ACCESS Unlocked: CMS’s Bold New Model for Tech-Enable Chronic Care Management

Summary

The Centers for Medicare and Medicaid Services (CMS) has leaned into technology-supported care for certain chronic conditions in its recently unveiled Advancing Chronic Care with Effective, Scalable Solutions (ACCESS) Model, a ten-year national voluntary demonstration that incorporates Outcome-Aligned Payments (OAPs) to Medicare Part B reimbursement for chronic condition management. Under ACCESS, participating organizations (defined below) receive recurring OAPs for helping manage qualifying chronic conditions, with additional payments for hitting specified outcome measures across the enrolled population. The amount to be paid to the participating organization has not yet been released.

Unlike most other care management models paid for by CMS, beneficiaries can enroll directly into the model or be referred by a provider.

CMS will evaluate the model’s impact on health outcomes, patient choice and total Medicare spending to assess whether to expand the model or make it permanent. The first cohort of ACCESS Model participants is slated to begin July 1, 2026, with applications beginning to be accepted January 1, 2026.

ACCESS Model Overview

Participants and Eligibility

To be eligible to participate in the model, organizations must be Medicare Part B–enrolled providers or suppliers (hereafter, providers), be in full compliance with federal and state licensure and privacy requirements and must have a designated physician Clinical Director accountable for quality, safety and oversight. Participating organizations may operate in one or multiple tracks and are responsible for managing all qualifying conditions within the selected track(s).

Part B-enrolled providers will be able to participate in the model directly. Interested health tech companies—many of which are not currently Part-B enrolled providers—will either need to enroll in Medicare (and meet the other requirements noted above) or contract with a Part B-enrolled provider that is an ACCESS participating organization to deliver services through an arrangement with that organization.

To help enrolled providers find potential software, CMS will launch an ACCESS Tools Directory for participants aimed at helping organizations identify optional software and hardware tools that may support model participation and compliance, such as data exchange and interoperability solutions, optional connected clinical devices like blood pressure cuffs and Health Insurance Portability and Accountability Act (HIPAA) compliance support tools.

Vendors listed in the directory may also choose to include optional promotional offers—such as product discounts or service credits—for ACCESS participants as long as they comply with all applicable federal and state laws, including those governing beneficiary inducement.

CMS seems to anticipate that there may be new organizations enrolling in Medicare to participate in ACCESS as it provides some guidance on how to enroll and maintain enrollment compliance in the released documents. Technology companies looking to enroll should understand the full impact of Medicare enrollment and participation on their other service offerings and financial model as they will no longer be permitted to bill Medicare beneficiaries privately and must accept Medicare payment as payment in full (no balance billing) for covered services they offer.

Beneficiary Enrollment

To be enrolled in the model, individuals with Original Medicare can either:

• Enroll directly with an ACCESS participant; or
• Be referred by a primary care provider (PCP) or another clinician.

CMS will maintain a public directory listing each ACCESS participant’s tracks, tools and risk-adjusted clinical outcomes to promote transparency and informed patient choice. A subset of individuals may be assigned to a control group for evaluation, as the Center for Medicare and Medicaid Innovation (CMMI) is statutorily required to evaluate the impact of each of its models. Medicare Advantage (MA) beneficiaries are excluded from enrollment in the model (although CMS notes that MA plans have the flexibility to offer similar programs).

Beneficiaries may participate in more than one track (discussed below).

Outcome-Aligned Payments (OAPs)

ACCESS will utilize recurring payments linked to achieving defined clinical targets. Payment levels depend on:

• Condition-specific, guideline-informed outcome measures;
• A minimum performance threshold (percentage of enrolled patients who meet the defined outcome) that increases annually; and
• Submission of required baseline and follow-up measures

ACCESS may be combined with accountable care organization or other risk arrangements, with benchmarks and performance year calculations incorporating ACCESS payments beginning in 2028. There are four tracks in which an organization can participate and organizations may participate in one, several or all. When a beneficiary is enrolled in multiple tracks with the same participant, CMS will apply a discount to the total payment amount to reflect administrative and operational efficiencies associated with delivering integrated care.

Most tracks (except MSK) include an initial year of care followed by an optional continuation period at a reduced rate, facilitating continued patient support.

Clinical Tracks and Outcome Measures

Option to Waive Cost-Sharing

Participating organizations have the option to waive beneficiary cost-sharing (deductible and co-pays) that would apply to OAPs under this model. Cost-sharing does not apply to co-management services (explained below). While this is not uncommon in CMMI models, it is a significant difference from other care management and remote monitoring services paid for under Medicare Part B, such as chronic care management, principal illness navigation, complex care management, remote physiologic monitoring and remote therapeutic monitoring. Beneficiary cost-sharing has long been cited as a barrier to patient participation in these care management and monitoring services.

