ACCESS Model Outcomes Payment: What MAHA ELEVATE Changes for Medicare and Care Teams
- Ernie Ianace, CEO
- Dec 18, 2025
- 6 min read
Two new CMS Innovation Center initiatives are easy to lump together as “more value-based care.” That framing misses what is novel here.
ACCESS is an outcomes-aligned payment pathway inside Original Medicare that pays recurring installments for managing qualifying chronic conditions, with full payment tied to measurable improvement or control.
MAHA ELEVATE is a federally funded evidence engine. It uses cooperative agreements to generate cost and quality data on whole person functional and lifestyle medicine interventions that are not currently covered by Original Medicare, explicitly as a support to conventional care rather than a replacement.
Together, they point to a single operating reality for health systems, physician groups, and technology-enabled care organizations.
Clinical improvement is becoming a billable product, and measurement infrastructure is becoming clinical infrastructure.
What ACCESS really changes
ACCESS Model Outcomes Payments are not a capitation model, nor is it a shared savings overlay. CMS is testing whether it can pay for improvements in chronic disease directly, using outcomes tied to a patient’s starting point rather than fee-for-service activities.
The mechanics that matter to leaders
1. Four clinical tracks with guideline-informed targets
ACCESS starts with four tracks: early cardio, kidney metabolic, cardio kidney metabolic, musculoskeletal chronic pain, behavioral health, depression, and anxiety.
Measures are track-specific and are anchored in the improvement or control of biomarkers and in validated patient-reported outcome measures for pain, mood, and function.
2. Payment follows outcomes, not minutes or modalities
Participants receive recurring Outcome-Aligned Payments for managing a patient’s qualifying condition, with payments tied to achieving measurable health outcomes.
This matters because it reframes what must be operationalized. The core capability is no longer “do we have RPM codes?” The core capability is “can we produce defensible improvement at scale, repeatedly?”
3. Care coordination is built in, with a new co-management payment
ACCESS is designed to complement traditional care. Referring clinicians receive electronic updates, and CMS indicates PCPs and referring clinicians may bill a new co-management payment for documented review and coordination actions, such as medication changes or problem list updates.
CMS also describes practical requirements for electronic updates and integration with a health information exchange or similar trusted network.
4. Public reporting and market selection are part of the model design
CMS intends to publish aggregated, risk-adjusted results and maintain a directory of participating organizations, including the conditions they treat and their outcomes, shaping referral patterns over time.
This creates a new layer of reputation and competition. Outcomes performance becomes visible, not just contractually relevant.
5. Interaction with MSSP and ACO REACH is explicit and time-bound
CMS anticipates no impact from ACCESS Outcome Aligned Payments on ACO benchmark and performance year calculations for MSSP and ACO REACH in 2026 and 2027. Beginning in 2028, ACCESS OAP expenditures are expected to be included.
For executives running ACO portfolios, this is a sequencing signal: early years are about capability building, later years are when financial feedback loops tighten.
What MAHA ELEVATE really is
MAHA ELEVATE is not a coverage expansion, at least not yet. It is a structured way for CMS to fund up to 30 cooperative agreements, with a total budget of about $100M over three years, to collect cost and quality evidence on whole person functional or lifestyle medicine interventions not currently covered by Original Medicare.
CMS will release a Notice of Funding Opportunity in early 2026, and the model launch is scheduled for September 1, 2026, with two cohorts starting in 2026 and 2027.
Several details are operationally important:
Interventions must support, not replace, conventional care.
Proposals must incorporate nutrition or physical activity.
Three awards are reserved for interventions that address dementia.
CMS is selecting organizations that can measure impact and report data in a timely manner, while safeguarding beneficiaries.
Eligible applicants explicitly include senior living communities, alongside health systems, ACOs, community-based organizations, and others.
For leaders, MAHA ELEVATE is best understood as “evidence production at federal scale.” It is a mechanism to turn promising lifestyle and functional approaches into a coverage or payment conversation backed by Medicare-relevant data.
The shared requirement: an end-to-end outcomes loop
ACCESS and MAHA ELEVATE differ in their instruments, but converge on one requirement: a closed-loop system that turns measurement into action and action back into evidence.
That loop has five non-negotiable components.
1. Structured baseline capture with provenance
Outcomes models rise or fall on the baseline. If the starting point is inconsistent, unstructured, or not attributable, the rest is noise.
Organizations need a rigorous approach to:
Baseline timing and repeatability
Device source and identity binding
Unit normalization and reference ranges for labs
Validated PROM selection and administration cadence
Attribution to the correct cohort, track, and episode window
CMS is explicit that baseline measures become the benchmark for tracking improvement or control, and that payment is tied to outcomes relative to that starting point.
