ACCESS Unlocked: How CMS Just Solved Digital Health's Billion-Dollar Reimbursement Problem

IMC Board
Dec 17, 2025
8 min read

Will digital health finally get the payment structure it deserves?

Key Takeaways:

CMS's ACCESS Model introduces outcome-based payments for technology-enabled chronic care, addressing a longstanding reimbursement gap in digital health
The 10-year voluntary program targets conditions affecting two-thirds of Medicare beneficiaries including diabetes, hypertension, and behavioral health issues
Over 500 technology-enabled care organizations have expressed intent to apply, signaling strong industry interest
The model waives beneficiary copayments and allows direct patient enrollment, removing traditional barriers to adoption
Program applications open January 2026, with the first cohort launching July 1, 2026

Health technology companies have long faced a brutal paradox. They develop innovative solutions that improve patient outcomes and reduce costs. And yet they struggle to get paid because Medicare's traditional fee-for-service model wasn't designed for digital care delivery.

That may be changing, however.

The new Advancing Chronic Care with Effective, Scalable Solutions (ACCESS) program from the U.S. Centers for Medicare & Medicaid Services (CMS) will be testing an outcome-aligned payment approach in Original Medicare. The goal is to expand access to technology-supported care options that help people to manage chronic conditions. This program represents a fundamental shift from paying for activities to paying for results.

Payment Problem Holding Digital Health Back

Traditional Medicare reimbursement creates significant obstacles for digital health companies. The methodology used to determine payment amounts generally treats digital health technologies as overhead rather than allocating costs directly to clinical services, resulting in chronic underpayment for technology-intensive care.

This has consequences beyond just business viability. Without clear reimbursement pathways, promising technologies that successfully obtain authorization from the U.S. Food and Drug Administration (FDA) often fail to reach patients who need them.

The stakes are high. Digital technologies are transforming health care delivery, helping people to manage chronic conditions with continuous support beyond the doctor's office through telehealth software, wearable devices, and coaching apps.

How ACCESS Changes the Game

ACCESS introduces what CMS calls outcome-aligned payments. Instead of billing for visits or time spent on care management, providers receive recurring payments based on whether patients achieve defined clinical improvements.

The model breaks from traditional Medicare reimbursement in critical ways that address longstanding barriers to digital health adoption.

Payment Tied to Results, Not Activities

With ACCESS, organizations get paid when patients hit specific health targets, not for the volume of services delivered. Payment depends on the overall share of patients who meet defined outcomes, compared to a minimum threshold that increases with each participation year.

This performance-based approach creates accountability while rewarding genuine clinical impact. If a technology doesn't deliver measurable improvements, the organization doesn't get paid regardless of how much care coordination or monitoring occurred.

Four Clinical Tracks Covering Medicare's Biggest Cost Drivers

The ACCESS program initially covers four areas in which chronic conditions are most prevalent and that improved management can significantly reduce downstream complications:

Early cardio-kidney-metabolic conditions—Hypertension, high cholesterol, prediabetes, and obesity, catching these conditions before they progress to more serious disease
Established cardio-kidney-metabolic conditions—Diabetes, chronic kidney disease, and cardiovascular disease, managing advanced conditions to prevent hospitalizations and further deterioration
Musculoskeletal conditions—Chronic pain, addressing a major driver of opioid use and disability
Behavioral health conditions—Depression and anxiety, tackling mental health issues that often complicate physical health management

These four tracks target conditions affecting approximately two-thirds of Medicare beneficiaries. The breadth of coverage creates multiple entry points for different types of technology vendors.

Direct Patient Access without Provider Gatekeeping

Unlike traditional Medicare payment models, ACCESS allows Medicare beneficiaries can enroll directly without requiring their existing provider to participate first. This represents a fundamental shift in how Medicare thinks about patient choice in care delivery models.

Traditional models require providers to opt in, and then patients access services through participating providers. ACCESS flips this dynamic, allowing patients to seek out technology-enabled care independently. This change signals CMS's recognition that patients should have agency in selecting digital care options that fit their preferences and lifestyles.

No Patient Copayments Creating a Zero-Barrier Entry Point

CMS will waive the copayment for ACCESS services, addressing a recurring request from remote monitoring providers and removing a significant financial barrier for beneficiaries. This is especially important for chronic care management, which requires ongoing engagement rather than episodic intervention.

