CMS ACCESS Model in 2026

CMS ACCESS Model in 2026: Co-Management Payments, Billing Rules, and What Physicians Need to Know

The Centers for Medicare & Medicaid Services (CMS) has launched a new payment model designed to expand access to technology-supported care for people with chronic conditions. The ACCESS Model-Advancing Chronic Care with Effective, Scalable Solutions—**introduces outcome-aligned payments for participating care organizations while creating a separate co-management payment opportunity for eligible clinicians who coordinate care with those organizations.

For U.S. physicians, primary care practices, specialists, Federally Qualified Health Centers (FQHCs), Rural Health Clinics (RHCs), and revenue cycle management teams, understanding this model is becoming increasingly important. It affects how certain chronic conditions may be managed, how participating organizations are paid, how referring clinicians communicate with technology-enabled care providers, and how qualifying coordination activities can be documented and billed.

CMS began the voluntary, 10-year model on July 5, 2026. By October 7, CMS listed more than 160 participating healthcare organizations. Separately, a survey released October 12 by the National Association of Accountable Care Organizations (NAACOS) and Innovaccer highlighted growing interest in ACCESS alongside uncertainty about funding, data interoperability, and implementation.

This guide explains how the CMS ACCESS Model works, who can participate, what eligible referring clinicians need to know about co-management payments, and how medical practices can prepare their workflows and billing processes.

Research and policy status: October 14, 2026. Always verify current CMS guidance before submitting claims or making participation decisions.

Key Takeaways

• ACCESS is a voluntary CMS Innovation Center model that tests a new payment approach for technology-supported chronic care in Original Medicare.
• The model began July 5, 2026, and is designed to run for 10 years.
• Its initial clinical tracks cover early cardio-kidney-metabolic conditions, established cardio-kidney-metabolic conditions, chronic musculoskeletal pain, and behavioral health conditions.
• Eligible Medicare Part B practitioners can receive a co-management payment for reviewing an ACCESS care update and performing qualifying care-coordination work.
• The standard co-management allowed amount is $30 for a qualifying track-specific service, with a possible additional $10 onboarding payment under the applicable rules. Geographic adjustments and sequestration affect actual payment.
• FQHCs and RHCs became eligible to bill qualifying co-management payments for dates of service beginning October 1, 2026.
• Documentation, time requirements, correct coding, eligibility checks, and coordination with the ACCESS organization are essential.
• ACCESS is not a universal bonus for every physician who treats a patient with a chronic condition. The applicable requirements must be met.

1. What Is the CMS ACCESS Model?

The ACCESS Model is a CMS Innovation Center initiative intended to expand access to technology-supported care for people with chronic health conditions. It tests whether outcome-aligned payments can encourage organizations to deliver clinically appropriate care using digital tools, remote monitoring, virtual services, and coordinated clinical support.

Traditional Medicare fee-for-service generally pays for defined services or activities. However, some technology-supported care models do not fit neatly into existing payment structures. For example, a clinical team may monitor a patient’s health data between appointments, provide behavioral support, or adjust a care plan using a combination of digital communication and clinician oversight.

ACCESS introduces an alternative payment pathway for eligible participating organizations, with payment linked to the achievement of defined health outcomes rather than simply the volume of activities performed.

The model is designed to complement existing care, not replace a patient’s relationship with their primary care physician.

Official source: CMS ACCESS Model overview

2. Why Is the ACCESS Model Important in October 2026?

The model is attracting attention because it brings together several priorities in U.S. healthcare: chronic disease management, technology-enabled care, clinical outcomes, interoperability, and alternative payment approaches.

A joint NAACOS–Innovaccer survey released on October 12, 2026, offers an early indication of how healthcare leaders are responding.

Among the 116 value-based care leaders surveyed:

• 72% said ACCESS was changing their technology strategy.
• 59% said co-management payments were not a meaningful funding source yet or that it was too early to determine their value.
• 93% reported having an AI strategy for care delivery.
• 73% had already invested in AI-enabled care management or virtual care.
• 52% identified EHR and data interoperability as a technology priority for the next 12 months.
• 45% identified funding as the single biggest barrier to technology adoption.
• Only 21% reported formally monitoring claims data to understand which of their patients were enrolled in ACCESS.

These findings point to an important distinction: organizations may be preparing their technology strategies for ACCESS without yet knowing whether the model’s payment structure will support their investments.

The survey is a snapshot of a defined group of healthcare leaders, not a national census of all physicians or medical practices. Nevertheless, it identifies practical issues that practices should evaluate before changing their workflows or investing in new technology.

