Physician Gainsharing in Mandatory CMS Episode Payment Models: Legal & Operational Implications
- December 20, 2024
- Chad Mulvany , Forvis Mazars
- Jim Daniel , Hancock Daniel & Johnson PC
In the 2025 Inpatient Prospective Payment System (IPPS) rule, the Centers for Medicare & Medicaid Services (CMS) finalized the Transforming Episode Accountability Model (TEAM). Beginning on January 1, 2026, approximately 700 hospitals in selected markets are required to participate in a two-sided risk model focused on five surgical episodes of care. In addition, current participants in the Comprehensive Care for Joint Replacement (CJR) and Bundled Payments for Care Improvement Advanced (BPCI-A) models may voluntarily opt into TEAM.
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