When patients face copayments for daily or weekly interactions with digital care platforms, cost becomes a deterrent to consistent participation. By eliminating this friction point, ACCESS increases the likelihood that beneficiaries will engage with and benefit from technology-enabled care throughout the entire care cycle.

Tech Companies Expressing Cautious Optimism

The industry response has been notably positive, with over 500 organizations expressing intent to apply. however, companies are tempering enthusiasm with practical concerns.

Remote patient monitoring company Cadence plans to participate and work with health system partners to enroll patients. Their CEO noted that the program makes it easier to build tech-enabled programs because outcomes and payments are tied to performance, which will separate high-quality providers from others.

Mental health tech company Headspace sees the model as validation of their approach. Their CEO observed that while the administration seems forward-thinking about technology, the fundamental challenge has been that payers haven't been willing to reimburse for these services.

Wait-and-See Approach

Not everyone is ready to commit. Companies like Freespira and Brook.ai are waiting for more details, especially around reimbursement rates and equipment cost requirements.

This caution makes sense. The program's success depends on whether payment levels adequately cover the costs of providing technology-enabled care at scale.

What This Means for Insurance Carriers, Agents, and Digital Marketers

For commercial payers and the marketers who serve them, ACCESS creates both opportunities and competitive pressure.

Following Medicare's Lead

When CMS reimburses something, it opens health plans to evaluating similar coverage. This ripple effect is powerful given current challenges around reimbursement for digital health technologies.

Carriers that proactively develop their own technology-enabled chronic care programs can differentiate themselves in the market. But those that wait may find themselves playing catch-up as beneficiaries become accustomed to digital care options through Medicare.

Value-Based Care Connection

ACCESS is designed to complement existing accountable care organizations (ACOs), groups of doctors and hospitals that share responsibility for patient outcomes, and other risk-bearing arrangements by encouraging the use of technology-enabled care to meet quality and savings goals. For carriers already operating in value-based arrangements, this creates natural synergies.

Market Intelligence Opportunity

CMS plans to maintain a public directory of ACCESS participants including their risk-adjusted clinical outcomes. This transparency creates valuable market intelligence for carriers evaluating which technology vendors deliver real results.

Digital Marketing Angle: Why This Matters Now

For digital marketers serving health tech clients or insurance carriers, ACCESS represents a significant shift in messaging opportunities.

New proof points available—The public outcomes directory creates credible, third-party validated data that technology companies can use in their marketing. Instead of relying solely on internal studies or small pilots, vendors will have Medicare-validated outcomes data.
Changed buyer journey—With clearer reimbursement pathways, the sales cycle for health tech solutions may shorten. Decision-makers at health systems and insurance companies have traditionally hesitated due to payment uncertainty. Now ACCESS removes a major objection.
SEO and content opportunities—Companies should prepare content strategies around outcome-based care, chronic disease management, and technology-enabled care delivery. As the program launches in July 2026, search volume around these topics will likely increase.

Implementation Timeline and Next Steps

The program moves quickly:

January 2026—Rolling applications begin
March 20, 2026—Deadline for first cohort consideration (updated from earlier April date)
July 1, 2026—First performance period begins
Through June 30, 2036—ACCESS program continues for full 10-year term

Applications received after the March deadline will be considered for a January 1, 2027 start, allowing multiple entry points for organizations.

FDA Connection: TEMPO Pilot

In conjunction with ACCESS, FDA announced the Technology-Enabled Meaningful Patient Outcomes (TEMPO) pilot, which allows nonFDA-authorized digital health devices to pilot their use in ACCESS while collecting real-world performance data.

This parallel initiative addresses another longstanding challenge. It creates a pathway for innovative devices to demonstrate value in real-world settings while working toward full FDA authorization.

Critical Success Factors to Watch

Several elements will determine whether ACCESS lives up to its promise:

Adequate payment rates—Participation will suffer if reimbursement levels don't cover the true costs of technology-enabled care delivery. The model's success hinges on financial viability for both providers and technology companies.
Primary care engagement—Success depends on how effectively the program links with primary care including how frequently primary care physicians (PCPs) receive updates and whether ACCESS documentation integrates into electronic health record (EHR) workflows.
Performance standards—CMS will monitor performance and may disenroll participants who fail to meet quality, safety, or outcome standards. This accountability mechanism protects beneficiaries, but also creates pressure on participating organizations.
Technology requirements—Organizations need to meet specific infrastructure requirements including integration with health information exchanges and use of FDA-authorized devices where applicable. These technical demands may present barriers for smaller organizations.