Sources: NAACOS survey announcement, October 12, 2026 and Medical Economics coverage.

3. Which Conditions Does the ACCESS Model Address?

ACCESS began with four clinical tracks. Each track has its own eligible conditions, performance measures, and outcome targets.

Clinical track	Conditions and scope
Early cardio-kidney-metabolic (eCKM)	High blood pressure, abnormal blood lipids, overweight or obesity with a marker of central obesity, and prediabetes
Cardio-kidney-metabolic (CKM)	Diabetes, stage 3a or 3b chronic kidney disease, and atherosclerotic cardiovascular disease, including heart disease
Musculoskeletal (MSK)	Chronic musculoskeletal pain
Behavioral health (BH)	Depression and anxiety

CMS has also announced additional tracks starting April 1, 2027, for heart failure, chronic obstructive pulmonary disease (COPD), substance use disorder, and tobacco cessation. CMS guidance states that current participants and applicants will not need to reapply solely to participate in the new tracks.

The expansion could broaden the range of patients who may benefit from technology-supported care, but eligibility and participation should be checked against current CMS requirements and the services offered by each organization.

Official source: CMS ACCESS Model.

4. How Does ACCESS Payment Differ From Traditional Medicare Fee-for-Service?

The model introduces Outcome-Aligned Payments (OAPs) for participating ACCESS organizations.

Under traditional fee-for-service, reimbursement is generally tied to covered services delivered and billed under applicable payment rules. Under ACCESS, participating organizations receive recurring payments to manage a patient’s qualifying condition, with payment linked to defined clinical outcomes.

Depending on the track, outcomes may include improvement or control in measures such as:

• Blood pressure
• Hemoglobin A1c (HbA1c)
• Lipid levels
• Weight
• Validated patient-reported measures of pain, mood, or function

CMS uses condition-specific targets informed by clinical guidelines. Payment is designed to reflect the organization’s overall performance against the applicable outcome targets, rather than requiring every individual patient to achieve their target for the organization to receive full payment.

This does not mean every patient outcome is guaranteed, or that every digital health service automatically qualifies for reimbursement. Participating organizations must satisfy CMS requirements, including Medicare enrollment, clinical oversight, applicable licensure, privacy and security obligations, and outcome reporting.

A critical operational distinction is that ACCESS payments replace traditional fee-for-service billing for the participating organization for the services covered under the model for its ACCESS-aligned beneficiaries during an active care period. CMS has restrictions intended to prevent duplicative payment for other services furnished to those beneficiaries by participating organizations and affiliated entities.

These restrictions should not be generalized to every independent referring clinician. Referring practitioners may be able to bill separate qualifying co-management services when they meet CMS requirements.

Official source: CMS ACCESS Model overview and FAQs.

5. What Is the ACCESS Co-Management Payment?

The ACCESS Co-Management Payment (CMP) is particularly relevant to primary care physicians and other eligible Medicare Part B practitioners.

It is intended to compensate eligible practitioners for reviewing an ACCESS care update and performing related care-coordination activities for a beneficiary enrolled in an ACCESS track.

Qualifying activities can include:

• Reconciling or adjusting medications
• Updating the patient’s problem list
• Establishing or modifying monitoring and follow-up instructions
• Coordinating care among clinicians
• Communicating with the ACCESS organization
• Documenting agreement or disagreement with recommendations, including the clinical rationale

Simply receiving a report or opening an electronic message is not enough. The practitioner must complete the required review and at least one qualifying care-coordination activity, and the required time must be documented.

Current co-management payment amounts

CMS guidance lists the following allowed amounts:

HCPCS code	Track	Medicare allowed amount
G0676	Early or established cardio-kidney-metabolic tracks (eCKM/CKM)	$30
G0677	Musculoskeletal track (MSK)	$30
G0678	Behavioral health track (BH)	$30
Modifier AC	Qualifying initial onboarding support	Additional $10

These are the listed allowed amounts, not a promise of the exact amount a practice will receive. Actual payment may vary with the Medicare Physician Fee Schedule geographic adjustment factor and is subject to the applicable 2% sequestration reduction.

The onboarding modifier is subject to specific restrictions and may be billed only once per billing provider, beneficiary, and track. CMS also limits qualifying co-management payments to up to three times in every 12 months per beneficiary, per ACCESS track. Multiple tracks may be billed for the same beneficiary only when distinct qualifying activities are performed for each track.

CMS states that beneficiary cost-sharing does not apply to these co-management services.

Official source: CMS ACCESS Co-Management Payment Billing Guidance.

