CMS holds a TEAM hospital to account for spending over target in a surgery only if it had at least 31 episodes in the three-year baseline.

31

baseline episodes: TEAM's low-volume threshold

CMS holds a TEAM hospital to account for spending over target in a surgery only if it had at least 31 episodes in the three-year baseline.

Below that threshold, CMS still runs its year-end comparison of those episodes against the target, but it does not make the hospital repay spending above the target.

Source: TEAM Model Overview slides (updated September 2026) (opens in a new tab), Slide 32, Reconciliation Process. Verified October 2026.

KentAppliedkentapplied.com/facts/team-low-volume-threshold-31-episodes

Related charts

Sources for the figures above: 42 CFR 512.550, Reconciliation process and determination of the reconciliation payment or repayment amount (opens in a new tab); Rate of initial denials of medical insurance claims continued to rise in 2024, Kodiak Solutions proprietary data show (opens in a new tab).

Related facts

Sources for the figures above: Transforming Episode Accountability Model (TEAM) model page (opens in a new tab); 42 CFR 512.550, Reconciliation process and determination of the reconciliation payment or repayment amount (opens in a new tab).

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