The Care Coordination Gap in the CMS ACCESS Model

The Care Coordination Gap in the CMS ACCESS Model

Socially vulnerable Medicare beneficiaries in two-sided risk Medicare Advantage plans have up to 30% less high-risk medication use and up to 17% fewer hospitalizations than those in traditional fee-for-service Medicare, according to a study in The American Journal of Managed Care (AJMC).  Now, CMS is testing whether a new kind of payment can bring more accountability for outcomes into traditional Medicare with the CMS ACCESS (Advancing Chronic Care with Effective, Scalable Solutions) Model.

On January 1, 2027, a second cohort of health systems and physician groups will begin receiving payments from Medicare through the ACCESS model. ACCESS pays participating organizations Outcome-Aligned Payments for managing patients’ chronic conditions, rather than reimbursing them visit-by-visit. It’s an outcomes-first experiment, with full payment depending on patients reaching measurable health targets, such as lowering blood pressure. It remains to be seen how payment rates directly support this approach, and the first cohorts will be an early test.

So what does ACCESS cover, and what coordination gaps should care teams plan for?

How ACCESS Works With Primary Care  

ACCESS is built around four initial tracks — early cardio-kidney-metabolic, cardio-kidney-metabolic, musculoskeletal, and behavioral health — and it’s intentionally designed to work alongside a beneficiary’s existing primary care relationship rather than replace it. Referring physicians can send patients to an ACCESS organization, receive regular electronic progress updates, and bill a new co-management payment for reviewing those updates and coordinating care.

On paper, ACCESS is a coordination model. In practice, it raises a more interesting question: When a patient’s ACCESS-covered care and the rest of their care happen in different places, who’s making sure both sides are working from the same picture?

This is the question every new payment model must work out in its early cohorts. It’s a real opportunity for CMS, participating organizations, and the primary care physicians (PCPs) in the middle of it to get it right. The model is still young, with a 10-year runway. There’s time to close this seam before it hardens into patterns.

Where the Coordination Gaps Are in the ACCESS Model

  1. The referral workflow is still taking shape. Trade coverage of the model’s rollout has already noted that primary care coordination workflows between PCPs and ACCESS organizations remain undefined. CMS now provides a template for the updates that ACCESS organizations send to referring clinicians, but each practice still must determine how those updates fit into its day-to-day workflow. In the model’s first year, how and when information reaches a beneficiary’s regular physician may differ depending on which of the more than 160 participating organizations a patient enrolls with.
  2. Substance use disorder support is coming, but it will be a separate track. CMS will add a substance use disorder (SUD) track in April 2027. That’s important because substance use rarely shows up on its own. It overlaps constantly with chronic pain, depression and anxiety, and cardiometabolic disease, which are conditions covered by the other tracks. Because SUD will be its own track, a patient’s SUD care and their pain or diabetes care may be managed by a different organization. An organization can be doing everything right within its track and still be working from an incomplete picture of a patient whose most urgent risk factor sits in another track.
  3. It reaches less than half of the Medicare population. ACCESS is built specifically within traditional Medicare. It isn’t available to the 55% of eligible Medicare beneficiaries now enrolled in Medicare Advantage. Some major health plans have pledged to offer ACCESS-aligned payment options, but the level of support will vary from plan to plan. This can create its own coordination seam: a beneficiary who moves between traditional Medicare and Medicare Advantage, which beneficiaries can do every year during open enrollment, can gain or lose access to this kind of coordinated chronic care support depending on which side of that line they’re on at the time.
  4. The economy is tight. The organizations best positioned to build real coordination infrastructure (such as real-time data sharing, care navigators, and closed-loop referral tracking) are also the ones facing the tightest margins to do so. Payment rates range from $90 to $420 per beneficiary per year, depending on the track, leaving participants little room to invest in care coordination and making it one of the first things new cohorts will need to address.

Why This Matters Most for the Patients With the Least Room for Gaps

ACCESS is too new to have its own outcomes data yet. But the AJMC cited earlier offers a useful analysis. Researchers analyzed data from more than 1.7 million socially vulnerable Medicare beneficiaries in two-sided risk Medicare Advantage plans, which had 13.5% to 16.6% fewer acute hospitalizations and 23.4% to 30% less high-risk medication use than those in traditional Medicare, with the largest gains among the most vulnerable groups.

ACCESS is, in part, CMS’s attempt to bring some of that same coordinated-care benefit into a part of Medicare that has historically lacked it.

The Opportunity Ahead

New cohorts will start every quarter through 2033. The organizations, physicians, states, and health plans leading the way are able to:

  1. Figure out how to keep a beneficiary’s full picture connected across ACCESS and non-ACCESS care;
  2. Maintain continuity across the conditions the model tracks and those it doesn’t;
  3. And track individuals across traditional Medicare and Medicare Advantage

That’s the same problem real-time care navigation for high-need, high-cost patients is built around: making sure that when a patient’s care occurs in more than one place, someone — or something — still keeps the full picture in view.

Frequently Asked Questions: CMS ACCESS Model

What is the CMS ACCESS Model?
ACCESS (Advancing Chronic Care with Effective, Scalable Solutions) is a 10-year voluntary payment model from the CMS Innovation Center that pays participating organizations Outcome-Aligned Payments  instead of billing Medicare per visit. These are recurring payments for managing a patient’s chronic conditions, with full payments depending on how many of an organization’s patients meet their health targets. It launched July 5, 2026, and runs within traditional Medicare. The goal is to test whether paying for results, rather than volume, can expand access to technology-supported care for  chronic conditions at scale.

Which conditions does the ACCESS Model cover?
As of launch, ACCESS covers four tracks: early cardio-kidney-metabolic (eCKM), cardio-kidney-metabolic (CKM), musculoskeletal pain (MSK), and behavioral health (depression and anxiety). Starting April 1, 2027, CMS is adding four more: heart failure, chronic obstructive pulmonary disease (COPD), substance use disorder, and tobacco cessation, along with a follow-on track for chronic musculoskeletal pain. This doubles the number of tracks the model addresses within its first year.

How do primary care physicians work with ACCESS organizations?
PCPs and other referring clinicians can refer their Medicare patients directly to an ACCESS organization, and the organization sends regular electronic updates to keep the referring physician in the loop. CMS also created a new billing option for this: clinicians who review an update and take a related care-coordinating step can bill a co-management service, paid at approximately $30 per service (subject to geographic and standard Medicare adjustments), plus a one-time onboarding payment of about $10 the first time they bill for a given beneficiary on a given track. The service can be billed up to three times per 12-month care period for each patient and track, or about $100 total.

Can Medicare Advantage members participate in the ACCESS Model?
No. ACCESS is built specifically within traditional Medicare. However, Medicare Advantage plans can choose to offer similar outcomes-based payment arrangements on their own. Beneficiaries who switch between traditional Medicare and Medicare Advantage during annual open enrollment gain or lose ACCESS eligibility depending on which coverage they’re enrolled in at the time.

When can organizations join the ACCESS Model?
CMS is accepting applications on a rolling basis from January 2026 through April 2033, giving organizations multiple entry points over the model’s 10-year run rather than a single application window. The first cohort’s deadline was May 15 (extended from the original April 1, 2026, deadline), ahead of the July 5, 2026, launch. The second cohort begins January 1, 2027. New cohorts will start every quarter after that. Organizations considering ACCESS should check the CMS Participant Portal directly for the current application window.

 

Wondering how your organization can prepare for ACCESS? Connect with our team to talk through where care navigation fits into your value-based care strategy.