CMS “ACCESS” tests outcome-aligned, tech-enabled chronic care

The Centers for Medicare & Medicaid Services (CMS) has announced the ACCESS Model (Advancing Chronic Care with Effective, Scalable Solutions), a 10‑year voluntary initiative slated to launch in July 2026. This model aligns with CMS’s stated goal of shifting toward technology‑supported care and outcomes-based payment. The ACCESS model aligns with the CMS aim to move traditional Medicare away from fee‑for‑service reimbursement and instead tie payments to measurable improvements in chronic disease management. CMS published Frequently Asked Questions (FAQs) and states that the Request for Applications will be available soon. The model’s first performance period will begin on July 1, 2026, with a second cohort of participants to begin on January 1, 2027.

CMS’s stated goals are to improve clinical outcomes at scale and reduce disparities by ensuring that technology‑enabled interventions are accessible across diverse populations. More than two‑thirds of Medicare beneficiaries live with one or more chronic conditions targeted by ACCESS, such as hypertension, diabetes, chronic musculoskeletal pain and depression.

Medicare Part B-enrolled providers (excluding durable medical equipment and laboratory suppliers) are eligible to apply. Applicants must demonstrate the capacity to adopt technology‑supported tools, manage populations with the targeted conditions and report outcomes to CMS. Participants should expect to integrate digital health tools into routine care, align clinical workflows to outcomes‑based reimbursement and operate within a competitive field of Part B providers. ACCESS is not for beneficiaries enrolled in Medicare Advantage plans, but CMS states that “plans may choose to offer similar programs."

Applications to participate in the model will open January 12, 2026, and close April 1, 2026. Providers that begin preparing now, by conducting compliance audits, vetting technology partnerships, developing technology-support access and educating clinical staff, will be better positioned to succeed under the new model.

How ACCESS is expected to operate

Operationally, ACCESS is designed to integrate technology‑supported care into routine practice for traditional Medicare beneficiaries with four common chronic conditions while tying payment to patient outcomes. Participants will be expected to deploy digital tools, such as remote monitoring devices, mobile health applications and telehealth platforms, to track and manage chronic conditions between visits. Beneficiaries enrolled in traditional Medicare with qualifying chronic conditions will be able to enroll through a participating ACCESS organization or be referred by their provider. CMS will measure performance against defined benchmarks, such as blood pressure control, glycemic management, functional status/pain and depression screening and follow-up, and will adjust payments based on whether those outcomes are achieved.

Participants will have flexibility in how they deliver care but must demonstrate interventions that are scalable and reach a broad patient population. Data reporting is central: participants will be required to submit outcome metrics and patient engagement information to CMS on a regular basis. In effect, ACCESS seeks to shift the focus from units of service to the measurable impact of care on patient health. CMS noted in the FAQs that ACCESS is intended to complement accountable care organizations and risk-bearing arrangements. CMS will require reporting using standard-based Application Programming Interfaces.

Payment approach

ACCESS is structured to allow flexibility in the delivery of services, but reimbursement will be contingent on demonstrating measurable improvements in patient health. In practice, this means participating providers must align clinical workflows, technology investments and reporting systems to ensure that outcome data is captured accurately and submitted to CMS in a timely manner. Conversely, performance below benchmarks may reduce payment levels, creating a form of risk-sharing that places greater emphasis on care quality and patient engagement. In addition, clinicians that manage ACCESS beneficiaries with a model participant will be able to bill a new ACCESS Model Co-Management service and receive a US$30 payment per service. This payment can be billed once every four months and beneficiaries will not be subject to cost sharing.

Legal and regulatory considerations

Providers entering ACCESS must navigate a complex regulatory landscape:

Fraud and abuse: The federal Anti‑Kickback Statute and Stark Law continue to apply. Outcome‑based payments and vendor arrangements should be structured to avoid inducements or improper referrals. The FAQs state that CMS intends to offer the CMS-sponsored model patient incentive safe harbor to ACCESS participants wishing to engage beneficiaries by waiving cost sharing. Any model‑specific waivers should be carefully analyzed and documented.

Regulatory compliance: CMS states in the FAQs that “[o]rganizations must maintain compliance with applicable state licensure, HIPAA and FDA requirements (or otherwise be subject to FDA enforcement discretion), and cooperate with CMS program integrity and evaluation activities.” An implementation guide will be published by CMS “in the coming months” that will provide additional details.

Telehealth and licensure: Multistate telehealth delivery, remote monitoring and asynchronous services should be evaluated for state licensure, scope‑of‑practice, prescribing and modality‑specific requirements. Patient engagement incentives (for example, devices or connectivity support) should also be analyzed under the Beneficiary Inducements civil monetary penalty and applicable safe harbors or waivers.

Financial and strategic implications

ACCESS introduces new performance‑linked, risk‑sharing payments. Participants should:

Financial models: Develop financial models capable of simulating performance under different case mixes, patient adherence levels and outcome scenarios, and potential upside or downside adjustments.

Prioritize technology enablement: Advance remote patient monitoring and therapeutic workflows, deploy care management platforms, integrate data systems and apply AI‑assisted risk stratification, all with careful attention to interoperability, cybersecurity and overall cost of ownership.

Invest in technology-support access: Invest in services that make technology‑enabled care accessible to all patients, building digital literacy programs, providing strategies for device access and connectivity and tailoring outreach to local communities where broadband and technology barriers may be most pronounced. Vendor contracts should embed data rights, security, service level agreements, audit rights, outcome‑based performance obligations and clear exit/transition terms.

Enhance governance and accountability: Strengthen governance and accountability structures by establishing clear ownership for performance measurement, data quality and corrective action. Board‑level oversight of risk and compliance will be essential to ensure that operational and financial responsibilities are met under the ACCESS Model.

Patient engagement: Success will hinge on involving Medicare beneficiaries in digital care, with strategies to overcome barriers such as digital literacy and broadband access among those who have limited experience with technology. Technology support and access should include culturally and linguistically appropriate services, device and connectivity strategies and geographically tailored outreach.

Continuing developments in value-based care

The ACCESS model is another attempt to use the Section 1115A flexibility created under the Affordable Care Act to transition reimbursement from volume to value. Stakeholders should anticipate additional guidance and model details to be promptly issued by CMS before the application period opens on January 12, 2026. The Norton Rose Fulbright team continues to monitor developments in value-based care, including CMS Innovation Center model design and implementation updates. If you have any questions, please contact us.