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January 8, 2026 – Happy New Year! If 2025 was any indication of what 2026 will be like, we have an extremely busy year ahead in the regulatory world. And no area was busier in 2025 than the Centers for Medicare & Medicaid Services (CMS) Innovation Center, which released a plethora of new models and model modifications. To help me recap the Innovation Center’s work in 2025 and forecast what these actions may mean for 2026 and future years, I’m bringing in my colleague Simeon Niles.
Any new administration takes a few months to assemble a leadership team and develop a set of priorities. The first major news from the Innovation Center came on March 12, 2025, when it announced substantial changes to its portfolio of payment models, including an early end to several payment models in 2025. CMS stated that these changes aligned with the Innovation Center’s statutory mandate to reduce program spending while maintaining or improving care quality, and cancellation would result in an estimated $750 M in savings. Models identified to end early included the Maryland Total Cost of Care model (although Maryland will move into the AHEAD model), Primary Care First, ESRD Treatment Choices, and Making Care Primary. CMS stated that it was considering options to reduce the size of the Integrated Care for Kids model and that it will not pursue the Medicare $2 Drug List or Accelerating Clinical Evidence models. On May 13, 2025, the CMS Innovation Center issued a new strategic framework outlining how the center intends to structure current and future value-based care models, with an emphasis on prevention, individual engagement, and market-based mechanisms. With a strategic framework in place, the Innovation Center went on to announce nine new models in 2025 as well as modifications to at least five existing models.
Some context is helpful in assessing these new models and modifications, and to understand why the administration chose to focus on them in its first year. For much of its history, the Innovation Center has been evaluated as if it were a single program, and one of its primary objectives has been to generate large savings in Medicare and Medicaid as quickly as possible. Many stakeholders have judged models primarily on near-term net savings to the Medicare trust funds, with the explicit expectation that every test will “pay for itself” within an often-narrow evaluation window. However, healthcare transformation takes time, and savings that stem from innovation may take longer than a typical three-to-five-year model timeframe to come to fruition.
Another way to understand the Innovation Center might be as a portfolio of investments, each with different objectives, risk profiles, and time horizons for return on investment. CMS is increasingly balancing reliable near-term returns with longer-horizon bets that require incubation but have the potential to reshape the healthcare ecosystem.
As we saw with the cancelation of existing models the Center believed would ultimately be “costers,” the Innovation Center’s strategy skewed heavily toward what any investor would recognize as low-risk, predictable returns. The following five new models were designed to guarantee savings, often mandating inclusion to remove participation bias.
| Model name | Model dates (in chronological order) |
|---|---|
| Wasteful and Inappropriate Service Reduction (WISeR) | January 1, 2026 – December 31, 2031 |
| GENErating cost Reductions fOr U.S. Medicaid (GENEROUS) | January 1, 2026 – December 31, 2030 |
| Global Benchmark for Efficient Drug Pricing (GLOBE) – PROPOSED | October 1, 2026 – December 31, 2031 |
| Guarding U.S. Medicare Against Rising Drug Costs (GUARD) – PROPOSED | January 1, 2027 – December 31, 2031 |
| Ambulatory Specialty Model (ASM) | January 1, 2027 – December 31, 2031 |
These models are not especially novel, as they modestly adjust existing programs. However, they are designed to produce the types of fiscal results that some stakeholders, including members of Congress, have called the Innovation Center to focus on.
Not many investors build a long-term strategy on low-risk opportunities alone. As the Innovation Center made additional model announcements, we saw the introduction of 10-year models and even cooperative agreements, which have historically been more difficult to evaluate and taken more time to determine whether they are “successful.”
| Model name | Model dates (in chronological order) |
|---|---|
| Better Approaches to Lifestyle and Nutrition for Comprehensive hEalth (BALANCE) | May 2026 – December 2031 |
| Advancing Chronic Care with Effective, Scalable Solutions (ACCESS) | July 5, 2026 – July 4, 2035 |
| Make America Healthy Again: Enhancing Lifestyle and Evaluating Value-based Approaches Through Evidence (MAHA ELEVATE) | September 1, 2026 – August 31, 2029 |
| Long-term Enhanced ACO Design (LEAD) | January 1, 2027 – December 31, 2036 |
These models are long-term innovation bets where savings are uncertain, measurement is complex, and the real value lies in learning, market shaping, and infrastructure development. The MAHA ELEVATE model is particularly interesting. While the other models were designed to generate savings and improve the quality of care, MAHA ELEVATE clearly exists to incubate future options for Innovation Center model tests. The model also reminds us of the Health Care Innovation Awards (HCIA), one of the first model “tests” that came out of the Innovation Center in 2012. One of the HCIA cooperative agreement awardees implemented the Centers for Disease Control and Prevention’s Diabetes Prevention Program in the first of two rounds of the model. Results from that award led to one of the few Innovation Center models meeting the stringent criteria for expansion under the Section 1115A of the Social Security Act, resulting in the Medicare Diabetes Prevention Program (MDPP) Expanded Model.
