Background on the CMMI ACCESS model

The Advancing Chronic Care with Effective, Scalable Solutions (ACCESS) model, launched by the Center for Medicare & Medicaid Innovation (CMMI), is a new payment framework providing outcome-aligned payments (OAPs) for managing specific types of chronic care in the Medicare fee-for-service (FFS) population.

The model will operate nationally as a decade-long voluntary program, with applications due by April 1, 2026 (applications will continue to be accepted on a rolling basis through 2033) and the first performance period beginning July 1, 2026. Participants will be able to participate under up to four clinical tracks: early cardio–kidney–metabolic (eCKM), CKM, musculoskeletal (MSK), and behavioral health (BH). CMMI has stated that more tracks/conditions may be added in future years.

The ACCESS model aims to improve health outcomes for Medicare FFS beneficiaries living with chronic conditions by expanding access to new technology-enabled care options that deliver measurable improvements in patient health.¹ The program is particularly focused on digital technologies, including telehealth software, wearable health tracking devices, and coaching apps that support people through behavioral and physical lifestyle changes, as these services can have meaningful impacts, especially with beneficiaries living in rural areas or areas with limited care options. According to the Centers for Medicare and Medicaid Services (CMS), this program also attempts to address Medicare FFS’s historical lack of a payment option that adequately reimburses novel technology-support care.

One of the ACCESS model’s most innovative features is that Medicare beneficiaries will select the ACCESS participant responsible for their care (versus being assigned as with Accountable Care Organizations [ACOs]). The model will include a Participant Directory that will highlight each participating organization’s tracks and risk-adjusted outcomes, which can be reviewed by beneficiaries and/or providers/physicians/ACOs when making decisions relating to various ACCESS participants. This directory has the potential to become a screening tool for beneficiaries and for health systems/ACOs looking to add ACCESS participants to their network. (More on this below.)

Additionally, the model is available for a wide range of participants; physician practices, digital health platforms, home-based care providers, and community-supported organizations can all apply. This inclusivity is intended to foster new partnerships and broaden the reach of chronic care interventions, especially in rural and underserved communities.²

Details on the CMMI ACCESS model: Payment systems and participation criteria

What are different payment mechanisms under the CMMI ACCESS model?

Two-tiered payment

Rather than being paid for the volume of services delivered, organizations will receive OAPs tied to improvements in patients’ clinical outcomes, such as controlled blood pressure, improved kidney function, reduced pain, or improved depression scores.³ Figure 1 summarizes the annual payment amounts⁴ for each clinical track, designed to “reflect expected resource needs to provide integrated care for each clinical track.”

There are two payment tiers:

1. Initial period (12 months): The initial period payment recognizes the “higher resource needs associated with onboarding, establishing care relationships, and achieving initial clinical improvement.”⁵ To receive “initial period” payment for a beneficiary, that beneficiary must have at least one required OAP measure not at target.
2. Follow-on period: These payments are lower, reflecting “lower resource needs for continued management of beneficiaries already established in care or whose OAP measures are well controlled at baseline.” That is, if a new beneficiary’s OAP measures are all already at or better than the target, the ACCESS participant will receive the follow-on period payments. (Note: There are no follow-on period payments for beneficiaries in the MSK track.)

Note that if a beneficiary is aligned to multiple tracks with the same ACCESS participant, the OAP payment for the lowest cost track will be reduced by 5%.

Payment adjustments

There are two adjustments to the above payments, both of which may result in a payment reduction. The larger of the two payment adjustments is applied during each semi-annual payment reconciliation.

