March 30, 2026

ACCESS Granted: Outcome and Value-Based CMS Model for Digital Health Management

Claire Castles, Alexis Gilroy, Gerald Griffith, Andrew Jack, John Kirsner, Laura Koman, Tyler Loveall, Andrew McGirty Jones Day + Follow Contact LinkedIn Facebook X Send Embed

The Centers for Medicare & Medicaid Services ("CMS") aims to expand digital health technology usage among Medicare beneficiaries and providers under its new Advancing Chronic Care with Effective, Scalable Solutions ("ACCESS") Model, where payment is tied to beneficiaries achieving measurable clinical outcomes.

To incentivize the growth of technology-enabled chronic condition management, CMS recently announced the ACCESS Model, which tests Outcome-Aligned Payments ("OAP")—fixed per-beneficiary payments where full payment is contingent on beneficiaries achieving measurable clinical outcomes. CMS will accept ACCESS Model applications through this Participant Portal beginning in 2026, with rolling admissions through early 2033. To participate in the first cohort, which begins July 5, 2026, applications are due April 1, 2026.

Key Features

• Duration: July 5, 2026 – June 30, 2036
• Eligible Participants: Medicare Part B-enrolled providers or suppliers (excluding Durable Medical Equipment, Prosthetics, Orthotics, and Supplies, or DMEPOS, and laboratory suppliers). Note: Interested digital health tech companies that are not Part B-enrolled providers may partner with eligible providers to deliver services.
• Eligible Beneficiaries: Original Medicare beneficiaries (i.e., fee-for-service, non-Medicare Advantage) who have qualifying chronic conditions included in one of the "Clinical Tracks" below:
  • Early Cardio-Kidney-Metabolic. Hypertension, or at least two of dyslipidemia, obesity or overweight with marker of central obesity, or prediabetes.
  • Cardio-Kidney-Metabolic. Diabetes mellitus, chronic kidney disease, or atherosclerotic cardiovascular disease.
  • Musculoskeletal. Chronic musculoskeletal pain.
  • Behavioral Health. Depression or anxiety.
• Eligible Technologies: Food and Drug Administration-compliant digital health tools, connected devices, and software and digital health devices participating in the TEMPO Pilot.
• Payment: Depending on the Clinical Track and other factors, the annual payment-per-beneficiary ranges from $90 to $420. Fifty percent of this payment is distributed in equal monthly installments. The remaining 50% is withheld until year-end. Participants may recover up to the full withheld amount if at least half of their beneficiaries meet the required clinical outcome target.
• Medicare Fee-For-Service ("FFS") Exclusion: ACCESS participants and their affiliated entities may not submit FFS claims for aligned beneficiaries during active care periods.

• CMS Program Overlap: ACCESS participants may participate in, and ACCESS beneficiaries may be attributed to, other CMS models, including, without limitation, managed security service providers and the upcoming LEAD Model. CMS is evaluating a temporary exclusion of ACCESS spending from accountable care organization financial benchmarks and reconciliation during the first year of ACCESS, before incorporating related spending into total cost-of-care calculations in later years.
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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.
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