ACCESS Model Update: Critical Technical Requirements Now Clear
The 10-year ACCESS program finally aligns Medicare payment with outcomes-focused care. Learn what it means for your organization and how to prepare.
Last updated: January 15, 2026 | We'll continue updating this guide as CMS releases more details about ACCESS requirements and reporting.
Applications opened this week, and the CMS Technical FAQs have clarified several make-or-break technical requirements that weren't explicit in the RFA. If you're preparing an application due April 1, read this first.
Blood Pressure Data: The Most Restrictive Technical Requirement
For eCKM and CKM tracks, blood pressure collection has strict technical requirements that will disqualify manual data entry:
✅ Required: Validated upper-arm cuff devices with timestamped, source-verifiable transmission
❌ Prohibited: Manual entry, patient-reported values, or unverifiable data
📊 Standard: Each submission must average 3+ readings per 2025 AHA/ACC guidelines
What this means for Healthie customers: Your RPM device integrations need to support automated data transmission with audit trails - not just display. If you're currently using manual BP entry workflows, you'll need to transition to connected devices. Check our Devices & Integrations documentation to confirm your BP cuff supports source-verifiable transmission, or contact our team to identify compatible devices.
Pro tip: Set this up and test it before you apply. CMS will ask about your technical infrastructure in the application.
How ACCESS Payments Actually Work (50/50 Split Model)
CMS has clarified the payment mechanics that affect cash flow planning:
💰 During the Care Period (Months 1-12):
- 50% of annual OAP paid quarterly as care is delivered
- 50% withheld pending performance reconciliation
📊 Performance Reconciliation (After Month 12):
- Calculate your Outcome Attainment Rate (OAR): % of patients meeting ALL required outcome targets
- Compare to Year 1 threshold: 50%
- If OAR ≥ 50%: Receive full withheld payment
- If OAR < 50%: Receive proportional payment (OAR ÷ 50% × withheld amount)
- Maximum reduction: 50% of total annual OAP
Additional adjustment: Substitute Spend (up to 25% reduction if patients receive duplicative services from other Medicare providers)
Financial planning note: Budget for 50% payment during the care period. Don't count on the withheld 50% until performance is reconciled. Organizations with tight cash flow should plan accordingly.
Mandatory Care Coordination: Not Optional, With Deadlines
ACCESS requires electronic transmission of care updates to PCPs/referring providers on specific timelines:
Care Initiation: Within 10 days of enrollment --> Care plan, baseline measures, goals, contact info
Care Completion: Within 30 days of period end --> Outcomes achieved, medications, follow-up recommendations
Care Escalation: Within 10 days of transition --> Details when needs exceed ACCESS scope
Transmission methods: Direct Secure Messaging, HIE-supported push, or HIPAA-compliant exchange Templates: CMS will provide standardized templates with required fields
In Healthie: Use Metrics to document required elements, and secure messaging or our Interoperability capabilities for transmission. Consider setting up workflow reminders for 10-day and 30-day deadlines.
Data Quality Standards: CLIA, CDC, NGSP Required
CMS has specific standards for where data can originate:
Lab Results:
- Must come from CLIA-compliant sources
- Lipids: CDC-standardized assays (LSP/CRMLN)
- HbA1c: NGSP-certified methods only
Patient-Reported Outcome Measures:
- Zero tolerance for modifications to validated instruments
- Must preserve exact wording, response options, order, and layout
- Collection systems must capture all items, prevent invalid responses, allow backward navigation, show progress indicators, include final save/submit confirmation
In Healthie: Our Forms library includes validated assessments (PHQ-9, GAD-7) with preserved instrument integrity. For lab results, use our API to connect with CLIA-compliant lab partners, or create custom metrics for manual entry with source documentation in charting notes.
