Understanding CMS’s New ACCESS Model: A Guide for Tech-Enabled Providers

What Is the CMS ACCESS Model?

On January 12, 2026, the Centers for Medicare & Medicaid Services (CMS) launched a groundbreaking initiative: the ACCESS Model – short for Advancing Chronic Care with Effective, Scalable Solutions.

This 10-year voluntary program is designed to transform how chronic conditions are managed across the U.S. healthcare system, especially for Medicare beneficiaries. Unlike traditional fee-for-service models that reward volume, the ACCESS Model introduces Outcome-Aligned Payments (OAPs) a value-based care structure that reimburses providers based on patient health improvements.

In other words:

• Predictable recurring payments for chronic care management
• Full payment earned only when clinical outcomes are achieved

For digital health providers, care management platforms, and tech-enabled clinics, this marks a significant opportunity and challenge. The ACCESS Model incentivizes innovation, but also sets a high bar for interoperability, compliance, and outcomes tracking.

Why It Matters

With over two-thirds of Medicare patients living with chronic conditions, ACCESS represents one of CMS’s boldest efforts to improve care quality and reduce costs at scale. It’s also a first-mover opportunity for startups and healthcare organizations ready to lead in the next generation of chronic disease management.

CMS ACCESS Model Timeline: What to Know

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Note: CMS will accept new applications on a rolling basis, but early participants can gain a competitive edge, access performance data first, and become reference points for future program iterations.

ACCESS in a Nutshell: What You Need to Know

What Is the CMS ACCESS Model Designed to Do?

The ACCESS Model is the latest value-based care program from the Centers for Medicare & Medicaid Services (CMS). It aims to improve chronic disease management by shifting Medicare reimbursement from volume to outcomes.

Instead of paying providers for each visit or service, CMS will provide recurring payments to organizations that manage patients’ chronic conditions and help them reach specific, measurable health improvements.

This model is focused on results. To earn the full payment, participants must demonstrate real clinical progress in the patients they serve.

Who Is the ACCESS Model For?

Eligible participants include:

• Physician group practices
• Health systems and accountable care organizations (ACOs)
• Digital health startups and tech-enabled care companies

To apply, organizations must be enrolled in Medicare Part B and able to deliver structured, tech-enabled care that aligns with CMS guidelines.

What Are the Participation Requirements?

To qualify for ACCESS, organizations must be able to demonstrate:

• Clinical oversight led by a licensed physician
• HIPAA-compliant technology infrastructure
• Interoperability with electronic health records (EHRs) using FHIR APIs
• Capacity to monitor and report clinical outcomes at the patient and population level

Participation requires both clinical readiness and the technical ability to manage data, integrate systems, and maintain compliance.

Clinical Tracks: Choosing the Right Focus Area

Applicants must select one clinical track and take responsibility for managing all conditions within that track. The model currently includes four tracks focused on high-impact chronic diseases:

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Each track requires a comprehensive approach to care delivery, including the use of digital tools, remote monitoring, and regular communication with referring providers.

How Outcome-Aligned Payments Work in the ACCESS Model

At the heart of the CMS ACCESS Model is a new payment structure called Outcome-Aligned Payments (OAPs). This approach replaces the traditional fee-for-service system with a model that ties reimbursement directly to patient health improvements.

Rather than billing for each service delivered, organizations receive a recurring, fixed payment per patient. To receive the full amount, providers must demonstrate that patients are reaching personalized clinical goals based on their baseline condition. For example, a patient with hypertension might need to show a specific reduction in blood pressure, while a patient with diabetes could be measured by improved HbA1c levels.

This structure gives providers more flexibility in how they deliver care. Instead of being limited by billing codes, ACCESS participants can use any combination of tools and services that support measurable improvement. That could include:

• Telehealth or virtual visits
• Remote patient monitoring
• Asynchronous digital engagement (via apps or messaging)
• Health coaching or lifestyle support programs

By focusing on outcomes rather than activities, the model gives tech-enabled organizations a significant advantage. If your digital tools help patients stay engaged and improve over time, they directly contribute to your organization’s reimbursement.

How Primary Care Providers Stay Involved

The ACCESS Model is designed to work alongside a patient’s existing primary care provider (PCP), not replace them. CMS has built referral and co-management mechanisms into the program to support ongoing collaboration between ACCESS participants and referring clinicians.

Patients can either be referred into an ACCESS program by their PCP or enroll on their own. To keep PCPs engaged, CMS allows them to bill a co-management fee (approximately $30 per patient, per quarter) for reviewing care plans and coordinating with the ACCESS provider.

One of the model’s requirements is that participants must electronically share care plans and key updates with the referring provider at multiple points during the patient’s care. These updates must follow FHIR-based interoperability standards, ensuring that all data can be securely and consistently accessed across systems.

