of the glide path to downside risk.
- Selection of the Alternative Payment Model (APM) option – Participants in Tracks 2 and 3 may select the Advanced APM (AAPM) option, while participants in Track 1 may only select the non-AAPM option.
- Submission of all Financial Arrangement List (FAL) and Clinician Engagement List (CEL) relationships within the program – Hospitals will also need to update this information quarterly.
Only authorized signatories within the TEAM participant portal can complete these key compliance tasks.
2. TEAM Requirements Starting Immediately in 2026
While most TEAM participants will not have downside risk within the first model year, all participants are subject to certain compliance requirements starting January 1, 2026. These include:
- Beneficiary Notification: Participants must notify beneficiaries in TEAM episodes of the hospital’s participation in the model. This notification should be traceable through the hospital’s electronic health record (EHR) system.
- Referral to Primary Care: Participants must provide a primary care referral to beneficiaries in TEAM episodes upon discharge. Referrals must respect the beneficiary’s choice of primary care provider.
3. CMS Claims Data Limitations
In late 2025, CMS is providing participating hospitals with basic target price and performance data for the five TEAM episodes. However, the target prices CMS provides are pending final adjustments, and CMS provides the performance data in a raw format that does not easily allow for actionable insights.
Forvis Mazars has the data tools and capabilities to help TEAM hospitals glean meaningful information from the CMS data. For example, we can help hospitals understand the difference between their historical performance and the TEAM target prices, identify performance indicators that explain the variation, and help develop a road map to improve performance throughout the TEAM time span.
4. Risk Variability Across TEAM Performance Years
As mentioned above, a hospital’s risk track will impact the length of the glide path to downside risk, which can play a significant role in the amount of incentives and/or losses over the course of the model. Most TEAM participants will not face downside risk in year one. However, risk tracks will be re-evaluated for each model year, and some hospitals could be at risk of losing thousands of dollars per case starting in 2027.
Given the time required to establish policies and care pathways that support success in TEAM, participating hospitals should not use the lack of downside risk in year one as a reason to delay. Instead, they should start developing plans now and begin taking steps to strengthen episode performance for year two and beyond.
5. TEAM Requirements for Low Episode Volume Hospitals
In the 2026 Inpatient Prospective Payment System final rule, CMS modified TEAM policies to reduce downside risk for hospitals with fewer than 31 cases in the baseline period for one or more of the five TEAM episode categories. However, these low episode volume hospitals are still required to comply with all model requirements, including:
- Submitting risk track selection, APM model selection, FAL, and CEL relationships by the required deadline.
- Beneficiary notification and referral to primary care for all TEAM episodes (even those with low volume).
- Tracking performance in all TEAM episodes (even those with low volume) to prepare for CMS reconciliation.
How Forvis Mazars Can Help
Our value-based care team at Forvis Mazars has extensive experience supporting hospitals in TEAM, BPCI-A, and other bundled payment models. We can help you prepare efficiently in the remaining time before TEAM begins and support compliance, performance, and monitoring throughout the course of the model. If you have questions or would like assistance preparing for TEAM, please reach out to our professionals today.