2. Clinical operations that are protocol-driven but clinician-governed
Outcomes do not improve because data is collected. Outcomes improve because clinical teams act earlier, more consistently, and with tighter follow-through.
That requires protocols that specify:
Who reviews which signals, when, and at what thresholds
What escalation looks like clinically and operationally
How medication titration decisions are documented
How care plans change and how patient education is delivered
How “failure to engage” is handled without biasing measurement
ACCESS requires that technology-supported care remains clinician-guided and coordinated, with a designated physician Clinical Director responsible for oversight and compliance.
3. Interoperability that writes evidence back into the record
In both models, value accrues to the organizations that can document improvement as structured data and share it across the care continuum.
CMS describes secure interoperable systems and electronic updates to referring clinicians, including integration with HIEs or trusted networks.
For most organizations, this means solving the unglamorous parts of interoperability:
Discrete results ingestion, not PDFs
Identity resolution across portals, devices, and EHR
Event driven updates, not periodic summaries
Reconciliation logic for conflicting readings
Workflow that makes documentation the byproduct of care, not extra work
4. Auditability and safeguards that reduce gaming risk
When payment is tied to measurable improvement, predictable failure modes emerge:
Selective enrollment of easier patients
Baseline manipulation or timing arbitrage
Missingness bias, where “harder” patients stop reporting
Device spoofing and unverifiable readings
PROM coaching that changes answers, not outcomes
CMS is already leaning into risk adjusted reporting and safeguards, including monitoring and the ability to terminate organizations that fail to meet quality, safety, or outcome standards.
Leaders should assume auditability requirements will harden over time. Build provenance and controls early, rather than retrofitting under scrutiny.
5. A patient experience that increases adherence without increasing burden
ACCESS and MAHA ELEVATE both rely on behavior change and sustained engagement. That is not a marketing problem. It is a workflow and design problem.
The winning patient experience will be:
Simple daily routines
Low friction data capture
Contextual coaching that is consistent with clinician plan
Escalations that feel supportive, not punitive
Clear consent and transparency
A pragmatic C-suite agenda for 2026
If you are preparing for ACCESS participation, MAHA ELEVATE application, or both, this is the most practical sequencing:
Pick one track to operationalize end-to-end first. Build depth, not breadth. ACCESS allows multiple tracks, but operational maturity matters more than coverage.
Stand up an outcomes data product team. This is not just analytics. It is clinical operations plus informatics plus compliance plus interoperability.
Define your minimum viable evidence packet. For each measure: source, cadence, validation, storage, and how it is shared back to the EHR and referring clinicians.
Model the financial timeline honestly. Outcomes work often increases near-term costs before downstream utilization falls. Ensure your board understands the lag and what leading indicators you will report.
Align ACO leadership early especially because ACCESS OAP expenditures are expected to be included in MSSP and ACO REACH benchmark calculations starting in 2028.
Where CareAlly and AgeWellAlly fit, with minimal marketing
Most organizations do not fail because they lack clinicians or devices. They fail because they lack an orchestration layer that connects measurement, action, and documentation across roles, systems, and settings.
CareAlly is designed to be that orchestration layer. It uses persona-based AI workflow orchestration to route work to the right clinical and operational roles, integrates via API-first connectors to EHRs and enterprise tools, including Slack, Teams, Salesforce, Smartsheet, HubSpot, Office, Google, and Apple, and operates within HIPAA boundaries with support for local de-identification models. In practice, this enables outcome-driven protocols to run reliably while keeping protected health information within boundaries.
AgeWellAlly is the complementary engagement and coordination layer for patients at home and residents in senior living communities. It supports simple daily agenda-driven routines, PROM capture, and shared care artifacts that reduce data missingness and improve adherence, which is often the hidden constraint in outcomes programs.
In an outcomes economy, orchestration is not a feature. It is the operating system.
Why ACCESS Model outcomes payment matters at Medicare scale
Medicare spending pressures are not abstract. Medicare benefits spending has been projected to grow from roughly $829B in 2021 to about $1.8T in 2031. CMS and MedPAC have also emphasized that total Medicare spending is on a trajectory to roughly double over a decade, rising from over $900B in 2022 to about $1.8T in 2031.
ACCESS and MAHA ELEVATE are two different bets on the same premise: if Medicare can pay for actual improvement and build a credible evidence base for interventions that change behavior and function, the system can bend the curve without rationing care.
The organizations that win will be the ones that treat outcomes measurement, interoperability, and protocolized care operations as a single integrated capability, not a collection of programs.
Here are the official CMS pages as clickable links:
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