Patient Exclusions Are Extensive (Screen Carefully)
ACCESS has detailed exclusion criteria that vary by track. Key exclusions many orgs miss:
eCKM/CKM exclusions include:
- Severe heart failure (NYHA Class III-IV)
- Active unstable angina
- CKD Stage 4 or higher (CKM allows Stage 3a/3b only)
- Moderate-to-severe dementia
- Patients 81+ with frailty indicators
- Nursing home residents 66+
BH exclusions include:
- Active suicidal/homicidal ideation
- Psychotic features (schizophrenia, bipolar I, major depression with psychosis)
- Severe eating disorders
MSK exclusions include:
- Inability to bear weight on affected area
- Recent surgery/trauma to affected area
- Severe arthritis requiring joint replacement
- Unstable fractures
- Pain from non-MSK causes (neuropathy, vascular disease)
Clinical workflow note: Build screening questions into your intake forms to flag excluded patients before enrollment. CMS will audit clinical eligibility.
FHIR R4 APIs: Four Required CMS Integrations
Your technical team needs to integrate with four CMS-hosted FHIR R4 APIs:
- ACCESS Eligibility API - Verify beneficiary Medicare coverage before enrollment
- ACCESS Alignment API - Submit prospective beneficiary enrollments
- ACCESS Reporting API - Submit outcomes data following Person-Centered Outcomes (PCO) HL7 FHIR Implementation Guide specifications
- Beneficiary Claims Data API (BCDA) - Receive Parts A, B, D claims for care coordination
Technical standards:
- Must comply with federal API certification criteria (45 CFR § 170.315(g)(10))
- Must support most recent USCDI version
- Note: CEHRT certification (42 CFR 414.1305) is NOT required - different from many CMS programs
In Healthie: Our API documentation and Interoperability capabilities support FHIR R4. For CMS-specific API integration, contact our team to discuss implementation options - some customers may need custom development through our API depending on their technical resources.
Action Items (If Applying by April 1)
☐ Audit your BP monitoring devices - confirm source-verifiable transmission capability
☐ Review patient population against exclusion criteria - calculate how many would actually qualify
☐ Map your current outcome tracking to CMS requirements - identify gaps
☐ Meet with technical team about FHIR API integration timeline (12-16 weeks typical)
☐ Calculate cash flow impact of 50/50 payment split
☐ Design care coordination workflow with 10-day and 30-day trigger points
☐ Confirm CLIA compliance of lab partners
Additional Resources: 📄 CMS ACCESS Model Overview 📄 Full Request for Applications (PDF) 📄 CMS ACCESS Technical FAQs
ACCESS Model Update: Applications Open January 12
Published January 5, 2025
The 61-page Request for Applications is live, and major medical associations have formally endorsed the model. First cohort applications open January 12, 2026, with a deadline of April 1 and program launch July 5.
Here's what's new—and how to set it up in Healthie.
Outcome Tracking: What CMS Requires
ACCESS pays for improvement, which means CMS needs structured outcomes data. They've defined exactly what you need to measure by track:
Track & Required Measures
eCKM: Blood pressure, LDL-C, weight, HbA1c
CKM: All eCKM measures + eGFR, UACR (kidney function)
MSK: BPI-SF, QuickDASH, LEFS, ODI, NDI
Behavioral Health: PHQ-9, GAD-7, WHODAS 2.0
In Healthie:
- Clinical metrics (BP, weight, HbA1c, labs): Use Metrics to track values over time. Set baseline at intake, monitor trends across the care episode. You can also create custom metrics for lab values like eGFR and UACR.
- Validated assessments (PHQ-9, GAD-7): These are built into Healthie's Forms library with auto-scoring. Assign at intake for baseline, reassign at intervals to track improvement.
- MSK PROMs (QuickDASH, ODI, NDI, LEFS): Build these as custom scored forms. Reach out to our team if you need templates.
- Pro tip: Create a charting template for each ACCESS track that prompts providers to document required measures at every visit.