1. Clinical Outcome Adjustment
• This adjustment measures the proportion of an ACCESS participant’s panel that met the OAP targets or improved by a specified threshold.
1. In the first year, if at least 50% of a participant’s panel met the target, full payment is received. This threshold may be adjusted in future years.
2. If less than 50%, the proportion of the participant’s panel that did meet the target is divided by 50% to produce an adjustment factor. This is subject to a 0.50 floor on the adjustment factor.
• For example, if 30% of all aligned beneficiaries met the targets, the participant would receive 30 / 50 = 60% of the full OAP amount.
2. Substitute Spend Adjustment
• This adjustment is intended to “minimize avoidable duplicative services” reasonably within the ACCESS participant’s control (e.g., initiation of new care for a diagnosis already being treated, such as a new physical therapy evaluation for a beneficiary with a previously identified MSK issue).
• Each track has a list of specific substitute services, and the substitute spend rate (SSR) is the proportion of aligned beneficiaries who did not receive any of the track-specific substitute services (i.e., higher is better).
1. If the SSR is at least 90%, full payment is received.
2. If the SSR is below 90%, the calculation works the same as the Clinical Outcome Adjustment, where the actual observed proportion divided by 90% becomes the adjustment factor (subject to a 0.25 adjustment factor floor).

Co-management payment

Since ACCESS is intended to complement traditional care, primary care providers and other referring clinicians will also be able to bill for a new $30 co-management payment⁶ for documented review of patient updates and care coordination with ACCESS program related services no more than once every four months per beneficiary per track. This payment will not be eligible for beneficiary cost-sharing but is expected to be included in CMS/CMMI ACO models.

Who can participate in the CMMI ACCESS model?

To be eligible, ACCESS participants must demonstrate readiness in several key areas: screening for health-related social needs (HRSNs), establishing referral pathways to community resources, and collecting and reporting data on both clinical and social outcomes. Participating organizations must also be enrolled in Medicare Part B as providers or suppliers (excluding durable medical equipment and laboratory suppliers) and must appoint a Medicare-enrolled Clinical Director or Medical Director to oversee care quality and compliance with the program. CMS will provide infrastructure funding to support technology adoption, care coordination, and data sharing, ensuring that organizations can build the necessary systems to succeed under the model.¹

Program overlap

The ACCESS model will not qualify as an advanced alternative payment model (AAPM). Instead, it is meant to complement existing models. Beneficiaries may be aligned to an ACCESS participant and a provider participating in another model, such as the Medicare Shared Savings Program (MSSP), ACO Realizing Equity, Access, and Community Health (REACH), or Long-term Enhanced ACO Design (LEAD). ACCESS-specific costs (which will be billed via new G-codes) will count toward ACOs’ total expenditures for purposes of financial reconciliation. However, “CMS is evaluating a temporary exclusion of ACCESS spending from ACO financial benchmarks and reconciliation during the first year of the ACCESS model, before incorporating related spending into total cost of care calculations in later years.”⁷

ACCESS model considerations for health systems, life sciences companies, and other stakeholders

Although the ACCESS model is an exciting next step in CMMI’s continued evolution of Medicare FFS payment policy, a number of key stakeholders need to plan and strategize to ensure they are well-positioned to make the most of this opportunity. Below are some key questions that various stakeholders should ask themselves as they consider how the ACCESS model might impact their organization.

Health systems/ACOs

How will my organization benefit from the ACCESS model?

For health systems, the ACCESS model represents an opportunity to introduce new care management tools to more effectively manage the care of beneficiaries your providers are treating. This could represent a financial opportunity for any risk-based arrangements a health system is participating in, and ensure that providers are focusing a larger portion of their time on essential, non-avoidable care. Note that if a health system is considering applying for the ACCESS model as a participant, CMMI is not allowing ACCESS participants to submit Medicare FFS claims (directly or indirectly) for aligned beneficiaries during active care periods.

For Medicare ACOs (participating in MSSP, ACO REACH, or LEAD), the ACCESS model represents an opportunity to more efficiently manage the costs of the ACO’s attributed beneficiaries and increase care coordination across providers both inside and outside of the ACO.

What are the potential risks and opportunities?

• Data collection: The ACCESS model framework envisions a comprehensive CMS-run marketplace where health systems and ACOs can identify highly effective ACCESS participants they may want to partner with and direct their beneficiaries towards to more effectively manage their care. However, if the data collection process and presentation are incomplete or difficult to interpret, it may be challenging for entities trying to identify effective ACCESS participants.


• Costs/benchmark impact: From an ACO perspective, the costs associated with the ACCESS model payments (both co-management fees and OAPs) represent a risk insofar as they are not offset by reduced utilization and expenditures from those beneficiaries. However, in a mature ACCESS marketplace, where comprehensive, credible data is available, ACOs would be incentivized to steer their beneficiaries to cost-effective ACCESS participants.
  
