CMMI Launches Voluntary Payment Model for Qualifying Chronic Conditions with Tech-Enabled Care

The Centers for Medicare & Medicaid Services (CMS) has announced that the Center for Medicare and Medicaid Innovation (CMMI) is testing an outcome-aligned payment (OAP) approach designed to give Medicare fee-for-service (FFS) beneficiaries¹ new options to prevent and manage chronic disease with technology-supported care. The Advancing Chronic Care with Effective, Scalable Solutions (ACCESS) Model is a 10-year national test of a new CMMI disease-specific and episode-based voluntary payment model² designed to expand access to technology-supported care for people with certain chronic conditions.

ACCESS will begin on July 1, 2026, and operate through June 30, 2036. CMS will accept applications on a rolling basis from January 2026 through January 2033 to allow multiple entry points for organizations that wish to participate. 

To be considered for the model's first performance period (beginning July 1, 2026), applications must be submitted by March 20, 2026. Applications received after this date will be considered for a start on Jan. 1, 2027.³ CMS will post application materials, deadlines and updates on the ACCESS Model webpage.

Overview of the ACCESS Program

The ACCESS program initially includes four clinical tracks focused on common chronic conditions:

1. early cardiometabolic and kidney conditions, including hypertension, dyslipidemia (abnormal or elevated lipids, as well as cholesterol), obesity or being overweight
2. late cardiometabolic and kidney conditions, including diabetes, chronic kidney disease and certain cardiovascular diseases
3. musculoskeletal conditions, including chronic musculoskeletal pain
4. behavioral health conditions, including depression or anxiety

CMS has clarified that organizations can participate in more than one clinical track.

Medicare FFS beneficiaries can enroll directly with a participating ACCESS organization or be referred by their healthcare provider. Beneficiaries can sign up in multiple different tracks from the same or different organizations.⁴

When a Medicare 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.

ACCESS Participation Requirements

To participate, organizations must be enrolled in Medicare Part B as providers or suppliers (excluding durable medical equipment and laboratory suppliers) and must designate a physician clinical director responsible for care quality and compliance. Participants must also meet all applicable federal and state requirements, including licensure and compliance with Health Insurance Portability and Accountability Act of 1996 (HIPAA) requirements (for covered entities) and applicable U.S. Food and Drug Administration (FDA) requirements.⁵

Under the ACCESS program:

• Participants are responsible for helping patients achieve their targets (e.g., lowering blood pressure or reaching guideline-informed goals).
• Participants must electronically share care plans and updates at key moments, including treatment initiation, completion and certain clinical milestones.
  • Participants must also integrate with a health information exchange (HIE) to allow referring clinicians to securely access updates.
• Providers must offer "tech-enabled care," including coaching, behavioral support, patient education and medication management that help manage chronic conditions.
  • Providers can also use remote patient monitoring devices and wearables to monitor beneficiaries.

CMS plans to maintain a public directory of ACCESS participating providers, including the conditions they treat and their risk-adjusted clinical outcomes. Notably, CMS will monitor performance and may disenroll participants who fail to meet quality, safety or outcome standards.

How ACCESS Payments Work (and Differ from Medicare FFS)

Each of the four ACCESS clinical tracks will include a set of guideline-informed, condition-specific measures and outcome targets. CMS will determine payment based on the overall share of patients who meet their defined outcomes, compared to a minimum threshold that increases with each participation year.

While Medicare FFS payments are tied to specific activities, services or devices provided, ACCESS introduces outcome-aligned payments (OAPs), which are recurring payments for managing a beneficiary's qualifying condition. ACCESS focuses on clinical improvement of specified conditions based on each patient's starting clinical measures. For example, in the ACCESS model, a participant may receive OAP recurring payments for managing a beneficiary with hypertension, but the full payment will be tied to the beneficiary achieving a specific reduction in blood pressure over a given period.

Additionally, and as further described below, primary care physicians (PCPs) and referring clinicians will be able to bill a co-management payment (without beneficiary cost sharing) for reviewing updates and documenting related care-coordination actions, such as medication adjustments or problem-list updates.

To facilitate continued clinical support, most, but not all, ACCESS tracks will include an optional continuation period. For example, CMS indicates that the musculoskeletal track has goals to resolve chronic pain during the initial care period and, therefore, does not have an additional optional follow-on period. During applicable continuation periods, however, CMS will pay a reduced payment rate to the organization that reflects lower resource needs once care is established.

Cost Sharing for Medicare Beneficiaries in the ACCESS Model

CMS intends to offer the CMS-sponsored model patient incentive safe harbor⁶ to ACCESS participants who wish to forego collection of beneficiary cost sharing for OAPs as a beneficiary engagement incentive. ACCESS participants should indicate in their model application whether they plan to collect or forego collection of OAP cost sharing and must apply this policy uniformly to all such beneficiaries.