Remote Monitoring: Required for Cardiometabolic Tracks
For eCKM and CKM, connected devices aren't optional—they're how you'll capture biometric data. Blood pressure cuffs, glucose monitors, and weight scales.
In Healthie:
Healthie integrates with wearables and RPM devices, including Fitbit, Apple Health, Withings, Dexcom, and others. Device readings flow into the client's Metrics tab automatically.
For additional RPM vendors, check our Integrations Marketplace or use our API to connect your existing platform.
Interoperability: The Technical Bar Is High
CMS requires FHIR-based APIs meeting federal standards and Health Information Exchange connectivity within 12 months of participation.
In Healthie:
Healthie's API-first architecture supports the data exchange standards CMS requires. Review our Interoperability documentation for FHIR, HL7, CCDA, and Direct Messaging capabilities.
For specific ACCESS interoperability questions, reach out to our team.
Care Delivery: Use What You're Already Using
ACCESS doesn't prescribe how care happens—virtual, in-person, async, group-based. It pays for outcomes. Your existing Healthie workflows apply:
- Telehealth for virtual visits
- Programs for structured content and async engagement between sessions
- Secure messaging for ongoing patient communication
- Scheduling for appointment management
- Client Portal for patient engagement and self-tracking
You don't need to change how you deliver care. You need to make sure you're documenting outcomes consistently.
In Healthie: Use Payments and Insurance billing to track ACCESS-related revenue separately from other payer sources.
Strategic Note: ACO Overlap
If your patients are attributed to ACOs:
- 2026-2027: ACCESS payments won't impact MSSP or ACO REACH benchmark calculations.
- Starting 2028: ACCESS expenditures will be included in ACO benchmarks. ATI Advisory notes this is "especially important if the ACCESS Organization is not controlled by the ACO."
Your Pre-Application Checklist
Where in Healthie
☐ Set up outcome tracking for your track's required measures
☐ Build or customize charting templates for ACCESS visits
☐ Confirm device integrations are flowing data correctly
☐ Review API/interoperability capabilities
☐ Confirm Medicare Part B enrollment status
External—CMS PECOS
☐ Identify your Clinical Director (MD/DO required)
Internal staffing decision
☐ Read the full RFA
Key Dates & Milestones
January 12, 2026: Applications open
April 1, 2026: Application deadline for first cohort
July 5, 2026: First cohort begins
October 1, 2026: Late applications considered for January 2027 start
June 30, 2036: Model ends
Still Watching For
CMS has indicated these details are coming in 2026 but hasn't released them yet:
- Specific OAP payment rates by track
- Risk adjustment methodology details — CMS has signaled risk-adjusted outcomes and public reporting but hasn't specified the approach.
- G-codes and billing guidance for co-management payments — Per CMS FAQs: "The ACCESS Co-Management Payment G-code, modifier, and additional billing guidance will be shared in 2026."
- Performance thresholds beyond Year 1 — CMS says minimum thresholds "increase with each participation year" but hasn't published the ramp-up schedule.
We'll update this post when CMS releases the above.
Resources
📄 Full Request for Applications (PDF)
📄 December 4, 2025 HHS-CMS Event Recording
Questions about ACCESS readiness? Reach out to our team or talk to your Customer Success Manager.
Medicare's New ACCESS Model: What It Means for Tech-Enabled Care (And How Healthie Can Help)
Published December 5, 2025
If you deliver tech-enabled chronic care, you probably heard the news: CMS just announced a massive Medicare opportunity for digital health.
The ACCESS Model (Advancing Chronic Care with Effective, Scalable Solutions) is a 10-year program that finally creates a real Medicare payment pathway for the kind of care our customers deliver every day: longitudinal, technology-supported, outcomes-focused care for people living with chronic conditions.
We're here to help you understand what it means and how to take advantage of it.
The Big Picture: Why ACCESS Matters
Here's the problem ACCESS is solving: Medicare has never had a great way to pay for tech-enabled care.
