Comment on CMS-2026-1256-0002

Summary: Optum (SCA Health) supports the proposal to allow physician-owned hospitals (POHs) to voluntarily opt into the Transforming Episode Accountability Model (TEAM). They argue that this inclusion should be broad rather than limited to grandfathered facilities and should include waivers for ACA Section 6001 capacity restrictions to ensure the model can accurately evaluate diverse provider types.