On December 19, 2025, CMMI issued a Request for Applications (RFA) for participation in the Advancing Chronic Care with Effective, Scalable Solutions model (ACCESS Model). Announced by CMS earlier this month, the ACCESS Model is a voluntary CMMI model aimed at improving care for Medicare fee-for-service (FFS) beneficiaries with chronic health conditions. Consistent with recent actions by other federal agencies intended to support the digital health field,1 the ACCESS Model is aimed at removing barriers to technology-enabled care solutions.
Payment Barriers to Digital Health
As reflected in the RFA, CMS views digital health as being particularly useful for managing chronic health conditions, but is concerned current payment systems may limit access to technology-enabled care.
For example, FFS payment approaches “cover a limited set of activities and items that are typically poorly aligned with evolving technology-enabled care, which is often continuous and remote.” Moreover, applying an activity-based payment approach to technology-enabled care creates a risk of uncontrolled costs, since, unlike personal services, technology-enabled care is “less supply-constrained.”
Current value-based care models also can present barriers to technology-enabled care. For example, because Accountable Care Organizations (ACOs) and Medicare Advantage (MA) plans “often have significant size and local concentration, they may select a single digital health vendor for a given clinical condition, creating a ‘winner-take-all’ dynamic.” Moreover, “custom contracts increase implementation costs and make vendor comparisons difficult, limiting competition.”
ACCESS Model Overview
To address potential payment barriers to technology-enabled care, the ACCESS Model will test an alternative payment methodology, referred to as “Outcome-Aligned Payments” (OAPs). Under the ACCESS Model, participating providers and suppliers (ACCESS Participants) will receive fixed payments for managing beneficiaries’ qualifying conditions over 12-month periods, with full payment contingent on achieving specified clinical outcomes. According to CMS, this payment model “emphasizes accountability for outcomes rather than specific activities, allowing ACCESS Participants to adapt their care delivery approach to achieve results.”
The ACCESS Model will be a voluntary model offered nationwide and will run for ten years, from July 5, 2026 through June 30, 2036. Participation in the ACCESS Model will occur in “cohorts,” with the goal of ensuring that all ACCESS Participants have the opportunity to participate in the Model for at least two years. The first cohort of ACCESS Participants will begin on July 5, 2026, and subsequent cohorts will begin on January 1, 2027 and quarterly thereafter. Applications to participate in the ACCESS Model will be accepted on a rolling basis from January 12, 2026 through April 1, 2033, with applications for the first cohort due on April 1, 2026.
As with all CMMI models, CMS will evaluate the ACCESS Model for its impact on quality of care and Medicare spending. If the ACCESS Model is found to improve quality without increasing costs — or to reduce costs without harming quality — HHS may consider expanding or making the ACCESS Model permanent through rulemaking.
The following is a summary of key (but certainly not all) features of the ACCESS Model.
Eligible Participants
Participation in the ACCESS model is on an application basis and is limited to Medicare Part B enrolled providers or supplies, excluding DMEPOS suppliers and laboratory suppliers. Applicants that are selected to participate in the ACCESS Model must execute a Participation Agreement with CMS, which Agreement contains various data reporting and compliance commitments.
Each ACCESS Participant must designate a Medicare-enrolled physician as a Medical Director to oversee patient care provided under the ACCESS Model.
Eligible Beneficiaries
Patients who wish to receive care under the ACCESS Model must “align,” or enroll, with an ACCESS Participant directly. Patient eligibility is limited to beneficiaries who have Medicare FFS as their primary payer and have a qualifying chronic health condition.
As discussed below, the ACCESS Model currently includes four clinical tracks, which are focused on common chronic health conditions that affect more than two-thirds of people with Medicare. An eligible beneficiary may only “align” with one ACCESS Participant in a given clinical track at a time. To the extent that an eligible beneficiary participates in multiple clinical tracks, they have the option to “align” with the same or different ACCESS Participants in different tracks.