6. Who Can Bill the ACCESS Co-Management Payment?

Eligibility depends on Medicare enrollment, practitioner type, the date of service, and compliance with the model’s billing requirements.

CMS guidance identifies the following Medicare Part B-enrolled practitioner types as eligible to bill the relevant co-management HCPCS codes beginning July 5, 2026:

• Physicians
• Nurse practitioners (NPs)
• Physician assistants (PAs)
• Certified clinical nurse specialists
• Clinical psychologists and psychologists billing independently
• Licensed clinical social workers (LCSWs)
• Registered dietitians and nutrition professionals
• Physical therapists in private practice
• Occupational therapists in private practice
• Speech-language pathologists
• Marriage and family therapists
• Mental health counselors

CMS guidance extends eligibility beginning October 1, 2026, to:

• Federally Qualified Health Centers (FQHCs)
• Rural Health Clinics (RHCs)
• Pharmacies meeting the specified specialty-code requirements

For FQHCs and RHCs, CMS provides separate billing instructions. Their qualifying co-management claims are submitted as institutional claims, using the 837I transaction or, when eligible, the CMS-1450 (UB-04) form.

Important: A practice should not assume that all staff members, facilities, or services qualify automatically. Confirm the billing entity’s eligibility and follow the current CMS instructions applicable to the provider type and date of service.

Official source: CMS Co-Management Payment Billing Guidance.

7. Documentation and Billing Requirements: What Practices Should Check

For revenue cycle management teams, the main challenge is turning a qualifying clinical activity into a complete, defensible claim.

CMS requires a minimum of five minutes of total practitioner time for reviewing the ACCESS care update and performing the associated care-coordination activity. Practices should ensure that their records demonstrate both the review and the actual work performed.

A practical documentation workflow should capture:

1. Beneficiary identification: Confirm the correct patient and Medicare beneficiary identifier.
2. ACCESS track: Identify the relevant track and the care update reviewed.
3. Clinical review: Document the information reviewed and its relevance to the patient’s care.
4. Care-coordination action: Record the action taken, such as medication reconciliation, a monitoring change, communication with the ACCESS provider, or an update to the problem list.
5. Time: Record the total qualifying time in accordance with applicable CMS documentation requirements.
6. Clinical rationale: Document decisions, including agreement or disagreement with recommendations where applicable.
7. Code and modifier selection: Use the appropriate track-specific HCPCS code and apply modifier AC only when the onboarding requirements are met.
8. Frequency and eligibility: Check the payment frequency limit, the billing entity’s eligibility, and any track-specific restrictions.
9. Claim review: Confirm that the claim is complete and submitted using the correct billing format for the practitioner or facility.

This is a practical workflow checklist, not a substitute for CMS’s complete billing instructions. Practices should consult the official guidance before operationalizing these steps.

Common risks to avoid

• Billing merely because an ACCESS care update was received
• Failing to document a qualifying care-coordination activity
• Billing without meeting the minimum time requirement
• Using the wrong track-specific code
• Applying the onboarding modifier when the requirements are not satisfied
• Exceeding the allowed frequency
• Applying physician or professional claim instructions to an FQHC or RHC without checking its separate guidance
• Treating an ACCESS co-management payment as interchangeable with chronic care management or another Medicare service
• Failing to review the model’s restrictions on participating organizations and affiliated entities

A reliable billing process should include written procedures, staff training, eligibility checks, documentation audits, and a method for resolving rejected or questioned claims.

8. What Should Primary Care Physicians and Referring Clinicians Do?

The ACCESS Model is designed to complement existing care. Primary care physicians and other referring clinicians can play an important role by helping patients identify appropriate participating organizations and by remaining involved in clinical decision-making.

Practical steps include:

Identify participating organizations

CMS maintains a directory of participating organizations and the conditions they manage. Practices can use it to identify potential partners by condition and location.

Review the services offered, clinical scope, communication processes, and available information before referring a patient.

Directory: CMS ACCESS Model Participants.

Establish a care-update workflow

Agree on how care updates will be delivered, who will review them, how urgent concerns will be escalated, and where actions will be documented in the medical record.

A care update should support clinical decision-making rather than become another disconnected inbox task.

Monitor patients and preserve continuity

Confirm that the patient’s existing care team remains informed about important changes. Medication adjustments, monitoring instructions, and follow-up plans should be communicated clearly.

ACCESS is intended to support coordinated care, not create parallel care plans that leave clinicians uncertain about responsibility.

