CMS’ new ACCESS Model (Advancing Chronic Care with Effective, Scalable Solutions) has prompted a noticeable amount of discussion across provider organizations, digital health companies, and policy teams. While ACCESS is not a financial-risk or financial gainsharing arrangement based on the details published thus far, it reflects an increasingly common focus within Medicare: shifting payment toward demonstrated improvements in patient outcomes rather than simply paying for services delivered.
A Model Built Around Clinical Improvement Results
ACCESS is a voluntary, 10-year model beginning July 2026, built for organizations caring for Traditional Medicare beneficiaries with defined chronic conditions. It is important to understand that ACCESS is not a financial-risk model, based on what CMS has released thus far. It does not include financial capitation or cost benchmarks/targets. Instead, participating organizations may earn bonus payments tied to improvements in specific clinical measures, each aligned to one of the model’s four tracks:
- Early cardio-kidney-metabolic risk
- Established cardio-kidney-metabolic disease
- Chronic musculoskeletal pain
- Behavioral health conditions such as depression and anxiety
CMS has outlined the categories of measures that will be used but has not released the final specifications, thresholds, or reporting processes. These will be important for organizations to review once published, since the model depends on documented change in metrics such as blood pressure, HbA1c, lipids, BMI or weight, validated pain and function assessments for MSK, and PHQ-9 or GAD-7 scores within behavioral health.
Providers will have flexibility to use digital monitoring tools, integrated care teams, virtual visits, and other approaches that fit their communities. Incentive payments will hinge on their ability to demonstrate improvement in guideline-based clinical measures.
Model Operations and Interactions with Existing Programs
ACCESS will run nationally from 2026 through 2036. CMS has also explained that the model will interact with ACO REACH and MSSP. For the first two years, outcome-aligned payments will not affect benchmarks or performance-year calculations. Beginning in 2028, CMS will include ACCESS-related expenditures within those existing program calculations.
Data Expectations and Measurement Considerations
Although CMS has not yet finalized the measurement rules, early information makes one point clear: ACCESS relies heavily on clinical data sources rather than claims data. Blood pressure, lab values, PROMs, and functional assessments require consistent clinical documentation, structured data capture, and in many cases device-generated inputs.
Organizations assessing participation should consider whether they have the infrastructure to capture, submit, and track these data types at scale across the patient groups defined by each track.
Why ACCESS Matters for Value-Based Care, Even Without Financial Risk
For the last decade, much of value-based care has revolved around spending targets, attribution methodologies, and the mechanics of actuarial benchmarking. ACCESS lands in a different space. It emphasizes measurable clinical change, particularly for chronic conditions that drive long-term morbidity but often fall outside traditional shared-savings incentives.
That choice is significant for three reasons:
- It expands the definition of “accountability.”
ACCESS signals that clinical outcomes themselves may become more central to future APM design, not simply as quality gates, but as payment-drivers. - It raises expectations for patient-level measurement infrastructure.
The outcomes CMS references—from blood pressure and HbA1c to PROM-based assessments for pain and behavioral health—require reliable clinical, laboratory, and device-generated data. This shifts attention toward capabilities that many organizations are still building. - It reinforces the role of technology-enabled care.
ACCESS effectively encourages teams to rethink care models for chronic illness through digital tools, proactive monitoring, and patient-specific engagement methods.
Risks
The devil lies in the details in terms of how effective this program will be at supporting objectives of the Triple Aim: better health for the population, better care for individuals, and lower total costs.
It wouldn’t be surprising to see short-term cost increases under ACCESS, as organizations invest in efforts to improve clinical measures such as A1C, blood pressure, PHQ-9, and BMI. 
The expectation is that increased preventive care now will translate into delayed or avoided costs later. The key questions are how long it will take for those impacts to materialize—and whether ACCESS’s final design and implementation can effectively guard against potential gaming.
We also anticipate that the program may evolve as early learnings emerge, meaning any strategy developed for ACCESS should remain adaptable to shifting requirements.
Looking Ahead
As CMS finalizes specifications and the sector digests what this model means for day-to-day operations, one takeaway is already clear: ACCESS represents another step toward a system that values demonstrable, patient-level improvement. It encourages organizations to refine the ways they measure clinical progress, coordinate care, and apply digital tools to chronic-condition management.
The Arbital Health team will continue to follow the model closely and help our partners interpret what ACCESS demands, how it functions, and what it requires from a measurement and workflow standpoint—all grounded in the details CMS has made public to date.
Andrew Mackenzie
Chief Science Officer, Arbital Health
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