To promote awareness of the ACCESS Model and to enable patients and providers to make informed choices, CMS will maintain a public-facing directory of ACCESS Participants. The directory will highlight each ACCESS Participant’s clinical tracks, the conditions they treat, and their risk-adjusted outcomes. CMS also will permit ACCESS Participants to engage in direct outreach to potentially eligible beneficiaries, provided they comply with CMS marketing rules.
Qualifying Chronic Health Conditions
The ACCESS Model initially will include the following four clinical tracks focused on common chronic health conditions:
- Early Cardio-Kidney-Metabolic (eCKM): hypertension (high blood pressure), dyslipidemia (abnormal or elevated lipids, including cholesterol), obesity or overweight with marker of central obesity, and prediabetes;
- Cardio-Kidney-Metabolic (CKM): diabetes, chronic kidney disease, or atherosclerotic cardiovascular disease;
- Musculoskeletal (MSK): chronic musculoskeletal pain; and
- Behavioral Health (BH): depression or anxiety.
CMS has indicated that it may consider additional clinical tracks or conditions in the future.
ACCESS Participants will be responsible for managing all qualifying conditions a beneficiary has within the clinical track in which they are enrolled.
To assess ACCESS Participants’ performance, CMS has included condition-specific measures, referred to as “OAP Measures,” in each of the four clinical tracks. For example, for the eCKM track, the OAP Measure for hypertension currently is “control or minimum improvement” in blood pressure (BP). For each OAP Measure, CMS will publish a corresponding “target,” informed by clinical guidelines. Targets will be “defined relative to each beneficiary’s baseline” and will “focus on improvement or control.” For example, under the eCKM track, a potential target for hypertension would be “a 10-mmHg reduction in systolic BP or a final BP below 130/80 mmHg.” As discussed below, patient performance against these Outcome Measure targets affects the total payment amount that an ACCESS Participant may receive.
Payment Methodology
ACCESS Participants will receive a “standard per-patient payment” (i.e., an OAP) for managing all qualifying conditions a beneficiary has within a given clinical track within a 12-month care period. Payment amounts will vary by clinical track and will include two “payment tiers”: (i) a higher payment rate for the beneficiary’s initial 12-month care period, in recognition of the “higher resource needs associated with onboarding, establishing care relationships, and achieving initial clinical improvement” during that initial period, and (ii) a lower payment rate for ensuing 12-month care periods, which is reflective of the “lower resource needs for continued management of beneficiaries already established in care or whose OAP measures are well controlled at baseline.”
Each ACCESS Participant will receive up to 50% of their total OAP amount in quarterly installments. The remaining 50% will be withheld and subject to a semi-annual reconciliation process. Notably, under this reconciliation process, the total OAP amount may be subject to one of two potential downward adjustments, which are designed to “ensure accountability for outcomes and coordinated care delivery.”
One downward adjustment, called the “Clinical Outcome Adjustment,” is based on the clinical outcomes achieved in the ACCESS Participant’s patient panel. For each Model year, CMS will specify a minimum “Outcome Attainment Rate” that must be achieved for an ACCESS Participant to earn full payment. An ACCESS Participant’s Outcome Attainment Rate is the percentage of aligned beneficiaries in their patient panel who completed their 12-month care period and met all required OAP Measure targets. If an Access Participant falls below the minimum Outcome Attainment Rate in a given Model year, their total OAP payment amount will be subject to a downward adjustment in accordance with a formula specified by CMS. In the first Model year, the minimum Outcome Attainment Rate will be 50%.
The second downward adjustment, called the “Substitute Spend Adjustment,” “focuses on reducing duplicative Medicare spending and encouraging comprehensive care delivery.” Each clinical track includes a “Substitute Spend List,” which is a list of “services considered substitutes if provided by another Medicare entity for the same condition.” For each Model year, CMS will specify a minimum “Substitute Spend Rate” that must be achieved for an ACCESS Participant to earn full payment. An ACCESS Participant’s Substitute Spend Rate is the percentage of aligned beneficiaries in their patient panel “who did not receive listed substitute services from other Medicare providers or suppliers for the same condition” during their 12-month care period. If an Access Participant falls below the minimum Substitute Spend Rate in a given Model year, their total OAP payment amount will be subject to a downward adjustment in accordance with a formula specified by CMS. In the first Model year, the minimum Substitute Spend Rate will be 90%.
