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CMS doesn’t have the greatest track record for launching successful and enduring demonstration models, but every healthcare leader should be paying close attention to the forthcoming model known as ACCESS (Advancing Chronic Care with Effective, Scalable Solutions).
Based on my reading, ACCESS is one of the most ambitious models ever introduced by CMS. In fact, I believe it could soon force every hospital and health system to reexamine some fundamental assumptions of their strategic planning – about who their competitors are, how stable their chronic care relationships really are, and what CMS is telling them about the future of Medicare payment.
In a moment, I’ll detail five ways that ACCESS could fundamentally disrupt U.S. healthcare, including the arrival of hundreds of new competitors and a potential shift in the long-running rivalry between Traditional Medicare and Medicare Advantage.
But first, let me be crystal clear about my thesis: Most hospitals will not want to participate directly in the model. For traditional providers with expensive networks and extensive infrastructure, the annual payments being offered simply don’t make sense. A close reading of the ACCESS documentation suggests that CMS is essentially creating a discount competitor for chronic care management. The ACCESS model is purpose-built for digital health companies, not for hospitals and health systems.
The Vision for ACCESS
According to the CDC, chronic diseases and mental health conditions are responsible for 90% of America’s $4.9 trillion in annual healthcare spending. Heart disease alone costs more than $233 billion per year. For chronic kidney disease, the figure is almost $96 billion.
Despite the outsized impact of these chronic conditions, we’ve never been very smart as a nation in our approach to treatment, because Traditional Medicare pays for encounters, such as a doctor’s appointment or a telephone check-in. Critics have long argued that real progress – or backsliding – happens between such engagements, so the traditional payment policy does little to improve outcomes.
CMS, in effect, is now saying that the critics are right: “Continuous support is well-suited to chronic disease management but has been difficult to deliver within traditional visit-based healthcare systems and payment models.” The ACCESS model is designed to get digital health monitoring tools into patients’ homes – and find a way to pay for it.
So, starting on July 5, Traditional Medicare for the first time will directly reimburse health tech companies that offer continuous monitoring and support to patients with chronic conditions. For some 30 million older Americansenrolled in Traditional Medicare, this change could be lifechanging – or even lifesaving.
In a webinar with the American Medical Association, Abe Sutton, director of the CMS Innovation Center, gave the example of a patient with heart disease. Rather than just paying for twice-a-year visits to the cardiologist, ACCESS might provide that patient with a digital blood pressure cuff at home, plus a smartphone app to provide daily nutrition coaching. Using remote data, a provider can titrate the patient’s medications, and any concerns are flagged for a follow-up visit.
Sutton estimates that two-thirds of Traditional Medicare beneficiaries will be eligible to receive this kind of technology-enabled care under the ACCESS model.
The Nuts and Bolts of ACCESS
When the model launches on July 5, 2026, it will cover a range of conditions in four clinical tracks: early cardio-kidney-metabolic (e-CKM); cardio-kidney-metabolic (CKM); musculoskeletal (MSK); and behavioral health (BH). CMS chose these tracks based on factors such as condition prevalence, technology availability, and suitability for outcome-based payment.
Unique to the ACCESS model, CMS will not require any specific approach or treatment in any of the clinical tracks. Instead, each track will simply have an array of outcome metrics, and participants will be paid when (and if)patients show measurable improvement. This represents a huge departure for CMS, which typically takes a much more prescriptive approach with demonstration models.
Outcomes will be published annually and available to the public, so the most effective approaches could scale quickly. The targets do look fairly aggressive: For blood pressure, participants must achieve a 15 mm Hg reduction in systolic pressure or a reading below 130 mm Hg. For diabetes, participants must achieve a full 1 percentage point reduction in HbA1c – meaning a patient at 8.0% must reach 7.0% – a target that sounds modest but proves considerably harder to attain across a diverse, older Medicare population.
Costs and Benefits
Annual payments will range from $180 per beneficiary for MSK and BH tracks to $420 for the highest-acuity CKM track covering diabetes, kidney disease, and cardiovascular disease. A much-anticipated rural add-on turns out to be just $15 per beneficiary, limited to eCKM and CKM tracks only. The add-on may offset device distribution costs in sparsely populated areas, but it won’t do much to incentivize participation by many cash-strapped rural systems.
Those are modest numbers, especially compared to Medicare’s payment rates for chronic care management, or CCM, which we analyzed in depth several years ago. Traditional providers can currently earn roughly $795 per patient per year for monthly phone-based care coordination – with payments reaching $1,731 annually for complex patients. The ACCESS payment is just $180-$420 per patient per year for managing many of the same chronic conditions: diabetes, hypertension, heart disease.
If ACCESS participants successfully manage chronic conditions and achieve the clinical outcomes they're paid for, then downstream spending should fall naturally. Fewer diabetic complications mean fewer amputations and dialysis starts. Better hypertension control means fewer strokes and heart attacks.