  The potential exclusion of OAP payments from the expenditures in the first year of ACCESS is something that ACOs will want to consider. Although this will reduce the risk in year one, these costs are likely to be included in subsequent years, so ACOs will need to refine their strategies quickly to avoid the potential erosion of savings from use of ineffective ACCESS participants by attributed beneficiaries. ACOs should also consider the impact of these additional costs on their benchmark (e.g., when rebasing in MSSP).

How can a health system or ACO make the most of this program?

For a health system or ACO, having an open line of communication and trust with ACCESS participants helping manage care for your beneficiaries is key to ensuring the model’s implementation improves (rather than hinders) effective care delivery and coordination for your population. Health systems or ACOs can also consider partnering with ACCESS participants (or participating themselves) to ensure that care is appropriately coordinated.

Additionally, the potential exclusion of OAP payments from MSSP/REACH/LEAD expenditures in year one means this year will be pivotal for health systems and ACOs to focus on to ensure they have a concrete strategy to manage ACCESS participation within their populations (without large adverse impacts on shared savings performance).

What is still unknown?

CMS has yet to clarify whether OAP payments will count towards ACO expenditures in Year 1.

Life sciences/health technology solutions

How do I know if I qualify to participate in the ACCESS model?

To participate directly in the ACCESS model, an organization must apply under a single Medicare Part B-enrolled taxpayer identification number (TIN). CMS requires ACCESS participants to be able to bill Medicare Part B. The Medicare Part B enrollment process is described on the CMS website: https://www.cms.gov/medicare/enrollment-renewal/providers-suppliers.

Organizations do not qualify to participate directly in the ACCESS model if they are:

• Purely technology or analytics vendors without an associated clinical entity
• Manufacturers or distributors that only sell devices, software, or diagnostics
• Entities that are otherwise unable to enroll as a Medicare Part B provider or supplier
• Organizations that cannot assume responsibility for care coordination, beneficiary engagement, and CMS reporting requirements

Importantly, CMS designed the ACCESS model around clinically accountable care delivery, not around standalone products or tools. As a result, many health tech and life sciences companies will not meet the eligibility requirements for direct participation, even if their solutions are highly relevant to the model’s goals.

Health tech and life sciences companies are therefore typically faced with a strategic choice:

• Participate directly by operating or acquiring a Part B-billing clinical entity and assuming accountability for care delivery and performance, or
• Partner with an ACCESS participant, supporting model success through technology, data, care management capabilities, or clinical programs while the participant organization retains contractual and regulatory responsibility with CMS

For most organizations, partnership is not a limitation of the ACCESS model but rather a reflection of how CMS intends innovation, care delivery, and accountability to work together under a value-based structure.

Note that participation in the ACCESS model does not change any existing legal or regulatory requirements that organizations would normally have needed to satisfy. Participants must still obey all applicable federal and state laws and regulatory requirements, meet HIPAA obligations as a covered entity, and address any FDA requirements for their interventions that qualify as medical devices under section 201(h)(1) of the Federal Food, Drug, and Cosmetic Act.⁸

How does billing work?

CMS plans to pay participating organizations their OAP payments through beneficiary-level payments corresponding with the use of specific G-codes for aligned beneficiaries. These OAP payments will be equal to one-twelfth of the Medicare portion of the annual OAP allowed amount for the beneficiary’s clinical track and will be provided monthly for the first 6 months of the care period. The remaining annual OAP payment (months 7–12) will not be paid until reconciliation as part of the final settlement process. Additionally, there is no beneficiary cost sharing for these G-codes (or those associated with co-management payments), as they are used primarily to allow CMS to track whether beneficiaries are actively receiving services from ACCESS participants. Participants can elect not to collect any beneficiary cost sharing in relation to the OAP payments for those aligned with the model, but they must do so uniformly across all aligned beneficiaries.

It will be important to evaluate the OAP payments (summarized above) against your organization’s expected costs to understand whether the model could be a good fit (as well as what the conditions for success/failure might be).

What’s in it for my organization?

