10/16/2025

CMS Issues Updated TEAM Guidance, Clarifies SNF 3-day Stay Waiver

Amid ongoing budget uncertainty, the Centers for Medicare & Medicaid Services (CMS) has also released updated guidance on the Transforming Episode Accountability Model (TEAM)—the new mandatory bundled payment program launching January 1, 2026. The update clarifies how participating hospitals may use a waiver from the Skilled Nursing Facility (SNF) 3-day stay requirement for certain surgical procedures.

The waiver applies only to Medicare fee-for-service beneficiaries who undergo one of five covered procedures—lower extremity joint replacements, surgical hip fracture repair, spinal fusion, coronary artery bypass graft, or major bowel surgery—at a participating hospital. Hospitals may use, but are not required to use, the waiver to admit patients directly to a qualified SNF within 30 days of discharge. To qualify, SNFs must have held a 3-star or higher rating for at least seven of the past 12 months; swing bed providers are exempt from that threshold.

Hospitals in designated core-based statistical areas are required to participate in TEAM, while others may opt in—particularly those involved in the ending Bundled Payments for Care Improvement–Advanced (BPCI-A) or Comprehensive Joint Replacement (CJR) models.

Members are encouraged to review the full TEAM guidance summary from LeadingAge for procedural codes, implementation timelines, and other billing considerations.