Care Coordination & Co-Management

ACCESS embeds structured expectations for participant organizations to coordinate with primary care and other referring clinicians and encourages co-coordinating providers to engage through fee-for-service payments.

• ACCESS organizations must share electronic care plans and updates at initiation, key milestones and completion using secure mechanisms (e.g., direct messaging), and maintain connectivity to a Health Information Exchange (HIE) or similar trusted network.
• Part B-enrolled clinicians may bill a new ACCESS Co-Management service (approximately $30 per review plus an initial onboarding add-on of about $10; up to roughly $100 per beneficiary per year) for documented review of ACCESS updates and related care-coordination actions.

Data Reporting, Privacy, and Device Oversight

Participants must:

• Report clinical data through CMS-hosted application programming interfaces.
• Maintain HIPAA compliance and appropriate device oversight (including obligations for digital health tools established by the Food and Drug Administration (FDA)).

CMS may disenroll participants for failure to meet quality, safety or outcome standards.

Implications for Potential Participants

ACCESS creates meaningful opportunity for Part B enrolled provider organizations and health tech companies, particularly in clinical areas where many commercial and MA plans already use per member per month care management vendors and episode-based arrangements. In these domains, ACCESS may feel like a Medicare analog to models insurers are already pursuing in CKD, diabetes and MSK.

Potential ACCESS participants should consider:

• Business Model Fit. Health tech companies that already deliver virtual coaching, remote patient monitoring and integrated clinical services will be well-positioned, especially if they can align their existing commercial or MA product offerings with ACCESS requirements. If these companies also have an affiliated physician practice (such as a captive professional entity) they may be well-positioned to have their affiliate practice enroll in Medicare and apply to be a participant. Large platforms and scaled CKD, MSK and behavioral health companies are likely to be among the earliest and most capable adopters, given experience with similar risk and outcomes constructs in commercial and MA lines of business.
• Provider Enrollment Readiness. Few digital health or MSK/CKD vendors are currently Part B–enrolled. Many may choose contracting partnerships and opt to be listed in the vendor directory rather than enrolling in Medicare and taking on added compliance responsibilities.
• Operational and Data Capabilities. Routine capture of patient-reported outcome measures (PROMs) for MSK/BH, standardized metabolic measures for eCKM/CKM and longitudinal outcomes at the patient level will be foundational. Organizations will need robust reporting, analytics and risk adjustment literacy to manage to OAP thresholds and to demonstrate performance across increasingly stringent benchmarks.

Open Questions

• OAP payment levels. CMS has not yet specified the OAP amounts by track. The ultimate attractiveness of ACCESS for participants will hinge on whether payment levels are commensurate with the intensity of technology, staffing and analytics required.
• Performance thresholds. While CMS has indicated that minimum performance thresholds will increase over time, the specific starting points, ramp-up schedule and allowance for partial improvement versus full control are not yet defined.
• Risk adjustment methodology. CMS has signaled the use of risk-adjusted outcomes and public reporting but has not yet detailed the risk adjustment approach or how it will interact with both OAP levels and minimum performance thresholds. Note: CMS has indicated that it is reevaluating risk adjustment methodologies in other areas, including the recent Request for Information released with the CY2027 Part D/MA Proposed Rule. This may signal changes for risk adjustment in CMMI models, which have historically used the same risk adjustment methodologies as MA.
• Model cost savings. As with all CMMI models, ACCESS must demonstrate cost neutrality or savings to Medicare; however, CMS has not yet described how total spending impacts will be measured or over what time period. Open questions include which utilization components are expected to drive savings, how those savings will be attributed to ACCESS interventions and who is accountable if savings are not achieved.

Looking Ahead

Primary Care. While CMS references the importance of collaboration with primary care, success will depend on how effectively this link is operationalized, for both referrals and ongoing, whole-person care. Key considerations include how frequently and in what format PCPs will receive updates, whether ACCESS documentation integrates into electronic health record workflows and whether the co-management payment is sufficient to motivate sustained engagement. PCPs remain central to preventing avoidable emergency and inpatient utilization and ensuring continuity across care settings. As a result, primary care buy-in will shape referral volume, data completeness, and overall clinical and financial outcomes, and may determine whether ACCESS functions as a scalable, longitudinal chronic care model or remains limited in reach.

Participant Readiness. CMS indicated the release of a comprehensive Request for Application, implementation guide and additional technical documentation in the coming months.

Prospective participants should begin internal readiness assessments now, including:

• Evaluating Medicare Part B enrollment status and compliance infrastructure
• Mapping current chronic-care capabilities against ACCESS tracks and outcome measures
• Identifying gaps in data, analytics, PROM capture and HIE connectivity
• Stress-testing business models under different OAP levels and performance-threshold scenarios once CMS releases more detail