Seen through this lens, Innovation Center models fall along a familiar continuum. On one end are the reliable performers, i.e., models that are not especially innovative but produce predictable savings. These stabilize the portfolio of Innovation Center models and demonstrate fiscal discipline. On the other end are the true innovation plays, especially models that test new roles for technology and longitudinal accountability.
In 2025, the Innovation Center also modified several existing models.
| Model name | Model modification |
|---|---|
| ACO REACH | On June 3, 2025, CMS published changes to the ACO REACH model starting in performance year 2026 that are “expected to improve the model test by adjusting the financial methodology to improve model sustainability.” |
| Transforming Episode Accountability Model (TEAM) | On July 31, 2025, CMS published the FY 2026 Inpatient Prospective Payment System and Long-Term Care Hospital Prospective Payment System final rule, which included final updates to TEAM policies. |
| Cell and Gene Therapy (CGT) Access | On July 15, 2025, CMS announced that 33 states, along with the District of Columbia and Puerto Rico, will participate in the CGT Access model. Of these, seven states and the District of Columbia have applied for and been awarded cooperative agreement funding. |
| Achieving Healthcare Efficiency through Accountable Design (AHEAD) | On September 3, 2025, CMS announced new policy and operational changes to the AHEAD model that will be implemented across all cohorts beginning in January 2026. The changes include introduction of a new model component, Geo AHEAD. AHEAD’s performance period for cohorts two and three now begins January 1, 2028, and the end date for all cohorts is now December 31, 2035. |
| Increasing Organ Transplant Access (IOTA) | On December 9, 2025, CMS released a proposed rule that would update and revise IOTA model provisions for performance year two, which will begin on July 1, 2026, and future performance years. |
The nine new models hit many of the key priorities set out by this administration, including:
These models capture a broad range of themes and engage stakeholders from across the healthcare spectrum, demonstrating that the administration chose to cast a wide net rather than focusing on one or two key topics. This overall strategy effectively means that mostly everyone in the healthcare community could be impacted by an existing or new model in 2026 or going forward. As we enter the new year, healthcare innovation is truly all around us.
According to the CMS Innovation Center’s website, 36 models are either active or have been announced. Many models are set to begin in 2026, including TEAM, WISeR, GENEROUS, BALANCE, ACCESS, MAHA ELEVATE, and GLOBE (the latter is proposed and not yet final). While some models with 2026 start dates have begun or will begin soon, a few are still under development, with details that need to be worked out. For example, on December 19, 2025, the Innovation Center released the official request for applications (RFA) for the ACCESS model. Applications are due April 1, 2026 (for the first cohort of participants). While the RFA includes many structural and operational details of the model, it does not include certain financial elements that stakeholders might wish to know before deciding to apply. McDermott+ and McDermott Will & Schulte will host a joint briefing at 3:30 pm EST on January 13, 2026, highlighting key policy design features, operational and financial considerations, and legal and compliance questions that are already emerging from the ACCESS RFA. You are welcome to register for the briefing!
In the next couple of months, stakeholders will also have the opportunity to comment on several models. Comments on proposed changes to the IOTA model are due on February 9, 2026, and comments on the GLOBE and GUARD models are due on February 23, 2026.
We expect the CMS Innovation Center to announce even more models and modifications this year. The administration may decide to introduce more models that align with the themes and priorities captured by the 2025 announcements, especially around lowering drug prices, leveraging new technologies to improve health outcomes, addressing the chronic disease epidemic, and encouraging more specialists to participate in models. The CMS Innovation Center could also explore new areas this year. For example, while CMS focused mostly on Medicare fee-for-service in 2025, the Center did not introduce any models in the Medicare Advantage (MA) space. The MA Value-Based Insurance Design model terminated at the end of 2025, so currently there are no MA models in the CMS Innovation Center portfolio.
At the start of the second Trump administration, the CMS Innovation Center set a goal of announcing 10 new models in 2025, and it achieved that goal (if you count Geo AHEAD)! The pace of new model announcements and model medications has been swift, and we have tried to keep you up to date through Regs & Eggs blog posts, webinars, and +Insights. With even more models on the horizon, we’ll be examining how the models interact with one another, which stakeholders they will impact, and how individuals and organizations can get involved and participate. If you have any questions about any of the CMS Innovation Center models or how they fit together, please reach out!
Until next week, this is Jeffrey (and Simeon) saying, enjoy reading regs with your eggs!
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