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The AHA expressed concerns June 10 to the Centers for Medicare & Medicaid Services about its proposed Transforming Episode Accountability Model (TEAM), saying it "is proposing to mandate a model that has significant design flaws, and as proposed, places too much risk on providers with too little opportunity for reward in the form of shared savings, especially considering the significant upfront investments required." The proposed mandatory payment model would bundle payment to acute care hospitals for five types of surgical episodes, which comprise over 11% of inpatient prospective payment system payments (not including outpatient payments that would also be at risk in the model). The association urged CMS to make model participation voluntary, reduce the discount factor from 3% to no more than 1%, and make several significant changes to design elements, otherwise CMS should not implement the model. “If CMS cannot make extensive changes to the model, it should not implement it at this time,” AHA wrote. “To do so would make TEAM no more than a thinly disguised payment cut, as it fails to provide hospitals a fair opportunity to achieve enough savings to garner a reconciliation payment.”