PEPC Comments on Transforming Episode Accountability Model

The Partnership to Empower Physician-Led Care (PEPC) was pleased to submit comments on the Transforming Episode Accountability Model (TEAM), proposed in the Fiscal Year (FY) 2025 Hospital Inpatient Prospective Payment Systems (PPS) proposed rule.

Our comments raise two points:

  • We support the proposed overlap policy with other APMs, including allowing model overlap without recoupment, and urge CMS to calculate accountable care organization (ACO) spending based on the FFS claims submitted for TEAM episodes rather than TEAM episode target prices.
  • We urge CMS to put appropriate safeguards in place to ensure independent primary care providers are not disadvantaged in the requirement for a primary care referral.

To read our full comments, click here.

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