🚨 DEEP DIVE: The CMS ACCESS Model is the "Subscription for Health" We’ve Been Waiting For....maybe?
Happy Tuesday!
If you read one thing this week, make it this.
Yesterday, the Centers for Medicare & Medicaid Services (CMS) quietly dropped one of the most significant policy shifts for digital health in the last decade. It’s called the ACCESS Model, and if you are building, investing in, or delivering technology-enabled care, this is the signal you have been waiting for.
For years, the industry has been stuck on a "billing code treadmill." We build incredible tools; AI coaching, continuous remote monitoring, predictive analytics, but we are forced to shoehorn them into antiquated Fee-for-Service (FFS) codes that pay for minutes spent rather than health achieved.
With ACCESS, CMS is finally cutting the red tape. They are proposing a model that pays for outcomes, not clicks.
Grab your coffee. Let’s break down exactly what this means for the future of healthtech.
The Friction Point: Why FFS Failed Digital Health
To understand why ACCESS is a big deal, we have to look at the status quo.
Currently, if you want to treat a Medicare beneficiary using digital tools, you are likely relying on Remote Patient Monitoring (RPM) or Remote Therapeutic Monitoring (RTM) codes. These are better than nothing, but they are rigid. They require specific device definitions, minimum data transmission days, and strict time-logging requirements.
The result? Activity-based care. Providers are incentivized to maximize data points and call minutes to ensure reimbursement, even if the patient just needs a passive nudge or an automated intervention. We are maximizing activity, not necessarily efficiency or outcomes.
The Solution: Outcome-Aligned Payments (OAPs)
The Advancing Chronic Care with Effective, Scalable Solutions (ACCESS) Model changes the currency of care.
Instead of billing for every 20-minute increment of time, participating organizations will receive a recurring payment (essentially a subscription fee) to manage a patient’s condition.
Here is the kicker: You only get the full payment if the patient gets better.
CMS is testing Outcome-Aligned Payments (OAPs). This gives providers complete flexibility on how they deliver care. Do you want to use a fancy FDA-cleared wearable? A text-message-based AI coach? A telehealth nutritionist? Go ahead. CMS doesn't care about the method anymore; they care about the metric.
If you can prove that you lowered a patient’s blood pressure or controlled their A1c using a specific tech stack, you get paid. This aligns the financial incentive with the clinical goal: keeping the patient healthy with the least amount of friction.
The Scope: Who is this for?
CMS is not starting small. They are targeting the conditions that drive the vast majority of Medicare spending. The model focuses on Original Medicare beneficiaries with:
- Hypertension: The silent killer.
- Diabetes: The metabolic crisis.
- Chronic Musculoskeletal Pain: A massive driver of opioid use and mobility issues.
- Depression & Anxiety: Recognizing mental health as a core chronic comorbidity.
This is a 10-year voluntary model, meaning CMS is playing the long game. They aren't looking for a quick pilot; they are looking to build a permanent alternative to Fee-for-Service.
The "Tech" in HealthTech
What’s fascinating about the RFA (Request for Applications) details is the language CMS is using. They are explicitly calling for "technology-supported care."
They list examples that would have been unimaginable in a CMS memo ten years ago:
- Wearable devices for continuous monitoring.
- Asynchronous apps for lifestyle coaching.
- Telehealth software for on-demand interaction.
This is a massive validation for the digital health sector. CMS is acknowledging that the future of chronic care isn't a quarterly 15-minute office visit; it’s continuous, data-driven support that lives in the patient’s pocket.
Dr. Matt’s Strategic Analysis: Is this a slam dunk? Not exactly. Here is the nuance you need to consider before you rush to apply
- The Risk of "Outcomes"
"Pay for Performance" is the holy grail, but it is also dangerous. How do you risk-adjust for a patient who is non-compliant regardless of your tech? How do you account for social determinants of health (SDOH) that might spike a patient's blood pressure despite your best algorithm? The ACCESS model will rely on risk-adjusted benchmarks, but the devil will be in the math. If the benchmarks are too aggressive, providers might shy away from the sickest patients, the exact opposite of CMS's goal.
2. The "Co-Management" Opportunity
One of the smartest parts of this model is the coordination with primary care. ACCESS participants (likely specialists or dedicated tech-enabled provider groups) can co-manage patients with a beneficiary's primary care doctor.
- The Opportunity: This creates a business model for "Bolt-on" healthtech companies. You don’t have to replace the PCP; you can be the specialized "hypertension management layer" that plugs into their practice, handling the daily digital grind while they handle the holistic care.
3. The Transparency Engine
CMS plans to publish the risk-adjusted outcomes of participating organizations. This is the "Yelpification" of clinical results. Imagine a world where a PCP can look up a dashboard and see: "Company A controls diabetes in 80% of patients, but Company B only manages 60%." Referrals will flow to the performers.
Timeline & Next Steps
If you are a digital health founder, a forward-thinking provider, or an investor, the clock has started.
- TBD: Request for Applications (RFA) has not yet been released. The specific details on payment rates and risk adjustment will be here (crossing fingers!).
- April 1, 2026: Application Deadline for Cohort 1. This is a tight turnaround.
- July 1, 2026: The program goes live.
My Advice: Start building your consortiums now. Digital health vendors need to partner with provider groups (you'll have to decide who/how to apply). If you have a tool that actually works, meaning it drives clinical results, not just engagement, this is your moment to shine.
We are moving from the era of "Digital Health" to just "Health"; efficient, scalable, and paid for by results.
🔗 Explore the Official CMS ACCESS Model Page
Until next week #StayCrispy,
Dr. Matt




