How Health Systems Can Start Preparing Now for the CMS ACCESS Model
The CMS ACCESS Model is not just another payment program; it is a structural shift in how chronic disease care will be delivered, measured, and paid for. Health systems that treat ACCESS as a last-minute compliance exercise will struggle to succeed. Those who begin preparing now will be positioned to lead.
ACCESS (Advancing Chronic Care with Effective, Scalable Solutions) rewards organizations for delivering continuous, outcomes-driven care across high-impact chronic conditions. Success requires more than connected devices or virtual visits. It requires deliberate alignment across operating models, governance, data infrastructure, and financial processes.
Based on an ACCESS readiness framework designed for health system leaders, here is how organizations can begin preparing today.
1. Clarify Your ACCESS Operating Model
The first question health systems must answer is how they intend to participate. Some organizations will operate ACCESS programs directly. Others may co-manage or enable programs through external partners. There is no one-size-fits-all approach, but clarity is essential.
Leaders should define which conditions and patient populations will be in scope, and how ACCESS aligns with existing ambulatory, physician enterprise, and population health strategies. Early alignment prevents fragmentation later.
2. Establish Clinical Governance and Accountability
ACCESS introduces long-term accountability for outcomes, not just activity. This requires a physician-led governance structure with clearly defined roles, established escalation pathways, and effective oversight processes.
Health systems should determine how clinical decisions are made, how performance is monitored, and how accountability is shared across internal teams and external partners. Governance gaps become operational risks once programs scale.
3. Build a Scalable, Vendor-Agnostic Device Strategy
ACCESS relies on continuous patient-generated data across various conditions, including cardio-metabolic disease, behavioral health, musculoskeletal conditions, and kidney disease. That makes device strategy foundational.
Organizations should ensure they can support multiple device types, avoid vendor lock-in, and rely on standardized, validated data. Flexibility to support BYOD, shipped kits, or hybrid models is critical—especially in Medicare populations.
4. Integrate Remote Data Directly into the EHR
Remote data that lives outside the EHR will not scale under ACCESS. Clinicians need role-appropriate, clinically meaningful summaries that are embedded directly into their existing workflows.
Health systems should prioritize EHR integration that supports team-based care, specialty-specific views, and efficient clinical action without forcing staff to log into separate systems.
5. Ensure Longitudinal Patient Visibility
ACCESS outcomes are measured over time. Systems must be able to view multi-month and multi-year trends, not just point-in-time readings.
Condition-specific longitudinal views and persistent historical data across programs are essential for demonstrating improvement, managing risk, and supporting clinical decision-making.
6. Design for Near Real-Time Monitoring—Without Alert Fatigue
Timely data ingestion enables early intervention, but only if alerts are clinically meaningful. ACCESS programs should include configurable thresholds by condition and risk level, with safeguards to prevent alert fatigue.
This balance—timely insight without overwhelming care teams—will be a key determinant of sustainability.
7. Enable Care Coordination Across Teams and Partners
ACCESS envisions coordinated, team-based care. This requires structured clinical updates to be shared with primary care providers, specialists, and care teams—regardless of whether care is delivered internally or through partners.
Continuity of care must be preserved even as delivery models evolve.
8. Plan for Multi-Condition Scalability
Many organizations will start with a limited set of ACCESS conditions. However, long-term success depends on the ability to expand programs over time without having to rebuild infrastructure.
Health systems should seek platforms and workflows that can be reused across both CMS and non-CMS programs, supporting new conditions as requirements evolve.
9. Prepare for Outcomes and Performance Reporting
ACCESS raises expectations for transparency. Health systems must track patient- and population-level outcomes longitudinally and report performance to clinical, quality, and executive stakeholders.
Early investment in reporting capabilities reduces risk once CMS reporting requirements go live.
10. Align Payment and Reimbursement Processes Early
Finally, ACCESS readiness requires coordination across clinical, billing, and finance teams. Organizations should establish transparency in program activity, documentation standards, and compliance processes well before going live.
Financial misalignment can undermine even the strongest clinical programs.
Preparing Deliberately for ACCESS
ACCESS rewards organizations that treat chronic care as a continuous, system-wide capability—not a collection of point solutions. Health systems that align operating models, governance, data infrastructure, and payment processes now will be best positioned to participate sustainably and at scale.
The question is no longer if ACCESS will change chronic care, but who will be ready when it does.