In addition to the optional OAP cost sharing, as noted above, there is no beneficiary cost sharing for the separate co-management payment billed by PCPs or referring clinicians when they review and coordinate care with ACCESS participants.

ACCESS Co-Management Payments

Clinicians who co-manage ACCESS beneficiaries with an ACCESS participant will be able to bill a new ACCESS model co-management service for documented review of ACCESS updates and care coordination activities. The service will be paid approximately $30 per service, subject to the geographic adjustment and standard Medicare payment adjustments.

To bill the co-management code, the consulting clinician must review the ACCESS care update and place a brief written note in the electronic health record (EHR) documenting the assessment and any care-coordination action, such as:

• a medication change or reconciliation
• an updated problem list
• monitoring instruction
• a referral

Clinicians who assist a beneficiary with onboarding and initial setup activities may also bill the co-management code with a CMS-specified modifier the first time they bill for that beneficiary to receive an additional payment of approximately $10, subject to the adjustments described above. The payment will be limited to once every four months per beneficiary per track, up to approximately $100 per year.

As noted above, there will not be Medicare Part B beneficiary cost sharing for this co-management service, and advance consent from beneficiaries will not be required.

The ACCESS Co-Management Payment G-code, modifier and additional billing guidance will be provided by CMS in 2026.

ACCESS Tools Directory

In addition to the ACCESS participant directory, CMS plans to host a resource within the ACCESS application and participant portal, called the ACCESS Tools Directory, to help participants identify optional software and hardware tools that may support model participation and compliance.

Vendors may voluntarily opt into the tools directory and also have the option to include promotional offers (e.g., product discounts or service credits). These offers may apply only for ACCESS participants and must otherwise comply with all applicable federal and state laws, including those governing beneficiary inducement. CMS will conduct basic review(s) for completeness and relevance but not independently verify, approve or endorse any listed products in the tools directory. Although CMS states that no confidential or beneficiary information will be shared with vendors through the tools directory, the existence of the directory seems to confirm CMS' willingness to allow technology vendors to have direct access to the platform. It also signals an intent to incentivize providers to engage in care coordination in furtherance of the belief that technology can play a meaningful role in managing chronic conditions.  

How the ACCESS Model Interrelates with ACOs and Impacts Participation with Other Shared Savings Models

Since many organizations interested in the ACCESS model may already participate in a Medicare Shared Savings Program (MSSP) and/or be affiliated with an Accountable Care Organization (ACO), CMMI clarifies in its FAQs that ACCESS is designed to complement existing ACOs and risk-bearing arrangements by encouraging ACOs to leverage technology-enabled care to meet quality and savings goals.

For 2026 and 2027, CMS will make system changes to support model operations and anticipates that there will be no impact from ACCESS OAPs on ACO benchmark and performance year calculations for the MSSP and ACO Realizing Equity, Access, and Community Health Model (REACH). Beginning in 2028, expenditures associated with ACCESS OAPs will be included in ACO benchmark and performance year calculations.

Notably, CMS does not expect ACCESS to qualify as an Advanced Alternative Payment Model (A-APM). Additionally, CMS anticipates that ACCESS services would not contribute to Merit-Based Incentive Payment System (MIPS) reporting obligations.

Holland & Knight will continue to monitor and report on developments on this and other CMMI payment models. For additional information or questions, please contact the authors or another member of Holland & Knight's Healthcare Team.

Notes

¹ CMS notes that Medicare Advantage enrollees are not included in the ACCESS program, though health plans may choose to offer similar programs.

² It is important to differentiate a CMMI voluntary payment model, such as ACCESS, from a CMMI mandatory payment model, such as the new Ambulatory Specialty Model (ASM). Though both voluntary and mandatory payment models are aimed at care coordination and promotion of preventative care, there is an inference with mandatory payment models that care has historically been delayed in specific instances (leading to poor outcomes) and can be better managed.

³ The CMMI webpage has an April 1, 2026, deadline to submit an initial application, but the FAQs section has been updated with an earlier deadline of March 20, 2026. As Holland & Knight seeks clarity, it is recommended that submissions be made by the earlier date of March 20, 2026.

⁴ Because the model's new payment approach is being tested, a small number of beneficiaries who try to enroll in a specific ACCESS track may be randomly assigned by CMS to a control group for that track. This process is intended to help CMS evaluate the model's impact, but patients in a control group will continue to have full access to all standard Medicare services and can work with their usual healthcare providers.

⁵ More information about participant requirements and responsibilities will be provided on the Request for Applications (which has not been released as of the publication of this Holland & Knight alert). To be notified by CMMI when available or for more information regarding the CMMI ACCESS program, please see the Model Interest Form.

⁶ See 42 CFR § 10001.952(hh)(9)(ii)(2).

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