This week, AAHKS submitted comments to the Centers for Medicare & Medicaid Services (CMS) on their 2025 Medicare Inpatient Prospective Payment System (IPPS) Proposed Rule, including the proposed Transforming Episode Accountability Model (TEAM) episode of care that will replace the Comprehensive Care for Joint Replacement (CJR) model in 2026. Our comments on the IPPS proposed rule highlighted that the proposed arthroplasty payment rate increases for facilities shows the disparity in Medicare physician reimbursement, the proposed IPPS market basket update is inadequate to meet the actual costs faced by facilities and that we support the removal of duplicative measures from the Hospital Value-Based Payment Program. 

For the TEAM proposal, our comments restated that physicians with requisite qualifications should be permitted to participate in any CMMI model as episode initiators and conveners; excluding ASCs from items and services included in the TEAM model episode will skew incentives for determining the best site of service/admission status for procedures under the TEAM model; and the proposed three-year rolling benchmarking methodology with annual updates under TEAM is too aggressive for many rural and small providers with little experience in value-based care, among many others. A full summary is available at the beginning of the comment letter. For that and more information, read the letter. 

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