CMS Tests Lifestyle Medicine in Medicare With MAHA ELEVATE

Key Takeaways

• CMMI is launching a new model called MAHA ELEVATE to test “evidence‑based, whole-person lifestyle and functional medicine” for the FFS Medicare population beyond currently covered services, using a cooperative agreement. The model does not establish a new Medicare payment or reimbursement pathway and Medicare FFS reimbursement will not be adjusted by participating in the model.
• MAHA ELEVATE will fund up to 30 organizations up to $3.3 million each to deliver these interventions aimed at addressing chronic disease, improving health and reducing costs with three awards reserved for those related to dementia and cognitive decline.
• The model emphasizes interventions that already have a strong evidence-base. Interested applicants must also show not only a solid previous track record of implementation but also significant operational sophistication, including the ability to enroll beneficiaries at scale and support rigorous data collection and evaluation.

What Is MAHA ELEVATE?

The Centers for Medicare & Medicaid Services (CMS) Innovation Center (CMMI) recently launched its Notice of Funding Opportunity (NOFO) for the . MAHA ELEVATE is a cooperative agreement opportunity that centers what CMS calls “whole-person functional or lifestyle medicine (FLM)” to prevent chronic disease in the fee-for-service (FFS) (“Original”) Medicare population. CMMI frames the goal as “determining which evidence-based [interventions] may best support conventional care and suit the health promotion and disease prevention needs of people with Original Medicare.”

With approximately $100 million available in funding, CMS will make up to 30 awards in two cohorts, and each approximately $3.3 million award will span three years. The NOFO specifies that three of the 30 total awards are set aside for programs focused on dementia and cognitive decline, reflecting a targeted priority within the model rather than a separate application process.

Eligible applicants include medical practice groups, health systems and non‑clinical community‑based organizations (CBOs). State or local governments may also apply as lead or partnering participants. Applicants must propose both the specific intervention(s) to be tested and the Medicare beneficiary population and chronic condition the intervention is intended to address. Importantly, applicants must also show that the proposed interventions are already evidence-based. Interventions must be aligned with the , of which nutrition or physical activity (or both) are required model components, and the remaining four—stress management, sleep, avoidance of risky substances or social connection—may also be incorporated. Each intervention must include at least one service not currently covered under FFS Medicare; programs may combine FLM interventions with Medicare covered services, provided the non‑covered component is central to the intervention being tested. MAHA ELEVATE funding may not be used to pay for direct food provision (e.g., meals, groceries or food vouchers), but could support wrap‑around services (e.g., nutrition education and counseling) in recognition of the impact nutritious eating has on an individual’s health. An example award given in the NOFO is a hypothetical program of eight group nutrition counseling sessions offered with a “five-tiered fitness program” to FFS Medicare patients with a BMI greater than 26.

In practice, this application demands significant experience and a certain degree of scale. The NOFO indicates that to be successful, an applicant must show a robust evidence-base supporting the proposed intervention(s), necessitating a history of successful implementation prior to making the application. Applicants must demonstrate significant operational experience, including readiness to recruit a meaningful number of FFS Medicare participants; report beneficiary‑level data; and submit regular clinical, utilization and process measures for model monitoring and evaluation. Importantly, CMS—not the applicant—will determine the minimum number of Medicare beneficiaries to be served by the intervention(s) and will tie a significant portion of the funding to completion of the established enrollment targets. Example enrollment thresholds provided in the NOFO were all over 1,000 Medicare beneficiaries. Applicants must also propose a randomized study design or otherwise include a valid comparison group. Taken together, these requirements elevate operational and data readiness to a threshold consideration as well as the qualities of the intervention itself.

Key Issues to Pay Attention To

Interventions focused on chronic disease prevention in the Medicare population are not new; in fact, they have been central to CMMI’s work since its inception and under all Administrations since. Examples given in the MAHA ELEVATE NOFO appear similar to ideas tested under the as well as , which scaled in 2016 and began covering services in 2018. However, MAHA ELEVATE’s political context is different, and the following three issues will determine what mark this model may ultimately make:  

1. What kinds of interventions will meet the “robust evidence-base” entry requirement. CMS has emphasized the importance of a “robust evidence-base” for proposed model interventions, but has not specified how different forms of evidence will be weighted in the application review or ongoing evaluation. CMS maintains discretion over which applications will scale the bar.
2. How CMS will evaluate quality and cost impact. As with all CMMI models, MAHA ELEVATE will be evaluated on its impact on total Medicare spending and quality. Key questions include which utilization components are expected to drive savings, how downstream effects will be attributed to MAHA ELEVATE interventions, and the time horizon over which quality and cost impacts will be assessed. Because MAHA ELEVATE is structured as cooperative agreements funding multiple change concepts—rather than a change to Medicare’s underlying reimbursement framework—the model is designed to generate evidence on non‑covered services rather than establish new covered services or payment pathways directly. The way CMS interprets cost findings will therefore depend on the strength and consistency of results across interventions within the model’s scale and timeframe, and how those findings inform future testing or policy consideration.
3. What the policy endgame will be. Because MAHA ELEVATE is a set of funded interventions rather than a single intervention, scaling will also likely need to be determined at the level of the intervention as opposed to the whole model.  Integrating any MAHA ELEVATE intervention more directly into the FFS Medicare program would likely require sustained evidence over time, additional testing and policy action beyond the scope of this model. Scaling specific interventions through further future CMMI models may be an interim step.

For Organizations Interested in Applying

Organizations interested in MAHA ELEVATE should begin assessing whether their interventions are evidence‑ready, implementation‑tested and scalable, and whether they have credible pathways to recruiting and engaging Medicare beneficiaries.

• : April 10, 2026 (required for all applicants)—must use the link provided by CMMI
• : May 15, 2026
• Cohort 1 performance begins: October 2026
• Cohort 2 performance begins: October 2027

For questions or more information on the MAHA ELEVATE model, please reach out to or .