Data Reporting and Sharing
To implement the payment methodology described above, the ACCESS Model requires regular data reporting to CMS. For each aligned beneficiary, ACCESS Participants will be required to report baseline clinical data and regular follow-up data, to allow CMS to assess whether required Outcome Measure targets were met. ACCESS Participants also will be required to report utilization data and other model-specific metrics.
CMS, in turn, also will share certain data with ACCESS Participants to facilitate care coordination. Specifically, ACCESS Participants will have the opportunity to “request access to certain Medicare claims data” for aligned beneficiaries.
ACCESS Participants also will be required to “support care coordination by making reasonable efforts to identify beneficiaries’ existing care team members”—specifically any PCP and referring clinician, if applicable—and to “share standardized clinical updates at key points in care.”
Co-Management Payments
To “support ongoing care coordination and encourage continued engagement” between referring clinicians and ACCESS Participants, CMS will permit PCPs and referring clinicians to receive a co-management payment for documented review of patient updates provided by ACCESS Participants. The co-management payment will be approximately $30 per service (subject to the geographic adjustment); provided, however, that payment will be limited to once every four months per beneficiary per clinical track, up to approximately $100 per year.
CMS will share the relevant payment code for this co-management service in 2026.
Beneficiary Cost-Sharing
CMS has indicated that it intends to permit ACCESS Participants to waive beneficiary cost-sharing for OAPs pursuant to the AKS safe harbor for CMS-sponsored model patient incentives. ACCESS Participants must apply their cost-sharing policy uniformly to all beneficiaries. If an ACCESS Participant chooses to collect beneficiary cost-sharing for OAPs, they must clearly disclose the expected beneficiary payment amount before beneficiary alignment (i.e., enrollment).
Clinicians who perform co-management services under the ACCESS Model may not collect any cost-sharing amount from beneficiaries for that service.
Potential Impacts of the ACCESS Model
Although the ACCESS Model is limited to Medicare FFS, it is clear that CMS hopes that OAPs may be adopted more broadly to encourage increased use of technology-enabled care. For example, in an FAQ, CMS clarified that MA organizations may independently adopt similar outcome-aligned payment arrangements with their contracted providers without the need for a waiver. Furthermore, CMS is encouraging cross-payer alignment with the ACCESS Model by making payer implementation resources, including reference provider agreements, source code, and technical documentation, available to help payers optionally align their contracting and performance models with the ACCESS Model.2
The ACCESS Model appears well-positioned to expand access to technology-enabled care, for the Medicare FFS population and potentially more broadly. Provided that ACCESS Participants make appropriate investments in digital health contracting, infrastructure, and collaboration, the ACCESS Model should translate to better integration of technology into care delivery across all patient populations.
- On December 5, 2025, the FDA announced a Technology-Enabled Meaningful Patient Outcomes (TEMPO) for Digital Health Devices pilot, which is intended to promote access to certain digital health technologies in connection with the CMS Access Model. Under the TEMPO pilot, manufacturers of certain digital health devices may request that the agency exercise its discretion not to enforce certain applicable FDA requirements, such as FDA premarket authorization requirements, when their device is offered to or by ACCESS Model participants for an intended use to improve patient outcomes, in connection with care expected to be covered by the ACCESS Model. The FDA has expressed an expectation that manufacturers participating in the TEMPO pilot will collect real-world data relating to the performance of their digital health devices, share the data with the FDA during the TEMPO pilot, and eventually use that data to seek appropriate marketing authorization from the FDA. ↩︎
- The agency is also encouraging collaboration with a broad range of players in the health care ecosystem, allowing clinical and patient societies and payers and health plans (among others) to sign up for updates in the Model Interest Form. ↩︎
