More details are now out for the ACCESS model, a new payment program from the Center for Medicare and Medicaid Innovation that incentives technology forward companies to join Medicare and rewards them for using technology to improve patient outcomes. The program starts the first week of July for the first cohort, with applications due April 1, 2026. Second Opinion previously covered the program, and in recent months, companies across digital health have been awaiting more details.
The payment amounts and performance targets are now published online.
My phone has been ringing nonstop this morning, and text threads are firing about the program since the update. Many companies in digital health are still digesting the news to assess whether it’s a fit, and I’ve heard from some companies that the expectation in the industry was that the rates would be low, as the government has been very clear that we need to take steps to bring down costs. Healthcare finally needs a deflationary moment.
That said, it’s a delicate balance as payments need to be high enough to encourage participation in the program. And these rates are lower than some of the rates that operators and policy experts I’ve been speaking to expected.
But here’s a few immediate reactions that I’ve heard - and I’m very curious to get a sanity check from you:
This program is going to require marketing to Medicare patients. There are high costs associated with patient acquisition, particularly for this population. So that’s a big question mark for companies that haven’t historically done a lot of direct-to-consumer marketing that might have otherwise been well-suited.
The published rates account for the patient paying their cost-share; however, if companies want to waive that (aka provide the program for free), the total amount they will be paid is 20% lower than the published rates.
This subset of the population is so expensive to reach, given competition for eyeballs with Medicare Advantage. And health systems have also historically been a difficult channel to market through. Will there be enough of an incentive here for hospitals to promote the program to their patients? In theory, the hospital could bill separately for educating the patient about the program, and then for co-managing them with a digital health partner. But is the juice worth the squeeze without other ROI for the hospital?
The most likely companies that will get involved initially are fully autonomous and heavy on AI/technology, versus heavy services companies with humans in the loop. However, the model does require medical director involvement. There will probably also be companies with an existing direct-to-consumer go-to-market strategy. Headspace is a good example in the behavioral health space. Hello Heart is another. Hinge, Sword, and Omada… My industry peers and friends are uncertain.
There’s a lot of questions circulating about the lack of a follow-on period for MSK.
The clearest target population here is rising-risk patients that are hiding in plain sight. Per Tom Cassels, a managing director at Manatt, the program presents an incentive for physicians in clinics and emergency departments to refer patients to program participants offering relatively light-lift, but ongoing, symptom monitoring and nudging. The goal is for patients to be redirected from avoidable high-cost settings to virtual or in-person clinician services.
One last thought: “While the model is well-intended and could have a real impact on patient outcomes, the rates are quite low to motivate new entrants to the Medicare program given the infrastructure they need to compliantly operate the program and achieve the desired outcomes,” said Manatt health-tech legal expert Randi Seigel. “We anticipate that some initially interested companies will have to take a hard look at the numbers to understand viability.”
And yet, as we noted, there might still be some opportunity here for a subset. It’ll be fascinating to watch which companies raise their hands and why.
What have been some of your immediate reactions to the ACCESS model? What companies in the health-tech space will benefit most? And what companies will not? My inbox is always open. Also worth noting that this is an experiment. CMMI will be closely following how all this plays out, and there’s potential here for adjustment based on feedback.
In other major policy news, several publications are reporting that Chris Klomp will now be Chief Counselor for the Department of Health and Human Services (HHS). He was previously the head of the Centers for Medicare and has been a big voice in the need to reduce costs. That includes drug spending, as well as in finding ways to bring technology into healthcare.
Klomp was previously a health-tech founder (Collective Medical), and he sat on the board of the women’s health company Maven Clinic. He’s also the subject of our next interview in this very publication – so stay tuned!
A reminder on upcoming webinars:
Hospitals as the new go-to-market, lessons from the trenches | Mar 3, 2026 12 PM ET | Anyone can sign up here |
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