The ACCESS model could provide a structured pathway to embed solutions into a CMS-sponsored value-based care model with defined payment, accountability, and scale. The model also affords the opportunity to generate real-world evidence tied to outcomes, which could inform future coverage, contracting, and product development strategies.

How do I maximize engagement with my program or technology?

Beneficiaries with FFS Medicare and one of the chronic conditions in the ACCESS model’s clinical tracks can enroll with a participating ACCESS organization directly or via referral from their healthcare providers. There is no limit on the number of clinical tracks beneficiaries may enroll in if they qualify, but only one ACCESS participant may provide services for a given track to each beneficiary during an enrollment period. Participating organizations can freely publicize their services among Medicare beneficiaries and referring providers to increase engagement.

CMS also plans to launch an ACCESS Participant Directory. This directory will host listings from participating vendors that include information about their services, as well as optional software and hardware tools that support member participation or compliance with their services. CMS has said these listings may contain optional promotional offers, including product discounts or service credits. Although it is not yet clear what the Tools Directory user experience will look like, participating organizations should consider how they wish to present their offerings to maximize enrollment.

Organizations participating in ACCESS may also wish to focus on methods to maximize their care coordination efforts once beneficiaries enroll to increase engagement with their interventions. The ACCESS model requires participating ACCESS organizations make a good faith effort to identify and proactively reach out to beneficiaries’ existing care teams, especially their primary care or referring clinicians, to share information about clinical progress. Although CMS does plan to supply some information about Medicare providers or suppliers associated with enrolled beneficiaries, participating organizations will also rely on the beneficiaries themselves to report this information during enrollment. Focusing on streamlining these care coordination efforts may incentivize greater referral rates from providers and may support better clinical outcomes for enrolled beneficiaries in the long run.

What are the potential risks and opportunities?

Participation in the ACCESS model has the potential to drive significant new enrollment in participating organizations’ interventions. This is a potential boon for organizations looking to expand and build an evidence base for their intervention.

ACCESS participation could also provide a pathway to Medicare coverage for some interventions. One of the ACCESS model’s stated goals is to allow CMS to gather data on the efficacy of technology-supported chronic care solutions not currently reimbursed by Medicare. Although it is not yet clear how CMS will use the data gathered from the ACCESS model to determine future coverage and reimbursement for interventions, participating in the program and successfully demonstrating clinical improvement could present a clearer path to future Medicare reimbursement.

Notably, at least 14 major health plans have pledged to follow CMS’s suit and adopt an outcomes-based payment structure aligned with the core principles of the ACCESS model.⁹ CMS is planning to provide “optional alignment resources” for these plans, including sample agreement structures and payment adjustment codes, standardized billing codes, and a reporting infrastructure, which will allow payers to drive providers to submit their performance data through a CMS-hosted interface and receive their payment determination results. This suggests that even organizations that choose not to participate in ACCESS formally may find that to continue to engage with commercial and MA payers, they may be pushed to align with ACCESS reimbursement structures in the near future.

It is important to note that participating organizations’ results will be shared transparently in CMS’s Participant Directory, so performance, positive or negative, will be public. Participating organizations should understand which measures will be assessed according to the clinical tracks and, based on the organizations’ various interventions, carefully consider whether participation in ACCESS is likely to consistently demonstrate positive results on those specific measures.

Does this program interact with the new MAHA-ELEVATE program?

The Make America Healthy Again: Enhancing Lifestyle and Evaluating Value-based Approaches Through Evidence (MAHA-ELEVATE) model is CMMI’s targeted initiative to bring functional and lifestyle medicine interventions to the Medicare FFS population. MAHA-ELEVATE seeks to address the lifestyle and behavioral choices of Medicare FFS beneficiaries that may be contributing to their chronic diseases by promoting approaches to care that emphasize whole-person functional or lifestyle medicine.¹⁰

To do this, MAHA-ELEVATE will provide approximately $100 million in funding to organizations that provide whole-person functional or lifestyle medicine services directly to patients or through partnerships for three-year cooperative agreements. Up to 30 proposals will be selected, each aimed at promoting health and prevention among Medicare FFS beneficiaries. These proposals must utilize evidence-based, whole-person care approaches, including functional or lifestyle medicine interventions not currently covered by Medicare FFS. These approaches to care are meant to encourage chronic disease prevention and wellness and must focus on whole-person care, including nutrition, physical activity, sleep, stress management, harmful substance avoidance, and social connection. The intent is to support, not replace, traditional medical care for people with Medicare.

