Recently
updated guidance from the Medicare Learning Network (MLN) on implementation of the Transforming Episode Accountability Model (TEAM) includes details on how hospitals participating in the bundled payment model can use a waiver from the Skilled Nursing Facility (SNF) 3-day stay requirements.
What is TEAM? The TEAM is the new mandatory bundled payment program that begins January 1, 2026.
Which hospitals are covered? Hospitals in designated core-based statistical areas (CBSAs) are mandated participants, but hospitals outside of the required CBSAs, can opt in to participate. This optional participation is most likely in cases where hospitals participated in previous bundled payment models like the Bundled Payment for Care Improvement – Advanced model (BPCI-A), which is scheduled to end December 31, 2025, or the Comprehensive Joint Replacement model (CJR), which ended in 2024.
Which Medicare beneficiaries are covered under TEAM? The TEAM only applies to Medicare fee for service (FFS) beneficiaries who receive care from a participating hospital for one of the following surgical procedures:
- Lower extremity joint replacements,
- Surgical hip femur fracture treatment,
- Spinal fusion,
- Coronary artery bypass graft, and
- Major bowel procedure .
Medicare Advantage (MA) enrollees are not eligible to be covered by TEAM.
Therefore, the 3-day stay waiver only applies to a limited set of Medicare FFS beneficiaries for the five qualifying surgical procedures and not all surgeries nor hospitalizations.
How does the TEAM 3-Day Stay Waiver Work? Here is what is important to know:
- Hospitals are permitted, but not required, to use the TEAM 3-day stay waiver.
- Hospitals can only use the waiver for Medicare FFS patients that receive one of the five surgical procedures covered by TEAM, and the SNF admission must occur within 30 days of discharge from the outpatient department or inpatient hospital.
- The waiver can only be used for “qualified SNFs,” which is defined as a SNF that has had a 3-star or higher rating for at least 7 of the last 12 months (see p. 5 of the memo). Swing beds providing SNF services are exempt from the 3-star or higher rating requirement.
- TEAM specific codes must be used when billing to be eligible for payment.
Members are encouraged to review all the details in the MLN
memo to determine its impact on their SNF.
Budget Reconciliation 2025
