The CMS ACCESS Model: What Every Primary Care Physician Needs to Know Before July 2026

Section analysis by Lilit Muradyan, Billing Department, WCH 

EDITOR’S NOTE — Why This Matters Now The ACCESS model launches July 1, 2026. Applications were due April 1, 2026 for the first cohort. If you missed it, the next entry point is January 1, 2027. Understanding this model isn’t optional — your patients are already eligible to enroll directly, with or without your referral.

The Problem ACCESS Is Trying to Solve

Let’s be honest about something most of us have felt in clinic: Medicare’s fee-for-service structure was built for a world of acute illness. You see a patient, you bill a code, you get paid. But the patients filling our schedules today aren’t coming in with pneumonia or fractures — they’re coming in with hypertension layered on top of prediabetes layered on top of low-grade depression, and every one of those conditions is best managed continuously, proactively, and digitally between visits. Traditional FFS billing doesn’t pay for that kind of care. It never has.

Chronic conditions affect more than two-thirds of all Original Medicare beneficiaries. Hypertension, diabetes, chronic kidney disease, musculoskeletal pain, anxiety, depression — these are the bread and butter of primary care. They are also, collectively, the primary driver of Medicare expenditure. CMS has been trying for years to move the needle: the Comprehensive Primary Care models, Primary Care First, Making Care Primary — each iteration getting closer to rewarding outcomes rather than visits. ACCESS represents the most structurally ambitious version of this experiment yet.

What Is the ACCESS Model?

ACCESS = Advancing Chronic Care with Effective, Scalable Solutions A 10-year national voluntary payment model (2026–2035) operated by the CMS Innovation Center (CMMI). It replaces activity-based reimbursement with Outcome-Aligned Payments (OAPs) — recurring payments tied directly to measurable improvements in patients’ health, not to the volume or type of services delivered. Technology-enabled care is a core requirement, not an add-on.

Announced December 4, 2025. First cohort launches July 1, 2026. Rolling applications through the early 2030s.

The Four Clinical Tracks

Track 1 — Early Cardio-Kidney-Metabolic (eCKM) Target conditions: Hypertension, dyslipidemia, obesity/overweight with central adiposity, prediabetes Outcome targets: Blood pressure control, lipid improvement, weight reduction, HbA1c trajectory The clinical angle: This is the prevention track. Patients here haven’t yet crossed into diabetes or established CKD, but they’re heading there. Think of the patient with a BP of 148/92, a BMI of 31 with abdominal obesity, and a fasting glucose of 107. The eCKM track is built precisely for that profile. Technology tools here include connected BP cuffs, continuous glucose monitors, dietary coaching apps, and telehealth check-ins — all aimed at reversing the trajectory before it solidifies.

Track 3 — Musculoskeletal (MSK) Target conditions: Chronic musculoskeletal pain Outcome targets: Clinically meaningful pain reduction and functional improvement; opioid-sparing outcomes tracked over the program period The clinical angle: This is the track that deserves the most attention from a public health standpoint. Chronic MSK pain is the leading driver of opioid prescribing in primary care. The model’s emphasis on opioid-sparing outcomes makes explicit what the clinical literature has been telling us for years: physical therapy, digital CBT-based pain management, and supervised exercise programs outperform long-term opioid therapy for most chronic pain conditions. This track is structured as an intensive one-year program, with no extended maintenance phase — the expectation is meaningful relief within that window.

Track 2 — Cardio-Kidney-Metabolic (CKM) Target conditions: Diabetes mellitus, chronic kidney disease (stages 3a/3b), atherosclerotic cardiovascular disease (ASCVD) Outcome targets: HbA1c control, BP control, lipid management; eGFR and UACR data submission required for CKD and diabetes subgroups The clinical angle: The higher-complexity track. These patients already have established disease, often on multiple agents, often with competing organ-level concerns. The UACR and eGFR reporting requirement is notable — it signals that CMS is watching for CKD progression as a hard outcome, not just glycemic surrogate markers.

Track 4 — Behavioral Health (BH) Target conditions: Depression, anxiety Outcome targets: Validated symptom scale improvement (PHQ-9 for depression, GAD-7 for anxiety), with technology-enabled monitoring between visits The clinical angle: Depression and anxiety are among the most undertreated conditions in Medicare populations and among the most consequential when missed — they drive worse outcomes across every other chronic condition. This track legitimizes digital mental health tools (asynchronous CBT, mood tracking apps, telepsychiatry coordination) under a payment umbrella that Medicare FFS has largely refused to provide.