That’s good news for more progressive health systems with extensive ACOs or other value-based care arrangements. If a tech partner takes on the risk and burden of managing chronic patients, those hospitals should reap financial rewards based on improved health outcomes for their population. Essentially, these systems would get the benefits of accountable care without having to manage the full actuarial equation.
On the flip side, a successful ACCESS model would have negative revenue implications for hospitals and health systems that treat chronic patients on a fee-for-service basis. Healthier patients need fewer services, undermining the very foundation of the FFS business model.
The Disruptive Nature of ACCESS
It should be clear by now that the ACCESS model is not intended primarily for hospitals and health systems, which typically lack the technology infrastructure for managing personal health devices at scale. In mid-April, when Medicare announced the first 150 provisional approvals for ACCESS participation, only three were traditional health systems.
Instead, the participant list was dominated by health tech companies like Headspace, Cadence, Welldoc, and Withings. “Most organizations have not previously served Medicare beneficiaries,” CMS noted in its press release.
Does that represent a whole new level of competition in healthcare? Absolutely. And it’s just one of the ways that this new model could disrupt healthcare as we know it.
I’ll start with a few observations that might turn out to be broadly positive, pushing healthcare transformation forward in helpful ways. Around the midpoint of this list however, things begin to change, and the potential impacts look decidedly more negative for hospitals and health systems.
First, ACCESS offers a relatively low-risk pathway to expand accountable care relationships in Traditional Medicare.
With Medicare Advantage growth stalling, CMS is nowhere close to its goal of having all Medicare beneficiaries in accountable care arrangements by 2030. Assuming that goal still holds, ACCESS provides an intriguing on-ramp, particularly for TM beneficiaries who've resisted MA enrollment or been underserved by traditional ACOs.
The key difference is that ACCESS participants don't bear downside risk for total cost of care. Unlike ACOs that succeed or fail based on whether they can bend the cost curve across all services – hospital admissions, specialist visits, post-acute care, and more – ACCESS participants are accountable only for achieving improved clinical outcomes in their specific chronic disease track.
This fundamentally lowers the barrier to entry. Digital health startups with strong clinical models but thin balance sheets can participate in outcome-based Medicare payment without needing the actuarial sophistication, stop-loss insurance, or capital reserves required for ACO participation.
Admittedly, this is a somewhat limited definition of “accountable.” But with the clock ticking down to 2030 and millions of seniors not yet enrolled in some form of value-based healthcare, ACCESS looks like a pragmatic and palatable solution.
Second, ACCESS could make Traditional Medicare more competitive with Medicare Advantage.
For years, TM has been competing with one hand tied behind its proverbial back. MA plans attracted millions of new enrollees by dangling inducements such as free gym memberships, dental coverage, and wellness programs – benefits that were forbidden in fee-for-service Medicare.
But ACCESS could help level the playing field because participating organizations can waive patient cost-sharing entirely, and the payment structure includes device costs. That means millions of TM beneficiaries could receive cellular-connected blood pressure monitors, glucose meters, or wearable devices at little or no cost when they enroll in ACCESS programs.
(As to why any provider would distribute technology for free, I’ve predicted for years that smart health devices will be distributed much like mobile phones, where the hardware is heavily subsidized in order to capture new subscribers and their ongoing revenue stream.)
Admittedly, ACCESS is limited to chronic disease management, not the full spectrum of supplemental benefits MA offers. But for millions of seniors managing diabetes, hypertension, or chronic pain, ACCESS could make Traditional Medicare much more attractive.
Third, ACCESS is almost entirely unconcerned with programs and processes, leaving organizations with wide leeway to design pathways that might achieve desired outcomes.
For decades, the CMS Innovation Center has launched demonstration models with explicit hypotheses about what constitutes "better" care delivery – mandating specific care activities, workflows, and structural requirements that participants must implement. Every model I can think of has been prescriptive about the "how" of healthcare delivery.
The ACCESS model flips the script completely. As CMMI Director Abe Sutton explained, the goal was to provide a menu of chronic conditions and then say, “Manage that. Use whatever approaches you need to use. Leverage different technologies that are out there. We're not specifically going through and saying, we'll pay for this one or we'll pay for that one.”
This process-agnostic approach creates an unusual dynamic, but flexibility comes with a trade-off. Call it venture capital meets Medicare payment policy: If your approach doesn't reach the threshold for clinical improvement, then you don't get paid. Outcomes = payment, full stop. Unlike previous models, there will be no credit for effort and no points for a good process.
Fourth, ACCESS is designed to bring a whole new range of service providers into Medicare Part B.
CMS counts more than 10,000 digital health and digital therapeutics companies, and the ACCESS model is specifically designed to create a direct reimbursement pathway for these companies within Traditional Medicare.
Opening up Part B participation in this way sends the strongest possible signal that ACCESS is meant to disrupt business as usual in healthcare delivery. ACCESS participants are required to designate a Medicare-enrolled physician as Medical Director to oversee clinical outcomes and compliance — a guardrail intended to ensure physician oversight.