Traditional Medicare pays for activities - a visit here, a procedure there. But that's not how modern chronic care works. When you're helping someone manage diabetes, hypertension, anxiety, or chronic pain, you're building a relationship over months and years. You're using apps, remote monitoring, coaching, and virtual check-ins. You're focused on outcomes - did their blood pressure improve? Are they feeling less anxious?
ACCESS flips the script. Instead of billing for each individual touchpoint, participating organizations receive recurring payments tied to actually improving patient health. CMS is calling these "Outcome-Aligned Payments" - and they're exactly what they sound like: get paid for getting results.
The conditions covered affect roughly two-thirds of all traditional Medicare beneficiaries. That's a massive population that can now access the kind of technology-supported care that's been transforming commercial and Medicare Advantage markets.
What Conditions Are Covered?
ACCESS focuses on four clinical tracks:
🫀 Early Cardio-Kidney-Metabolic (eCKM) For earlier-stage conditions: hypertension alone, OR two or more of the following: high cholesterol, obesity/overweight, or prediabetes. This track focuses on prevention and stopping progression before conditions become more serious.
🫀 Cardio-Kidney-Metabolic (CKM) For more established conditions: diabetes, chronic kidney disease (Stage 3a/3b), or cardiovascular disease. Outcomes measured include blood pressure, HbA1c, cholesterol, weight, and kidney function.
🦴 Musculoskeletal (MSK) Chronic pain lasting more than 3 months. Outcomes are measured through validated patient-reported assessments of pain and function.
🧠 Behavioral Health (BH) Depression and anxiety. Outcomes are measured using standard tools like PHQ-9 and GAD-7.
The two CKM tracks are actually a smart design choice by CMS - it means organizations can work with patients at different stages of their health journey, from early intervention (eCKM) through more complex chronic disease management (CKM).
If your organization delivers care for any of these conditions - whether that's diabetes management, virtual MSK programs, behavioral health support, or integrated chronic care - ACCESS creates a pathway to sustainably serve Medicare patients.
Key Dates to Know
Applications open: January 12, 2026
First cohort application deadline: March 20, 2026
First cohort launches: July 1, 2026
The program runs through: June 30, 2036
The January 12, 2026 date is approaching quickly! If you're interested in participating, now is the time to start preparing.
What Does CMS Require? (The Short Version)
We're still waiting for CMS to release the full Request for Applications with all the details. But here's what we know so far about what participating organizations will need:
- A physician Clinical Director – Every ACCESS participant needs a Medicare-enrolled MD or DO overseeing clinical quality and compliance.
- Outcomes tracking and reporting – You'll need to capture baseline health data for each patient, track their progress, and report outcomes to CMS through their APIs.
- Interoperability with primary care – ACCESS is designed so tech-enabled care complements the patient's primary care relationship, not replaces it. You'll need to share care plans and updates with referring providers through secure, electronic means.
- Flexible care delivery – Good news: CMS isn't mandating how you deliver care. Virtual, in-person, asynchronous, app-based – use whatever approach works best for your patients and your model.
How Healthie Supports ACCESS Participation
Here's the thing: ACCESS isn't asking for anything new from Healthie customers. The model rewards exactly what our platform was built to do — longitudinal, outcomes-focused, technology-enabled care delivered by collaborative care teams.
Healthie already powers 40,000+ clinicians supporting 15+ million patient lives across behavioral health, nutrition, chronic disease management, and more. We're ONC-certified, HIPAA and HITRUST compliant, and API-first by design. When CMS describes what ACCESS participants need, they're describing what Healthie customers already have.
📊 Track Outcomes From Day One
ACCESS pays for results, which means you need to measure them. Healthie's Goals and Metrics let you set clinical targets (blood pressure, weight, HbA1c) and track progress over time. Our Forms and Assessments capture the validated patient-reported outcome measures ACCESS requires—PHQ-9, GAD-7, pain scales, functional assessments—and tie them directly to the patient record. No spreadsheets, no workarounds. Baseline to outcome, all in one place.
