As we close out 2025, the Centers for Medicare & Medicaid Services (CMS) has introduced an exciting development for providers focused on chronic disease management. The Advancing Chronic Care with Effective, Scalable Solutions (ACCESS) Model, announced by the CMS Innovation Center, aims to bridge a longstanding gap in traditional Medicare fee-for-service: reimbursing innovative, technology-supported care that happens outside of in-person visits.

For many practices—whether primary care, specialty, palliative, or coordinated care teams—this voluntary model opens the door to recurring payments tied directly to patient outcomes, rather than the volume of services. It's a shift that could help sustain and scale digital tools like remote monitoring, telehealth, asynchronous messaging, and AI-supported coaching for patients with common chronic conditions.

What the ACCESS Model Looks Like in Practice

The 10-year model is set to launch on July 1, 2026, with applications opening in early 2026 (interested organizations can already submit a non-binding Interest Form on the CMS website to stay updated).

Instead of billing for individual encounters, participating Medicare-enrolled providers (or even certain technology companies that enroll directly) will receive monthly Outcome-Aligned Payments (OAPs) for managing enrolled beneficiaries' chronic conditions. Full payment depends on achieving risk-adjusted, condition-specific outcomes—such as lowering blood pressure by a targeted amount or improving depression scores—based on clinical guidelines.

Providers choose from four initial clinical tracks, and can participate in one or more:

• Early Cardio-Kidney-Metabolic (eCKM)

  : Focusing on prevention with conditions like hypertension, dyslipidemia, obesity, and prediabetes.

• Cardio-Kidney-Metabolic (CKM)

  : Managing established diabetes, chronic kidney disease, and cardiovascular disease.

• Musculoskeletal (MSK)

  : Addressing chronic musculoskeletal pain (typically an initial intensive period without ongoing continuation).

• Behavioral Health (BH)

  : Treating depression and/or anxiety.

Care can be delivered flexibly—in-person, virtually, remotely, or asynchronously—and most tracks include an initial year of higher-intensity management followed by an optional lower-rate continuation period.

To support implementation, CMS plans to publish an ACCESS Tools Directory listing compliant software, hardware (e.g., connected blood pressure cuffs), and interoperability solutions. Outcomes will be publicly reported in a directory for transparency, helping patients and referrers make informed choices.

Opportunities and Considerations for Providers

In our work with healthcare organizations, we've seen how chronic conditions affect more than two-thirds of Medicare beneficiaries, often requiring ongoing coordination that traditional FFS doesn't fully reward. ACCESS aligns well with that reality, offering:

• A stable revenue stream for tech-enabled services that improve adherence and outcomes.

• Flexibility to partner with digital health vendors or even waive patient cost-sharing (done compliantly to avoid AKS/FCA issues).

• Potential synergy with ACOs or other value-based arrangements (with adjustments starting in 2028).

Referring clinicians, including many palliative care providers, can bill a new co-management code (no beneficiary cost-sharing) for reviewing updates and coordinating care—up to about $100 per patient per year.

That said, participation involves real accountability:

• Robust data tracking and outcome reporting.

• Compliance with HIPAA, state licensure, and FDA rules for any regulated devices.

• Strong governance, including a designated physician clinical director.

Practical Steps to Prepare

If your organization is considering ACCESS, here are some initial actions we often recommend to clients:

• Submit the Interest Form

  Get on CMS's list for application notifications and updates via the

  official ACCESS page

  .

• Assess Your Readiness

  Inventory current tech tools, patient panels with qualifying conditions, and ability to measure/track outcomes.

• Evaluate Partnerships

  Explore vendor options early and review contracts for compliance and data-sharing.

• Review Legal and Operational Implications

  Consider cost-sharing waivers, direct tech company enrollment, and integration with existing programs.

• Plan for Patient Engagement

  Think through enrollment processes—beneficiaries can self-enroll or be referred—and how to communicate benefits.

Looking Forward

The ACCESS Model reflects CMS's broader push toward patient-centered, value-based care where technology plays a central role. Early interest has been strong, with hundreds of organizations already signaling intent to apply.

At MDRxLaw, we've been helping providers navigate CMS Innovation Center models for years—from structuring partnerships to ensuring compliant documentation and preparing for audits.

If you're evaluating whether ACCESS fits your practice, or need guidance on applications, vendor agreements, or compliance strategies, our team is ready to assist.

Reach out for a discussion of your organization's opportunities under the ACCESS Model. Contact us at (212) 668-0200, email info@mdrxlaw.com, or visit mdrxlaw.com.

We're here to help turn this new pathway into practical, sustainable improvements in chronic care.