Comment on CMS-2026-1256-0002

Summary: The American Podiatric Medical Association (APMA) expresses significant concerns regarding the mandatory nature and two-sided risk of the Transforming Episode Accountability Model (TEAM), arguing it may create perverse incentives to avoid high-risk patients. The organization specifically opposes expanding episode-based accountability to ambulatory surgical centers (ASCs) unless CMS can demonstrate that such an expansion preserves patient access and appropriately accounts for patient complexity.