This week, ASA submitted comments to the Centers for Medicare and Medicaid Services (CMS) on its FY 2026 Hospital Inpatient Prospective Payment System (IPPS) proposed rule. The rule included several policy proposals, including proposals for digital quality measures, new hospital quality measure development, and Alternative Payment Models (APMs).
ASA’s comments largely centered on CMS’s Transforming Episode Accountability Model (TEAM), set to become mandatory on January 1, 2026. Although the model is focused on a limited number of facilities, the appropriate implementation of TEAM in those facilities could highlight the essential role anesthesiologists have in improving care and patient satisfaction while reducing costs. In previous models, hospitals have relied upon anesthesiologists to implement core features of perioperative care, lead enhanced recovery models, and better coordinate patient care postoperatively. Those physician-led efforts have saved hospitals and our health system millions of dollars, reduced lengths of stay, and increased patient satisfaction.
ASA reiterated its opposition of CMS imposing immediate TEAM participation and requested that CMS better define an on-ramp for anesthesiologists and their groups to participate in TEAM. ASA’s comments explained that anesthesiologists are often excluded from financial attribution lists for alternative payment models, despite their contributions to patient-centered care, improved care coordination, and cost reduction. While CMS develops improved pathways for anesthesiologists to participate in and receive financial compensation in these models, ASA recommended CMS institute several years of voluntary or tiered participation in TEAM.
ASA’s letter also asked CMS to work closely with facilities and health systems to evaluate their readiness for a transition to digital quality measurement. On the Hospital Inpatient Quality Reporting Program, ASA welcomed the opportunity to work with CMS on perioperative nutrition measures and encouraged the agency to consider measures of patient and caregiver well-being withing the framework of a surgical episode.
Click here to read ASA’s comment letter.
Please contact the ASA Department of Quality and Regulatory Affairs at [email protected] with any questions.
Date of last update: June 11, 2025