Although both the ACCESS and MAHA-ELEVATE models aim to test new health interventions and gather data on their efficacy, they do not interact. Interventions that receive grants under the MAHA-ELEVATE model can target and treat conditions that sit outside the four main clinical tracks defined under the ACCESS model, and the grants are meant to fund delivery of care services as well as administration and data collection.

In summary: How the CMMI ACCESS model affects chronic care management under Medicare

CMMI’s ACCESS model introduces a new financial framework for chronic care management under Medicare, presenting both opportunities and challenges for participating organizations. Although the model offers the potential for OAPs and greater integration of technology-enabled care, it also introduces new requirements around data reporting, care coordination, and public performance transparency. For ACOs and health systems, it will be essential to be aware of how ACCESS participants are interacting with beneficiaries with diseases/conditions they are being treated or at-risk for. For potential ACCESS applicants, it will be essential for them to evaluate the OAP payment amounts against expected costs to determine whether the financials of the model could be a good fit for their organizations.

¹ Centers for Medicare & Medicaid Services. (2026, February 12). ACCESS (Advancing Chronic Care with Effective, Scalable Solutions) Model. Retrieved February 24, 2026, from https://www.cms.gov/priorities/innovation/innovation-models/access.

² Radovic, N., Downing, S. P., Greis, J. S., & Cilek, J. A. CMS announces new ACCESS model, advancing a national outcomes-based framework for chronic care, health equity and community integration. Benesch. Retrieved February 24, 2026, from https://www.beneschlaw.com/insight/cms-announces-new-access-model-advancing-a-national-outcomes-based-framework-for-chronic-care-health-equity-and-community-integration/.

³ Coral Health Advisors. (n.d.). CMMI launches new technology-supported chronic care model: What you need to know about ACCESS. Retrieved February 24, 2026, from https://www.coralhealthadvisors.com/blog/cmmi-launches-new-technology-supported-chronic-care-model-what-you-need-to-know-about-access.

⁴ Center for Medicare & Medicaid Innovation. (n.d.). Advancing Chronic Care with Effective, Scalable Solutions (ACCESS) model: Model payment amounts and performance targets. Centers for Medicare & Medicaid Services. Retrieved February 24, 2026, from https://www.cms.gov/priorities/innovation/files/access-payments-amts-perf-targets.pdf.

⁵ Center for Medicare & Medicaid Innovation. (2026, February 12). Advancing Chronic Care with Effective, Scalable Solutions (ACCESS) model: Request for applications. Centers for Medicare & Medicaid Services. Retrieved February 24, 2026, from https://www.cms.gov/priorities/innovation/files/access-rfa.pdf.

⁶ Subject to geographic adjustment, sequestration, etc.

⁷ Center for Medicare & Medicaid Innovation. (2026, February 12). Advancing Chronic Care with Effective, Scalable Solutions (ACCESS) model: Request for applications. Centers for Medicare & Medicaid Services. Retrieved February 24, 2026, from https://www.cms.gov/priorities/innovation/files/access-rfa.pdf.

⁸ Food and Drug Administration. (2021, September). Classification of products as drugs and devices & additional product classification issues: Guidance for industry and FDA staff. Department of Health and Human Services. Retrieved February 24, 2026, from https://www.fda.gov/media/80384/download.

⁹ Centers for Medicare & Medicaid Services. (2026, February 12). Major health plans join ACCESS payer pledge. Retrieved February 20, 2026, from https://www.cms.gov/priorities/innovation/major-health-plans-join-access-payer-pledge .

¹⁰ Centers for Medicare & Medicaid Services. (2025, December 11). MAHA ELEVATE (Make America Healthy Again: Enhancing Lifestyle and Evaluating Value-based Approaches Through Evidence) model. Retrieved February 24, 2026, from https://www.cms.gov/priorities/innovation/innovation-models/maha-elevate .