How the Payment Model Actually Works

Under traditional FFS, you bill a code and get a fixed fee regardless of what happens to the patient afterward. ACCESS flips that logic entirely.

Participating organizations receive:

• Recurring Outcome-Aligned Payments (OAPs) — paid monthly or quarterly throughout the enrollment period, as long as the patient remains enrolled
• Full reconciliation payment — earned only when a defined percentage of the organization’s enrolled patients meet their condition-specific outcome targets
• Performance thresholds that increase annually — meaning the bar gets higher each year, incentivizing sustained improvement rather than one-time gains

The payment amount is condition-specific and individual-baseline-referenced. A patient whose BP is 165/100 at enrollment and reaches 130/80 is “successful” — but the target is set relative to their own starting point, not a universal threshold. This is a meaningful methodological choice: it creates incentives for organizations to enroll even high-complexity patients rather than cherry-picking the easy cases.

PAYMENT STRUCTURE KEY POINTS OAPs are prospective and recurring — not fee-for-service Full payment requires meeting population-level outcome thresholds Thresholds increase each program year Most tracks: intensive phase (6–12 months) + lower-rate maintenance phase MSK track: intensive one-year program only (no maintenance phase)

The Primary Care Physician’s Role: More Central Than You Might Think

Here is where the analysis gets practical — and where the stakes for PCPs become clear.

ACCESS is not a primary care model. Participating “organizations” can be physician groups, hospitals, digital health companies, or a combination. A patient might enroll with a digital health startup that provides their hypertension management via connected devices and remote coaching, while you continue to be their PCP. This creates a care coordination scenario that has no clean precedent in current Medicare billing.

CMS has built in several mechanisms to keep the PCP in the loop:

1. Referral pathway. Primary care clinicians can formally refer patients to ACCESS organizations. This is voluntary, but the referral process creates a documented relationship that triggers subsequent data sharing.

2. Electronic updates. Participating ACCESS organizations are required to send electronic updates to referring clinicians on enrolled patients’ clinical progress. In practice, this means your EHR should — in theory — receive structured updates on a patient’s BP trends, HbA1c trajectory, or PHQ-9 scores from their ACCESS provider.

3. Co-management payment. PCPs who document review of these updates and perform coordination activities can bill a new co-management payment code specifically created for this model. This is a modest but real financial incentive for engagement — and it formalizes the PCP’s role as the longitudinal care anchor even when another organization is managing the specific condition.

CMP Billing Details: Codes, Amounts, and Requirements

CMS published formal billing guidance for the Co-Management Payment on June 5, 2026. Eligible Medicare Part B practitioners — including physicians, NPs, PAs, clinical psychologists, LCSWs, registered dietitians, and several other practitioner types — can begin billing CMP HCPCS codes starting July 5, 2026. FQHCs and RHCs become eligible in October 2026; guidance for pharmacists is forthcoming.

To bill a CMP, the eligible practitioner must review an ACCESS Care Update for the beneficiary and track, and perform at least one care-coordination activity — for example, reconciling medications, updating the problem list, modifying follow-up instructions, coordinating with other clinicians, communicating with the ACCESS provider, or documenting agreement or disagreement with ACCESS recommendations. A minimum of 5 minutes of practitioner time is required.

G-Code	Track	Allowed Amount	Description
G0676	eCKM / CKM	$30	Review of ACCESS care update for eCKM/CKM track conditions plus at least one care-coordination activity
G0677	MSK	$30	Review of ACCESS care update for MSK track conditions plus at least one care-coordination activity
G0678	BH	$30	Review of ACCESS care update for BH track conditions plus at least one care-coordination activity
Modifier AC	First G-code per track	+$10	Initial onboarding support for ACCESS enrollment and device/application setup

CMS pays 100% of the Medicare-allowed amount, subject to the 2% sequestration reduction; actual payment varies by location based on the Medicare Physician Fee Schedule Geographic Adjustment Factor. Beneficiary cost-sharing does not apply to the CMP, so practitioners do not need advance beneficiary consent for these services.

Frequency: CMPs are payable up to 3 times every 12 months, per beneficiary, per ACCESS track. You may bill CMPs for multiple tracks for the same beneficiary when distinct review and care-coordination activities are performed for each. Modifier AC may be billed only once per billing provider, per beneficiary, per track. CMS does not cap how many clinicians may bill the CMP for the same beneficiary, though billing patterns will be monitored for potential duplication or abuse.