Train billing and clinical staff together

Clinical and billing teams should agree on the evidence needed to support a co-management claim. Billing personnel should understand the documentation requirements, while clinicians should understand which actions and time records must be captured.

Evaluate whether the workflow is financially sustainable

A payment opportunity should be evaluated against the time required for clinical review, documentation, communication, technology, and compliance. Do not assume that the allowed amount will cover all operational costs or that every potential service will qualify.

9. What Does the ACCESS Model Mean for Medical Billing and Revenue Cycle Management?

The model creates a specific need for coordination between clinical operations and revenue cycle management (RCM).

A practice may need to identify enrolled patients, receive and route care updates, capture qualifying activities, confirm eligibility, apply the appropriate code, submit claims, and monitor payment results.

A well-designed process can help prevent missed billing opportunities while reducing errors that arise when new payment rules are introduced without adequate staff training.

Recommended RCM controls

Patient and track identification: Maintain a reliable process for matching care updates to the correct patient and track.

Documentation completeness: Use a checklist or structured workflow to confirm that the record supports the billed service.

Coding validation: Verify the correct HCPCS code, modifier requirements, billing entity, and date-of-service rules.

Frequency edits: Track payments by beneficiary and track to reduce the risk of exceeding CMS limits.

Denial and payment monitoring: Review remittance advice and claim outcomes to identify recurring problems. Investigate the reason for each denial rather than assuming every rejection is a coding issue.

Compliance audits: Periodically review a sample of claims against the clinical record and current CMS requirements.

Performance reporting: Monitor claim acceptance, denial reasons, payment turnaround, documentation exceptions, and staff workload. These measures help management understand whether the process is functioning as intended.

MedLink Analytics works with healthcare providers on medical billing, claims processing, revenue cycle management, and analytics. Practices evaluating a new reimbursement workflow should focus on accurate documentation, compliant claim submission, and clear visibility into financial performance—not simply increasing claim volume.

10. Technology, Interoperability, and Patient Data

Technology is central to ACCESS, but technology alone does not ensure that the model will work operationally.

Participating organizations need secure, interoperable systems for enrollment, clinical data exchange, reporting, and care coordination. Referring practices also need workable processes for receiving and acting on information.

Healthcare leaders surveyed by NAACOS and Innovaccer identified data interoperability as a major priority. That finding is consistent with a practical challenge facing medical practices: data may exist in an EHR, remote-monitoring platform, or external care-management system without being readily available to the clinician who needs it.

Before investing in a new platform, practices should assess:

• Whether relevant clinical updates can be received and matched reliably
• Whether information can be incorporated into existing workflows
• Whether staff can identify outstanding tasks and escalation needs
• Whether the system supports appropriate access controls and audit trails
• Whether data exchange meets applicable privacy and security requirements
• Whether the practice can obtain meaningful operational and financial reports

The model’s technology requirements should be checked against current CMS specifications. Practices should not assume that a particular vendor or product automatically meets all requirements.

11. Financial and Operational Risks Providers Should Understand

The ACCESS Model introduces a new approach to care and payment, but it is not a guarantee of higher revenue or lower costs for every organization.

Co-management payments may not cover all costs

The allowed payment must be considered alongside the time required for review, documentation, care coordination, staff training, and technology. A practice should estimate its actual cost of delivering qualifying services before deciding how broadly to implement the workflow.

Data visibility may be incomplete

A practice may not always know which patients are enrolled in an ACCESS organization. Establishing reliable communication and patient-identification procedures can help reduce missed updates and confusion.

Clinical responsibilities must remain clear

The practice and ACCESS organization should establish how recommendations, medication changes, abnormal findings, and follow-up needs will be communicated. Responsibilities should be documented rather than assumed.

Payment restrictions require careful interpretation

The rules applicable to ACCESS participants differ from the rules governing independent referring clinicians who bill qualifying co-management services. Participating organizations and their affiliated entities must pay particular attention to the model’s restrictions on traditional fee-for-service billing for ACCESS-aligned beneficiaries during active care periods.

Early implementation evidence is still developing

The model is new. The current evidence on implementation, financial sustainability, and longer-term clinical outcomes is not yet sufficient to conclude that every participating arrangement will be successful. Practices should monitor official CMS updates and evaluate their own results over time.

12. What Should Medical Practices Do Next?

For practices considering ACCESS referrals or qualifying co-management billing, the following sequence provides a practical starting point.