But that's where the similarities to traditional health systems end. Digital health organizations tend to be narrowly focused and asset light: They don't operate emergency departments, manage complex inpatient units, or navigate the political challenges of employed physician networks. They're built specifically to deliver remote, technology-enabled chronic disease management at scale.
This raises a question that every hospital CFO should be asking right now: If digital health companies successfully capture your chronic disease population – particularly in markets where Amazon One Medical or similar competitors are already gaining ground – what happens to your financial model?
For health systems still heavily dependent on fee-for-service inpatient revenue, the math gets uncomfortable quickly because chronic disease patients are among your highest utilizers. Keeping them healthier is genuinely the right outcome, but if a technology company is successfully managing their conditions, you're looking at fewer complications, fewer admissions, and fewer high-margin procedures. For a system built around inpatient volume, that's not a strategic inconvenience. That's a structural threat.
And finally, ACCESS allows patients to sign up directly for chronic care management services – no referral by a PCP required.
The implications here are significant, and my primary concern is fragmentation of care. Historically, health tech companies had to appeal to providers and health systems: We can make your job easier. We can help improve your ACO's population results. As long as payments flowed through traditional providers, technology vendors had strong incentives to integrate with existing care teams. That structure, however imperfect, encouraged carecontinuity.
ACCESS fundamentally changes this dynamic, allowing health tech companies to enroll Medicare beneficiaries directly and start billing – even if the patient’s PCP has never heard of the company or its technology. With direct-to-consumer marketing, it’s entirely possible that a patient could end up with separate vendors managing their cardiovascular disease, chronic pain, and depression.
This is exactly the kind of fragmented delivery that value-based care was supposed to solve.
To CMS's credit, the model does include some safeguards. To quote from the program’s RFP, participants must communicate with a patient’s PCPs at several key points:
- Care Initiation: Within 10 days of care initiation. Communicates care plan, baseline measures, responsible contact, and initial goals.
- Care Completion: Within 30 days after the end of the 12-month care period, or sooner if the beneficiary disenrolls or transitions care. Summarizes achieved outcomes, medications, and follow-up recommendations.
- Care Escalation: Within 10 days of any transition of the beneficiary to another clinician or care setting due to clinical needs exceeding the scope of ACCESS services.
In practice, that means a minimum of two touchpoints per year – and it’s doubtful that health tech companies will want to drive up their costs by doing more than the minimum. Additional clinical updates are “encouraged but not required,” with the goal of promoting “effective care coordination while minimizing alert fatigue.”
There is no mechanism allowing providers to block or dis-enroll patients from ACCESS programs; they are notified, not consulted. PCPs can bill a co-management fee of roughly $100 per year for reviewing electronic updates and coordinating care adjustments. Will that be enough to ensure meaningful engagement by busy providers juggling 2,000+ patients? Only time will tell.
Conclusion
As we’ve said before, demonstration models have been coming and going for decades. In fact, according to a study by the Congressional Budget Office, out of 49 models implemented and evaluated between 2011 and 2020, only four met the threshold for nationwide expansion.
It's possible that ACCESS will buck that trend. Any model that introduces radical flexibility and major new competition into approximately $1.1 trillion in annual Medicare spending certainly can't be ignored.
But let's be clear about what this model is and isn't. ACCESS is not an opportunity for most hospitals and health systems to participate directly. The per-patient payments are too modest, the outcome targets are aggressive, and the upside doesn't justify the infrastructure investment for organizations carrying the full cost of a traditional health system.
In that sense, ACCESS is more than just a new payment model – it's a signal of where Medicare is headed with chronic disease management. CMS is saying it does not want to continue paying for episodic, encounter-based care. Instead, the agency is signaling a strong move toward in-home technology and continuous monitoring delivered by asset-light competitors who can manage patients at a fraction of a health system's cost structure.
For health systems still heavily dependent on fee-for-service inpatient revenue, that signal deserves serious attention. ACCESS alone won't immediately erode your admissions volume. But if digital health companies successfully manage chronic disease in your market – fewer complications, fewer exacerbations, fewer high-acuity episodes – the downstream impact on inpatient utilization accumulates quietly. By the time it's visible on your income statement, the window for a strategic response has likely narrowed considerably.
For more progressive systems with strong value-based care arrangements, the calculus looks different. A well-structured partnership can offload the technology risk and startup costs of chronic disease management while improving the population health outcomes that drive ACO performance. For employed physician groups already operating under significant financial pressure, co-management fees that seem modest in isolation can provide material relief at scale. A panel of 1,500 Medicare patients generating $150,000 annually is not a solution, but it is a number worth paying attention to.
With the ACCESS model officially launching on July 5, digital health companies will soon come knocking on hospital doors, eager to leverage your referral networks and community relationships to build their patient volume. The question isn't whether this model will change your world overnight. It won't. The question is whether you're reading the signals clearly enough to get ahead of what comes next.