This closed-loop approach helps maintain continuity of care and ensures that the patient’s broader care team is informed throughout their treatment.

Who Is Eligible to Apply?

The ACCESS Model is open to a wide range of healthcare organizations from traditional provider groups to digital-first startups as long as they meet CMS’s technical and regulatory requirements.

To apply, your organization must:

• Be enrolled as a Medicare Part B provider or supplier
• Designate a licensed Physician Clinical Director to oversee clinical care
• Demonstrate compliance with HIPAA, all relevant state licensure laws, and applicable FDA regulations (especially for devices or software used in care delivery)

If your organization is not yet enrolled in Medicare, you may still be eligible by partnering with an existing provider or by initiating the enrollment process before applying.

ACCESS is intentionally inclusive, but success requires a high degree of readiness both technically and operationally.

Your Technical Readiness Matters

To participate in the CMS ACCESS Model, clinical capabilities are only part of the equation. Your technical infrastructure must also meet CMS’s requirements for interoperability, data security, and performance tracking. This is where many organizations will face the steepest learning curve.

ACCESS is not a traditional program. It assumes that participants can operate within a connected, data-driven care ecosystem, using modern healthcare standards and platforms to deliver results.

FHIR Integration: A Non-Negotiable Requirement

CMS requires all ACCESS participants to support FHIR-based data exchange. This ensures that patient data flows securely and consistently between systems including electronic health records (EHRs), Health Information Exchanges (HIEs), and CMS itself.

To meet this requirement, your platform must be able to:

• Retrieve clinical data from major EHRs (such as Epic, Cerner, Athena)
• Send structured care plans and outcome updates back to referring providers
• Integrate with HIEs for ongoing care coordination

If your system is not already FHIR-ready, this is the first technical milestone to address. Building or integrating with a FHIR API layer will be essential for participation.

HIPAA-Compliant Infrastructure

Handling remote patient monitoring data, mental health scores, or chronic care metrics means dealing with highly sensitive information. Every component of your digital infrastructure must comply with HIPAA privacy and security standards.

This includes:

• End-to-end encryption (in transit and at rest)
• Role-based access controls for clinical and admin users
• Detailed audit logs to track access and changes
• Secure, healthcare-grade hosting environments

Compliance is not just about checking boxes. CMS expects participants to demonstrate that their systems can protect patient data at scale and over time.

AI and Advanced Analytics: Encouraged but Optional

While not mandatory, CMS has clearly signaled that organizations using AI-driven tools will be well-positioned in this program. From a care management perspective, these tools can support smarter interventions, better risk stratification, and more efficient use of clinical resources.

Some of the most promising use cases include:

• Predictive models to flag at-risk patients
• AI diagnostics or virtual triage assistants
• Real-time analysis of wearables and biomarker data
• Personalization engines to increase patient engagement

In a model where outcomes determine payment, these technologies can help providers act sooner, improve results, and maximize their reimbursement potential.

Preparing for the ACCESS Application: What to Do Now

If you’re planning to apply by the April 1, 2026 deadline, preparation needs to begin immediately. The application process will require a clear plan and proof that your organization can meet both clinical and technical criteria.

Here’s a practical five-step preparation plan:

1. Assess Your Technical Infrastructure

Start with a technology audit. Confirm that your platform supports FHIR integration, meets HIPAA requirements, and can scale for population-level care.

2. Review Clinical and Regulatory Readiness

Ensure that your organization is properly enrolled in Medicare Part B, has a designated Clinical Director, and meets all state licensure and FDA requirements for care delivery tools.

3. Define Your Care Delivery Strategy

Select the clinical track that aligns with your expertise and patient population. Outline how your care model will work including the digital tools you’ll use, your staffing plan, and how you’ll track progress toward outcome goals.

4. Map Out Interoperability Plans

You’ll need to show how your system connects to EHRs, HIEs, and CMS reporting channels. Begin identifying integration requirements now to avoid delays later.

5. Identify the Right Technology Partner

Participating in ACCESS is a complex technical challenge. For many organizations, success will depend on partnering with a healthcare technology firm that can build or adapt the infrastructure required to meet CMS standards.

Ready to Apply for the CMS ACCESS Model?

If your organization is preparing to apply for the first ACCESS cohort by April 1, 2026, or planning for a future entry point, now is the time to take action.

Whether you're a provider looking to modernize chronic care delivery or a digital health company building for value-based care, the ACCESS Model offers a major opportunity but only for those who are ready on both the clinical and technical fronts.

At Momentum, we specialize in helping healthtech innovators design and implement the infrastructure required for CMS programs like ACCESS. From FHIR integration and HIPAA-compliant development to AI tooling and patient-facing apps, we provide full-service technical support to help you launch with confidence.

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