1. Read the current CMS guidance. Confirm eligibility, applicable codes, time requirements, documentation rules, frequency limits, and claim submission instructions.
2. Identify relevant participating organizations. Use the CMS directory to determine which organizations support the conditions and locations relevant to your patients.
3. Define clinical and administrative ownership. Decide who receives care updates, who reviews them, how actions are documented, and how urgent issues are escalated.
4. Build a compliant billing workflow. Configure documentation prompts and billing checks only after validating them against the applicable CMS rules.
5. Train clinical and billing teams together. Make sure both groups understand the requirements and how their work connects.
6. Monitor results. Track claims, denials, payment accuracy, documentation completeness, staff workload, and patient-care coordination.
7. Reassess periodically. Review CMS updates, operational performance, and the financial sustainability of the workflow before expanding it.

Frequently Asked Questions

What does ACCESS stand for in Medicare?

ACCESS stands for Advancing Chronic Care with Effective, Scalable Solutions. It is a voluntary CMS Innovation Center model testing outcome-aligned payments for technology-supported care for people with qualifying chronic conditions in Original Medicare.

When did the CMS ACCESS Model begin?

The model began on July 5, 2026, and is designed to run for 10 years. CMS guidance should be checked for current participation and implementation details.

Can a physician bill for reviewing an ACCESS care update?

Eligible Medicare Part B practitioners may bill the applicable co-management payment when they review an ACCESS care update, perform at least one qualifying care-coordination activity, meet the minimum time requirement, document the service, and satisfy all applicable billing rules.

How much is the ACCESS Co-Management Payment?

CMS lists a $30 allowed amount for each of the three track-specific co-management codes. A qualifying initial onboarding service may be eligible for an additional $10 under modifier AC. Actual payment may vary with geographic adjustment and sequestration, and all eligibility, documentation, and frequency requirements apply.

Can FQHCs and RHCs bill ACCESS co-management payments?

CMS guidance makes FQHCs and RHCs eligible to bill qualifying co-management payments for dates of service beginning October 1, 2026. They must follow the applicable CMS requirements and their separate institutional claim submission instructions.

Does every physician who treats a patient with diabetes qualify?

No. A qualifying diagnosis alone does not establish eligibility for the co-management payment. The patient must be enrolled in the relevant ACCESS track, the practitioner or billing entity must be eligible, and the required review, care-coordination activity, time, documentation, and other billing rules must be satisfied.

Does ACCESS replace traditional Medicare for all participating patients?

No. ACCESS is a specific model for qualifying conditions and services. Participating organizations have model-specific payment and billing restrictions for ACCESS-aligned beneficiaries during active care periods. Patients retain their Original Medicare rights, coverage, and freedom to see Medicare healthcare providers. Referring clinicians should review the applicable CMS rules before billing.

Is the ACCESS Model the same as chronic care management?

No. ACCESS is a distinct CMS Innovation Center model with its own participating organizations, outcome-aligned payment structure, clinical tracks, and co-management payment rules. Practices should not treat its codes or requirements as interchangeable with those for chronic care management or other Medicare services.

Conclusion

The CMS ACCESS Model represents an important development in technology-supported chronic care and outcome-aligned payment in Original Medicare. For physicians and medical practices, its practical significance lies in understanding how participating organizations deliver care, how referring clinicians coordinate with them, and how qualifying co-management activities are documented and billed.

The October 2026 survey findings suggest that healthcare leaders are already considering ACCESS in their technology strategies, while questions remain about funding, interoperability, and implementation. For individual practices, the most prudent approach is to understand the rules, establish clear clinical and billing workflows, and evaluate operational and financial results before scaling.

A successful process requires more than knowing which code to submit. It depends on accurate patient identification, meaningful clinical review, complete documentation, compliant claims, and communication that supports continuity of care.

For healthcare providers, billing teams, and practice administrators, these fundamentals can help turn a new payment model into a structured, measurable, and clinically responsible workflow.

References and Authoritative Resources

1. Centers for Medicare & Medicaid Services (CMS). ACCESS Model: Overview, design, clinical tracks, and frequently asked questions.
2. CMS. ACCESS Model Participants.
3. CMS. ACCESS Co-Management Payment Billing Guidance.
4. National Association of Accountable Care Organizations (NAACOS). NAACOS and Innovaccer Research Finds Health Care Leaders Are Shifting Tech Strategy to Adjust to CMS’ ACCESS Model, October 12, 2026.
5. Medical Economics. Health care leaders are planning around Medicare’s ACCESS model but doubt it will pay off, October 12, 2026.

This article is for general educational and operational information. It is not legal, coding, reimbursement, or clinical advice. CMS guidance and applicable requirements may change; providers should verify current official instructions before billing or making participation decisions.