📱 Integrate Remote Monitoring Seamlessly
For CKM and eCKM tracks, especially, connected devices are table stakes. Through Healthie's API and our Harbor marketplace of 70+ integrations, blood pressure cuffs, glucose monitors, weight scales, and other RPM devices feed data directly into patient charts. Your care team sees the full picture without toggling between systems.
🤝 Collaborate Across Care Teams and Share Data With PCPs
ACCESS is built around coordination — tech-enabled care that works with primary care, not around it. Healthie's API-first architecture supports the interoperability ACCESS demands. Our platform is designed for multi-provider, multi-disciplinary care teams, with shared records, task assignment, and internal messaging that keeps everyone aligned. When CMS says you need to share care plans electronically with referring providers, Healthie's infrastructure is ready.
💬 Deliver Care However It Works Best
Virtual visits. Async messaging. Coaching programs. In-person sessions. Patient apps. ACCESS doesn't prescribe how care happens—and neither does Healthie. Our telehealth, chat, Programs (our built-in LMS), and patient engagement tools give you the flexibility to design care models that actually work for your patients. Whether someone needs a weekly video check-in or daily app-based support, you can build it in Healthie.
📋 Stay Compliant Without the Overhead
Medicare programs mean documentation requirements. Healthie's EHR, charting, and scheduling tools keep your clinical team focused on patients while capturing what you need for compliance and reporting. We're HIPAA, HITRUST, SOC-2 Type 2, and ONC certified — the compliance foundation that Medicare participation requires.
🚀 Scale Without Rebuilding
ACCESS is a 10-year program. Organizations that participate will need technology that can grow with them, from the first cohort to a national scale. Healthie's platform already supports organizations ranging from solo practitioners to enterprise digital health companies. Our infrastructure is built to scale, and our API means you're never locked into a single way of doing things.
Bottom line: If you're considering ACCESS, you don't need to rip and replace your tech stack or build custom infrastructure from scratch. Healthie customers are already operating on a platform designed for outcomes-focused, longitudinal, tech-enabled care. ACCESS is just Medicare finally catching up to the way care should be delivered.
Who Should Consider ACCESS?
ACCESS is a strong fit for organizations that:
✅ Already deliver tech-enabled chronic care (diabetes programs, virtual MSK, behavioral health, etc.)
✅ Have an outcomes-focused care model (not just billing for activities)
✅ Want to expand into Medicare fee-for-service (beyond just Medicare Advantage)
✅ Can designate a physician Clinical Director
✅ Have (or can build) infrastructure for outcomes tracking and data sharing
If that sounds like you, ACCESS could be a game-changer. And if you're a Healthie customer, you're already on a platform designed for this moment.
What's Next?
We'll keep updating this guide as CMS releases the Request for Applications, technical specifications, and payment details. There's still a lot we don't know - like exact payment amounts per track and specific reporting requirements - but we'll break it down as soon as the information is available.
In the meantime, here's what you can do:
- Review your current capabilities - Can you track outcomes? Share data with other providers? Capture patient-reported measures?
- Consider Medicare Part B enrollment - If you're not already enrolled, you'll need to be (or partner with an organization that is). This process takes time.
- Talk to your Healthie team - We're here to help you think through how your Healthie setup can support ACCESS participation.
Learn More
Have questions about how Healthie can support your ACCESS preparation? Reach out to our team - we'd love to help you navigate this exciting opportunity.
About Healthie: Healthie powers healthcare outside the hospital. Our EHR, telehealth, and patient engagement platform supports over 40,000 clinicians delivering longitudinal, collaborative care to 15+ million patient lives. From behavioral health to nutrition to chronic disease management, Healthie is the infrastructure for tech-enabled care at scale.