Long-Term Implications for the Industry

ACCESS signals where health care payments are heading. The model's emphasis on outcomes over activities suggests that Medicare Part B reimbursement will continue moving away from fee-for-service logic, especially for chronic care.

For insurance carriers, this creates strategic questions about their chronic care management approaches. For agents, it means staying informed about new coverage options that may appeal to tech-savvy beneficiaries. For digital health companies, it offers a potential pathway to sustainable business models based on proven outcomes rather than fragmented billing codes.

The program isn't a silver bullet. Reimbursement challenges persist in areas that ACCESS doesn't address so implementation details will determine actual impact. But the combination of a 10-year commitment, outcome-based payments, and elimination of copayments represents the most comprehensive effort yet to integrate digital health into Medicare's payment structure.

What to Do Now

The ACCESS program launches in less than seven months. Organizations that move strategically now will have first-mover advantages in outcome-driven chronic care delivery.

For Insurance Carriers

Your competitive positioning depends on how quickly you adapt to this outcome-focused approach. Here's where to start:

Monitor the public outcomes directory once it launches in order to identify high-performing technology vendors
Evaluate your chronic care management programs against ACCESS's outcome-focused framework
Consider pilot programs that mirror ACCESS's approach for commercial populations

For Insurance Agents

Your clients will start asking questions about digital care options as ACCESS rolls out. Position yourself as the informed advisor who saw this coming:

Stay informed about digital care options becoming available to Medicare beneficiaries
Prepare to discuss technology-enabled care management as a covered benefit differentiator
Track which health systems in your market participate in ACCESS

For Digital Health Companies

If you've been waiting for reimbursement clarity, this is your moment. The window for first-cohort participation closes March 20, 2026:

Review program requirements and assess readiness for application
Develop outcome measurement capabilities aligned with ACCESS's clinical tracks
Build relationships with health systems that could serve as participating organizations

Sources:

Fierce Healthcare: CMMI debuts ACCESS Model to spur use of tech in chronic disease treatment
Foley Hoag LLP: CMS Announces ACCESS (Advancing Chronic Care with Effective, Scalable Solutions) Model
Holland & Knight LLP: CMMI Launches Voluntary Payment Model for Qualifying Chronic Conditions with Tech-Enabled Care
Manatt, Phelps & Phillips, LLP: ACCESS Unlocked: CMS's Bold New Model for Tech-Enable Chronic Care Management
MobiHealth News: CMS unveils ACCESS model to expand digital care for Medicare patients
Modern Healthcare: CMS' ACCESS program brings cautious optimism from tech companies
Point-of-Care Partners (POCP): The CMS ACCESS Opportunity: Elevating Chronic Care Through Outcome-Driven Models
Powers Pyles Sutter and Verville PC: Payment for Digital Health Technologies: Barriers and Paths Forward
U.S. Centers for Medicare & Medicaid Services (CMS): ACCESS (Advancing Chronic Care with Effective, Scalable Solutions) Model

Further Thoughts

ACCESS represents more than just another CMS pilot program. It's a 10-year commitment that fundamentally reframes how Medicare pays for technology-enabled chronic care.

For an industry that's spent years navigating reimbursement uncertainty, that commitment matters. Digital health companies can finally build sustainable business models around proven outcomes rather than cobbling together fragmented billing codes. Insurance carriers gain a roadmap for their own chronic care innovation. Agents acquire a new value proposition for tech-savvy beneficiaries.

The program won't solve every challenge. Implementation details still need refinement. Payment rates must prove adequate. Technology infrastructure requirements may exclude smaller players. And success ultimately depends on whether participating organizations can consistently deliver the clinical outcomes that justify the investment.

But ACCESS changes the conversation from "Will digital health ever get paid?" to "Which digital health solutions deliver results worth paying for?" That shift from skepticism to selectivity marks real progress.

The smartest players are already preparing. They're reviewing technical requirements, identifying potential health system partners, and building outcome measurement systems. They recognize that ACCESS isn't just about accessing new revenue streams. It's about demonstrating value in ways that shape reimbursement policy for years to come.

The reimbursement landscape for digital health has been stuck for too long. ACCESS offers a way forward. What you do with that opportunity determines whether you lead the transformation or watch it happen from the sidelines.