On December 19, 2025, the Centers for Medicare & Medicaid Services (CMS) Innovation Center released the official request for applications for the Advancing Chronic Care with Effective, Scalable Solutions (ACCESS) model. ACCESS is a new 10-year voluntary model that introduces outcome-aligned payments (OAPs) for technology-enabled chronic care prevention and management in original Medicare.
ACCESS is designed to expand beneficiary access to digital and virtual care models by replacing traditional fee-for-service (FFS) billing with fixed recurring payments tied directly to measurable clinical outcomes. CMS contemplates participation by digital health companies, virtual care organizations, and technology-enabled provider groups that can manage selected conditions at scale.
Webinar | ACCESS explained: What CMS’s new model could mean for digital health
Join McDermott+ and McDermott Will & Schulte for a joint briefing highlighting key policy design features, operational and financial considerations, and legal and compliance questions that are already emerging from the RFA.
LEARN MORE & REGISTER
Key highlights for potential applicants
- CMS will assess ACCESS applicants on prior patient volume across all lines of business, with attention to Medicare-eligible populations specifically, and geographic reach, likely favoring participants that demonstrate operational readiness and ability to scale.
- Applicants will need to enroll in Medicare Part B prior to executing a participation agreement with CMS. CMS will not provide flexibility on provider/supplier enrollment for purposes of the model, which may present a challenge to some digital health companies.
- OAPs will be monthly and will be subject to partial withholds and adjustments reconciled to clinical performance. While the request for applications does not include a detailed financial methodology or final OAP rates, it’s clear that CMS will try to structure targets and adjustments to encourage early participation and market entry. CMS plans to release payment rates and related model methodology in advance of the April 1, 2026, initial application deadline.
- ACCESS participants and affiliated entities may not bill any Medicare FFS claims for aligned beneficiaries during active care periods, which will materially shape partnership decisions.
- ACCESS beneficiaries may also be aligned to accountable care organizations (ACOs). ACCESS G-code spending will be treated like FFS expenditures for ACO reconciliation. CMS is considering (but has not committed to) temporary exclusion of ACCESS spending from ACO benchmarks in year one, which appears to be a slight tempering of expectations based on previously issued information.
- CMS will use beneficiary-level randomization (90:10 intervention-to-control initially and subject to future adjustment). This randomized control trial approach is notable and uncommon for Innovation Center models, signaling CMS’s need for strong statistical power to determine ACCESS’s impact and attribute outcomes to the model’s interventions. Control group beneficiaries are excluded from participation for 12 months.
- CMS anticipates that Medicare Advantage, Medicaid, and commercial payers could adopt ACCESS billing codes, data standards, and care models over time.
The full breakdown of the ACCESS model is for McDermott+ clients and McDermott+ Insider subscribers only; please contact your relationship consultant with questions. For inquiries, please contact info@mcdermottplus.com.