Claim requirements to keep in mind: the diagnosis code on the claim must correspond to a qualifying condition for the beneficiary’s aligned ACCESS track, or the claim will be denied. The rendering practitioner’s NPI must be reported; if CMP services are furnished by auxiliary personnel under general supervision, the supervising practitioner’s NPI must be reported as both rendering and supervising practitioner. Documentation of your review of the ACCESS Participant’s electronically shared clinical update is required to support every CMP claim. Billing the CMP does not replace or affect billing for office visits or other distinct covered services.

CRITICAL COMMENTARY — The co-management payment is a good idea that may not survive contact with reality. Its value hinges on three things that are not guaranteed: (a) ACCESS organizations actually sending timely, structured updates; (b) those updates being interoperable with your EHR system; and (c) the payment being sufficient to compensate for the cognitive load of reviewing and documenting that coordination. Early implementation will tell us whether this mechanism has teeth. PCPs should document every coordination activity meticulously from day one.

What Technology Is Required?

This is a harder question than CMS’s public materials suggest. The model requires FHIR-based API integration for data reporting and clinical update sharing. This is a significant infrastructure demand that most solo and small-group practices cannot meet independently — and one reason why large health systems, ACOs, and digital health companies are better positioned as participating organizations than individual PCPs.

For the primary care physician in a community practice, the practical technology question is simpler: What tools should I be steering patients toward, and do any of those tools connect to ACCESS-participating organizations?

By track:

Track	Technology Examples
eCKM	Cellular-connected BP cuffs, CGMs (for prediabetes monitoring), dietary tracking apps, body composition scales
CKM	CGMs, GLP-1 adherence monitoring tools, eGFR monitoring integration, telehealth nephrology
MSK	Digital physical therapy platforms, remote pain tracking tools, CBT-based pain apps
BH	Digital CBT apps, PHQ-9/GAD-7 automated tracking, telepsychiatry platforms

What This Means for Your Patients

Patients with Original Medicare can enroll directly with a participating ACCESS organization — without a referral from their PCP. CMS will maintain a public directory of participating organizations with their outcomes data (risk-adjusted), so patients can compare options before enrolling.

This has immediate implications for your practice:

1. Informed consent conversations will change. Patients may come to you having already enrolled in an ACCESS program or considering it. They need to understand that ACCESS complements — does not replace — their primary care relationship, and that they retain full Medicare rights and access to any Medicare provider.

2. You may inherit clinical data you didn’t order. The electronic updates from ACCESS organizations will land in your workflow. This is useful information — but only if the interoperability actually works, and only if you have a process for reviewing it.

3. Dual enrollment questions will arise. Patients can participate in more than one ACCESS track simultaneously. A patient with hypertension, depression, and chronic back pain could theoretically be enrolled in eCKM, BH, and MSK tracks concurrently. Whether that’s coordinated care or fragmented care depends entirely on how well the participating organizations communicate with each other — and with you.

The Bigger Picture: Why This Model Is Different

Several things distinguish ACCESS from prior CMS chronic care models, and they’re worth naming clearly.

Structural novelty: Previous models primarily worked through physician practices or ACOs. ACCESS opens the door to digital health companies and non-traditional care organizations participating directly in Medicare. This is a deliberate policy choice — CMS is betting that technology-forward organizations can achieve better outcomes for specific conditions than traditional practice models, at lower cost.

Outcome accountability with teeth: The payment structure is genuinely outcome-contingent. Organizations don’t just get paid for enrolling patients and checking boxes — they have to demonstrate population-level results. The annually increasing performance thresholds mean there’s no coasting.

Patient agency: Direct enrollment without PCP referral is unusual. It creates patient autonomy while also creating care coordination risk. CMS is wagering that the public directory of risk-adjusted outcomes will be sufficient to help patients make informed choices. That’s an optimistic assumption about health literacy and directory usability.

10-year horizon: The model runs through 2035. This is a serious policy investment, not a pilot. CMS has signaled that if ACCESS works, it could become a permanent payment pathway — potentially restructuring how a substantial portion of chronic disease management is reimbursed in Medicare.

Practical Takeaways for Primary Care Physicians

▶ Know which of your Medicare patients qualify. Pull a list of patients with hypertension, diabetes, CKD (3a/3b), ASCVD, chronic MSK pain, depression, or anxiety. These are your ACCESS-eligible population. Over two-thirds of your Original Medicare panel likely qualifies for at least one track.

▶ Understand that patients can self-enroll. You may not know a patient has enrolled until you receive an electronic update — or until they tell you in the exam room. Build awareness into your intake process.

