Is this the most meaningful advancement for tech-enabled care delivery since COVID? Many industry experts say yes. Here’s a comprehensive breakdown of what the Centers for Medicare & Medicaid Services (CMS), through the Center for Medicare and Medicaid Innovation (CMMI), announced. Plus, we discuss what it could mean for digital health companies, virtual care providers, remote patient monitoring platforms, and chronic care management organizations.

What CMS announced: a new outcomes-based payment model under Medicare Part B

CMMI released a new payment model designed to accelerate adoption of healthcare technology that improves outcomes for Medicare beneficiaries. Early reactions across the digital health ecosystem suggest this could be the biggest tailwind for tech-enabled care since the surge in virtual care adoption during the COVID-19 pandemic.

At a high level, CMS is introducing a technology-supported chronic care model that combines recurring payments with outcomes-based incentives under Medicare Part B. Participating organizations can receive ongoing payments for managing beneficiaries with certain chronic conditions and additional payments for hitting specific clinical outcome targets.

A few notable aspects:

Beneficiaries can self-enroll or be referred. Unlike many CMS programs, the model does not require an initiating visit with an existing provider.
Providers and technology companies can apply beginning January 2026.
The model officially launches July 1, 2026.
CMS will evaluate performance and decide whether to expand or permanently adopt the model.

While the announcement is generating excitement, key details have not yet been released. To make sense of what is known and what remains unclear, I spoke with two experts from Manatt Health: Jared Augenstein, Senior Managing Director, and Randi Seigel, Partner and digital health regulatory expert. Their comments below are jointly attributed.

From Left to Right: Jared Augenstein is a senior managing director with Manatt Health, an interdisciplinary policy and business advisory practice of Manatt. Randi Seigel provides legal and strategic counsel to health care providers, emerging health tech and services companies, women’s health companies, insurers, and post-acute care providers.

Key questions about CMS’s outcomes-based pricing model

Why is the outcomes-based pricing model such a big innovation?

RS/JA: This model stands out because it is explicitly technology-forward. The structure blends recurring, not-at-risk payments with outcomes-based payments measured at the population level. CMS will define standardized, guideline-informed metrics for each condition.

Examples include:

Hypertension: blood pressure control
Diabetes: HbA1c improvement
Depression: PHQ-9 score changes

Specific outcome targets (for example, points of improvement required) will be released in forthcoming guidance.

When will CMS release the actual payment rates?

RS/JA: We expect to see payment rates in late 2025 or early 2026. CMS is expected to release an RFA very soon, but we do not know whether payment rates will be included.

Which digital health companies are best positioned to participate?

Likely early adopters

RS/JA: Companies offering virtual coaching, remote patient monitoring (RPM), chronic condition management, or integrated clinical services are strong candidates. Those already aligned with Medicare Advantage or commercial outcomes-based models have an advantage, especially if they operate an affiliated physician entity that can enroll in Medicare Part B.

Scaled organizations in CKD, MSK, diabetes, mental health, and metabolic health are expected to be among the earliest adopters.

Companies less likely to participate

RS/JA: Companies lacking an affiliated provider group cannot enroll in Medicare. They would need to partner with or contract through a Medicare-enrolled organization. Companies unable to comply with HIPAA, HIE connectivity requirements, or FDA device rules may also sit this out.

Is this really the biggest tailwind for digital health since COVID?

RS/JA: It is a significant tailwind, especially for organizations already successfully delivering chronic care improvements. However, unlike COVID-era telehealth flexibilities, this model does not open the doors to everyone. Requirements include:

Eligibility for Medicare enrollment
Compliance with HIPAA
Use of FDA-cleared or exempt devices, where required
Acceptance into the program by CMS
Ability to take on outcomes-based financial risk

In other words, strong companies may thrive, but many will not qualify.

What hasn’t CMS shared yet?

RS/JA: The two most important unknowns are:

Actual payment rates and the structure of recurring vs. at-risk payments.
Specific measurement targets for clinical outcomes.

These details will ultimately shape whether the model is financially viable for participants.

What role does primary care play?

RS/JA: CMS positions primary care clinicians as central partners, but participation appears optional. PCPs can bill up to $100 per beneficiary per year for reviewing documentation submitted by ACCESS participants, as long as they document this review. Beneficiaries can self-enroll, so CMS will need to clarify how PCPs become aware that a patient joined the program.

Could this model increase fraud risk?

RS/JA: Yes. Participants can request to waive beneficiary cost-sharing entirely. If every participant does so — which seems likely — oversight challenges increase. There is also no cost-sharing for co-managing provider reviews, another potential vulnerability CMS will need to monitor.

Will this increase utilization of digital health tools?

RS/JA: Absolutely. Beneficiaries will gain broader access to tools that historically were self-pay or commercially reimbursed only. We expect utilization to rise significantly, especially in the first few years. CMS will need to clarify how this model interacts with existing RPM, RTM, and primary care management programs.

What does this mean for companies like Virta, Omada, Hinge, and others?

RS/JA: It represents a meaningful opportunity. These companies already have the infrastructure, clinical models, and risk-bearing capabilities to participate in Medicare. They know how to manage outcomes and operate in value-based environments.

What about infrastructure vendors and CMS’s tools directory?

RS/JA: The Tools Directory is one of the most intriguing aspects. CMS is essentially creating a marketplace where vendors can showcase their technology directly to ACCESS participants and even offer discounts or credits, within fraud and abuse guidelines. This could become a powerful marketing channel, though potentially very crowded.

Bottom line

CMS’s new outcomes-based payment model has the potential to reshape tech-enabled chronic care delivery in Medicare. For companies with established clinical models, compliant infrastructure, and the ability to manage outcomes at scale, the ACCESS model may represent one of the most important federal opportunities since the pandemic.

Much more guidance is coming, including payment rates, outcomes targets, and operational details. We will continue tracking every update to help digital health leaders understand what this model means for strategy, investment, and future growth.

These responses can be attributed to both of them. Stay tuned for far more on this new model. I’ll do my best to unpack it for you.

Do you have additional questions? Shoot them over to me and I’ll do my best to get them over to the right folks. I’m also curious for your thoughts on the model if you’re a care delivery provider that potentially could participate. Shoot me a note at christina@secondopinion.media. Jared and Randi have also offered to help, and they can be reached at jaugenstein@manatt.com and rseigel@manatt.com.