Bundled Payment Models

CMS is moving bundled payments toward larger mandatory, episode-based models under the Trump administration, with stakeholder focus converging on TEAM and the proposed CJR-X expansion as hospitals warn that chronic inpatient underpayment, downside-risk exposure, and quality-measure design could undermine participation and care redesign. Provider groups including Premier, AHA, NAACOS, and HCTTF are positioning for technical changes—risk adjustment, stop-loss protections, benchmarking, overlap rules with ACOs, and more actionable quality metrics—while technology and specialty stakeholders are treating TEAM and emerging cardiac bundles as signals that longitudinal data infrastructure and physician alignment will be table stakes for VBC success. The strategic tension is clear: CMS is using mandatory bundles to accelerate episode accountability, but hospitals and ACOs are pressing for model design that does not penalize high-acuity providers or conflict with broader population-based arrangements like MSSP ACOs (Premier comments; HCTTF comments).