▶ Familiarize yourself with the co-management billing pathway. CMS has created a specific payment for reviewing ACCESS updates and coordinating care. Learn the documentation requirements before your first patient enrolls. Missing this is leaving money — and clinical credit — on the table.

▶ Engage with ACCESS organizations in your community. As the directory populates, understand who the participating organizations are in your area, what tracks they offer, and what their technology infrastructure looks like. A working relationship with the organizations managing your patients’ conditions is preferable to receiving a data stream with no relationship behind it.

▶ Watch the interoperability closely. The model’s clinical promise depends on seamless data sharing between ACCESS organizations and referring clinicians. If the updates you receive are PDF faxes rather than structured FHIR data, escalate that feedback. The model’s design intent and its real-world execution may diverge significantly in year one.

A Note on What We Don’t Know Yet

This article is being written as the model enters its first year of operation. Several critical details remain genuinely uncertain:

• The specific dollar amounts of Outcome-Aligned Payments have not been publicly released
• How EHR vendors will handle incoming structured data from ACCESS organizations is not yet standardized
• Whether the co-management payment level will be sufficient to motivate sustained PCP engagement is untested
• How CMS will handle care attribution disputes between ACCESS organizations and PCPs is not yet clear
• The model’s interaction with Medicare Advantage plans remains limited — MA beneficiaries are excluded from ACCESS enrollment, though MA plans may independently develop similar arrangements

These are not arguments against engagement. They are arguments for careful documentation, active participation in CMS feedback mechanisms, and treating year one as a learning opportunity as much as a billing opportunity.

References & Sources

1. Centers for Medicare & Medicaid Services. ACCESS (Advancing Chronic Care with Effective, Scalable Solutions) Model. CMS Innovation Center. https://www.cms.gov/priorities/innovation/innovation-models/access
2. CMS Newsroom Blog. Improving ACCESS to Technology-Supported Care with Outcome-Aligned Payments. December 19, 2025. https://www.cms.gov/newsroom/blog/improving-access-technology-supported-care-outcome-aligned-payments
3. Cohen M, Augenstein J, Seigel R, et al. ACCESS Unlocked: CMS’s Bold New Model for Tech-Enabled Chronic Care Management. Manatt Health Highlights. December 2, 2025. https://www.manatt.com/insights/newsletters/health-highlights/access-unlocked-cms-s-bold-new-model-for-tech-enable-chronic-care-management
4. Epstein Becker Green Health Law Advisor. ACCESS Model: CMMI’s New Technology-Enabled Chronic Care Model. January 6, 2026. https://www.healthlawadvisor.com/access-model-cmmis-new-technology-enabled-chronic-care-model
5. Holland & Knight. CMMI Launches Voluntary Payment Model for Qualifying Chronic Conditions with Tech-Enabled Care. December 2025. https://www.hklaw.com/en/insights/publications/2025/12/cmmi-launches-voluntary-payment-model-for-qualifying-chronic
6. Akin Gump. CMS Launches Five New Models at the End of 2025. January 7, 2026. https://www.akingump.com/en/insights/alerts/cms-launches-five-new-models-at-the-end-of-2025
7. Foley Hoag LLP. CMS Announces ACCESS Model. December 4, 2025. https://foleyhoag.com/news-and-insights/publications/alerts-and-updates/2025/december/cms-announces-access-advancing-chronic-care-with-effective-scalable-solutions-model/
8. Moss Adams / Prevounce Blog. CMS Unveils the ACCESS Model: A New Era for Technology-Enabled Chronic Care. December 19, 2025. https://blog.prevounce.com/cms-unveils-the-access-model-a-new-era-for-technology-enabled-chronic-care
9. ArentFox Schiff. CMS Innovation Center Unveils ACCESS Model to Expand Technology-Supported Care for Chronic Disease. February 9, 2026. https://www.afslaw.com/perspectives/health-care-counsel-blog/cms-innovation-center-unveils-access-model-expand-technology
10. AHCANCAL. CMS Launches ACCESS Model to Improve Chronic Care in Medicare FFS Through Technology. 2025. https://www.ahcancal.org/News-and-Communications/Blog/Pages/CMS-Launches-ACCESS-Model-to-Improve-Chronic-Care-in-Medicare-FFS-Through-Technology.aspx

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Article prepared for the EduRx Primary Care specialty education section. Content reflects the CMS ACCESS model as announced December 4, 2025, and updated through available public materials as of June 2026. Payment amounts and implementation details are subject to revision as CMS releases additional guidance.