The Innovations Center May Be Rolling Out Its Most Innovative Program Yet

The Centers for Medicare and Medicaid Innovation (CMMI) was created as part of the Affordable Care Act in 2009 to design and test “pilot programs called Alternative Payment Models (APMs), which reward health care providers for delivering high-quality, coordinated care.”¹ CMMI has multiple categories of care and payment innovation, including accountable care models, disease-specific and episode-based models, health plan models, prescription drug models, state and community-based models, and statutory models.

Uniquely, the legislation provided CMMI with 2 very important privileges. The first was to provide safe harbor from potential regulatory hurdles that may prevent testing innovations such as anti-kickback statutes or waiving copayments for enrollees. The second is the ability to implement new programs and payment models for all of Medicare if an innovation is proven to be successful (thereby potentially preventing the need for new legislation or administrative rulemaking or successfully contesting suits in the courts if claimants do not like the new payment model). Every administration since the formation of CMMI has utilized its placement in CMS and its purpose and privileges to test models and policy ideas they favor.

A History of Attempting to Innovate with Conventional Actors and Conventional Care

The CMMI website currently lists 105 models in its history with 23 active and another 11 announced, pending finalization of rules and launch. Though only 1 is currently active (Cell and Gene Therapy Access) in the Prescription Drug Models category, there are 4 currently announced in that category, most of which are new ways of purchasing drugs either through negotiation or rebating with governmental entities. On the health outcomes side, the other models almost exclusively look to medical providers or systems where medical providers are on point for improving quality and decreasing overall costs, through Accountable Care Organizations or bundled contracting mechanisms.

Ripping the Band Aid Off: A Chance at Value-Based Care for Those Not Typically Invited

More recently, CMMI has been looking beyond traditional health system actors and providers who have been driving most of the care delivery and, subsequently, spend. Advancing Chronic Care with Effective, Scalable Solutions (ACCESS) was announced, using the word acronym to imply that patients need access to more (and better) solutions for chronic care. Although physicians and physician groups can receive modest compensation for coordinating with ACCESS provider-participants, ACCESS “providers” don’t have to employ physicians to do the chronic care delivery themselves. In fact, there may not be a person involved at all. Nearly every program in CMMI history related to care delivery has required direct, or at least indirect, supervision of care for specific patients receiving care under the model.

ACCESS opens direct care delivery to any number of providers, provider types, humans and non-humans and doubles down on producing outcomes, with 50% of payment subject to performance across all patients aligned with the program. In other words, the administration, through CMMI, is essentially saying, “The existing system with the traditional providers is not getting to patients at the scale necessary, nor the effect size, nor with enough incentives to produce outcomes. Let’s open the opportunity to a broader range of actors to be involved with chronic care and value-based reimbursement.”

ACCESS Is Meant to Be Technology Enabled

CMMI purports that the solution ACCESS provides “Will test a new payment option that emphasizes outcomes over activities, enabling clinicians to offer innovative technology-supported care that improves patients’ health and complements traditional care.”² And technology providers are responding. Well known medical provider technology enablement groups like Innovacer and Aladade are listed as participating, along with behavioral change application Noom and many other technology companies.^3,4 CMMI is promoting the use of telehealth software, wearable devices, and apps as a means of force multiplying a strained and often inefficient deployment of health care providers.

Are the Program Measures Heavily Weighted Toward Optimizing Medication Use?

But wait, chronic care delivery with frequent touchpoints to generate outcomes largely produced by drug therapies…hold on…isn’t that pharmacy’s job? One of the unfortunate requirements of ACCESS is that participants must be a Medicare Part B provider for the purposes of billing. Though pharmacists and pharmacies could work through coordinating medical providers or directly with participants, it seems at this stage of the authorization process CMMI is not letting pharmacies participate in ACCESS despite being an obvious solution to optimize therapy for patients who have already been diagnosed, prescribed therapy, and are not meeting goal—the target patients for ACCESS alignment.

And here we are again. Lack of provider status with the Social Security Act rears its ugly head again. Add this program to the list of missed opportunities to transform the community pharmacy business model and the pharmacist practice model, whilst allowing the obvious choice for optimizing medication use to intervene, see patients, and get them to goal.

Where Do We Go From Here?

CMMI has been announced as a 10-year program and no doubt much will be learned even within the first few months. Hopefully, community pharmacies and pharmacists of all stripes will be able to participate (directly or indirectly) with a reasonable and workable level of autonomy to effectively allow 30 million fee-for-service Medicare recipients to access their skills, relationships, care delivery capabilities, and ability to improve outcomes and lower overall cost of care.

REFERENCES

1. How an idea becomes a model. US Centers for Medicare & Medicaid Services. Updated February 27, 2025. Accessed May 19, 2026. https://www.cms.gov/priorities/innovation/about/how-ideas-become-models

2. ACCESS (advancing chronic care with effective, scalable solutions) model. US Centers for Medicare & Medicaid Services. Updated May 15, 2026. Accessed May 29, 2026. https://www.cms.gov/priorities/innovation/innovation-models/access

3. ACCESS model accepted applicants. US Centers for Medicare & Medicaid Services. Updated May 27, 2026. Accessed May 29, 2026. https://www.cms.gov/priorities/innovation/access-model-accepted-applicants

4. Act on ACCESS now before the transition reshapes your Medicare relationships. Innovaccer. Accessed May 29, 2026. https://innovaccer.com/cms-access