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TEAM Bundles and SNFs’ Eligibility for 3-Day Stay Waiver
The Medicare Learning Network has published detailed guidance on how hospitals participating in the new bundled payment model called Transforming Episode Accountability Model (TEAM) can use a waiver from the Skilled Nursing Facility (SNF) 3-day stay requirements.
First, a little background on TEAM. The TEAM is the new bundled payment program that begins January 1, 2026. Hospitals in designated core-based statistical areas (CBSAs) are mandated participants, but hospitals outside of the required CBSAs, can opt in to participate. This optional participation is most likely in cases where hospitals participated in previous bundled payment models like the Bundled Payment for Care Improvement – Advanced model (BPCI-A), which is scheduled to end December 31, 2025, or the Comprehensive Joint Replacement model (CJR), which ended in 2024. And only Medicare FFS beneficiaries can be covered under TEAM. TEAM only applies to the following procedures and therefore the 3-day stay waiver could only apply for these situations not all hospitalizations: Lower extremity joint replacements, surgical hip femur fracture treatment, spinal fusion, Coronary artery bypass graft and major bowel procedure. As for the MLN memo, here is what is important to know:
- Hospitals are permitted but not required to use the 3-day stay waiver they have been given under the model
- If they opt to use the waiver, it only applies to patients eligible to be covered by TEAM and the admission must be within 30 days of the discharge.
- The waiver can only be used for “qualified SNFs” which is defined as a SNF that has had a 3-star or higher rating for at least 7 of the last 12 months (see p. 5 of the memo). Swing beds providing SNF services are exempt from the 3-star or higher rating requirement.
- Qualifying SNFs must include the proper code for a TEAM waiver to be eligible.
Members are encourage to review all the details in the MLN memo to determine its impact on their SNF.
Update on Medicare Claims Processing During Shutdown
Per a Medicare Learning Network (MLN) newsletter sent on October 1, 2025, the Centers for Medicare and Medicaid Service (CMS) clarified the impact of the legislative shutdown on Medicare payment processing. In the newsletter, Medicare Administrative Contractors (MAC) were directed to put a temporary hold on claims. This pause may prevent both the MACs and providers from incurring additional burden and cost associated with a need to reprocess claims denied due to the expiration of the telehealth and hospital at home waivers and similar items in the event that those services are ultimately extended by Congress as part of a continuing budget resolution or other action. The hold is only expected to last 10 business days, or until October 14, 2025. There is a statutory minimum payment floor of 14 days – meaning MACs hold electronic claims for 14 days before releasing payment regardless of the situation.
New LeadingAge Resource: “Medicare Open Enrollment 2026: What You Need to Know.”
The annual Medicare Open Enrollment period begins October 15 and ends December 7. It is the time of year when Medicare eligible beneficiaries make decisions about how to receive their Medicare benefits, including selecting a Medicare Advantage (MA)plan. As in years past, we’ve compiled an updated resource to help members educate their staff, residents, clients and their caregivers about this process and beneficiaries’ options.
This resource can help LeadingAge members connect those they serve with unbiased resources to evaluate their options, help their staff answer questions from and share unbiased resources with the older adults and their families. It also offers some ideas about questions a beneficiary should ask in evaluating their options, and outlines which actions they must take during open enrollment (e.g., Part D coverage). We also explain the ways providers can assist beneficiaries under MA regulations, including sharing which MA plans they contract with and their merits.
This year, this information is even more important as millions of Medicare beneficiaries enrolled in MA plans have received notices that their current plan will no longer be offered in 2026. This means they must make a new choice – return to traditional Medicare fee-for-service or enroll in a new plan. For this special group of individuals who are losing their coverage, if they return to Medicare FFS, they will also be eligible for certain guaranteed issue Medicare Supplemental Insurance plan coverage (sometimes called Medigap) for their Medicare cost sharing. Guaranteed issue means the plans cannot deny the person coverage or charge higher premiums if the person has a pre-existing condition, but this is a limited opportunity.
Check out this year’s Medicare Open Enrollment resource.
