A Blunt Assessment of Every Major ACCESS Model Participant, Their Business Models, and What CMS’s New Outcome-Aligned Payment Framework Actually Means for Their P&L and Patient Populations

Abstract

What it is: The ACCESS (Advancing Chronic Care with Effective, Scalable Solutions) Model is a 10-year, voluntary, nationwide CMS Innovation Center model launching July 5, 2026, testing an Outcome-Aligned Payment (OAP) methodology for technology-enabled chronic care across four clinical tracks: eCKM (early cardiometabolic), CKM (full cardiometabolic/diabetes/CKD), MSK (musculoskeletal pain), and BH (behavioral health: depression and anxiety).

Key payment mechanics: Monthly fixed per-patient payments with a 50% withhold reconciled at end of 12-month care periods. Full payment contingent on achieving OAP Measure targets across a patient panel. The Outcome Attainment Threshold (OAT) starts at 50% in the first 18 months. A Substitute Spend Adjustment (SST starting at 90%) penalizes participants whose patients receive duplicative FFS services for the same condition from other providers. Only the larger of the two adjustments is applied per reconciliation period, capped at 50% and 25% respectively.

The payer context: 14 major payers representing 165 million covered lives have signed the ACCESS Payer Pledge, committing to align commercial, MA, and Medicaid payment to the model’s structure by January 1, 2028. This includes UnitedHealthcare, Humana, Cigna, CVS/Aetna, Centene, Devoted Health, and several BCBS plans.

The participant field: 150-plus organizations accepted as of April 2026, spanning virtual-first digital health companies, traditional brick-and-mortar specialists, pharmacies, care management vendors, and a handful of entries that defy easy categorization.

Key questions addressed: Who has the business model alignment, patient panel sophistication, and outcome track record to actually make money here? Who will make the biggest clinical dent in Medicare’s chronic disease burden? Who is absent from the list who probably should be there? And who are we looking at going, really?

How to Think About This List Before Getting Into Specifics

There’s a temptation to treat the ACCESS accepted applicant list as a flat roster, an alphabetical spreadsheet of companies that all said yes to the same thing. That would be a mistake. The gap between the top tier and the bottom tier of this group, in terms of actual readiness to thrive in an outcome-aligned payment model, is enormous. The business model differences are even starker than the clinical ones. Some of these organizations have been building toward exactly this moment for years, running commercial book-of-business programs with outcome accountability, investing in remote monitoring infrastructure, and proving out that they can move biomarkers at scale. Others are walking in from adjacent markets with a lot of enthusiasm and not a lot of evidence. A few are genuinely puzzling additions.

To understand who’s positioned well, you need to internalize one thing about how the OAP payment structure actually works in practice. The model pays a fixed monthly per-patient rate (amounts not yet published as of the April 2026 application period), with 100% of payments flowing in months one through six and the back half effectively held until the 12-month mark. Full release of that withhold depends on the participant’s Outcome Attainment Rate, meaning the share of their total patient panel who hit the required clinical targets. The OAT starts at 50% across the first 18 months, which sounds lenient until you realize most of these organizations have never tried to move Medicare FFS patients through an outcome-linked accountability framework before. Medicare populations are older, more complex, and more likely to have comorbidities that complicate biomarker improvement. The organizations that have spent years managing commercially insured populations in their 40s and 50s are going to face a real wake-up call when the panel shifts to original Medicare beneficiaries, many of whom are in their late 60s, 70s, and 80s with entrenched disease patterns and polypharmacy issues.

The Substitute Spend Adjustment is the other thing that makes this genuinely hard. If a participant’s patients start getting physical therapy evaluations, psychiatric evals, DSMT sessions, or cardiac monitoring billed through FFS channels by other providers during the care period, the participant’s Substitute Spend Rate drops and their payment gets dinged. This creates a coordination burden that tech-first, virtual-only companies are particularly bad at managing, because they often don’t have deep enough relationships with a patient’s brick-and-mortar care team to prevent those FFS encounters from happening. That 90% SST in year one is going to be a real problem for anyone who doesn’t have tight care coordination workflows.

With that backdrop, let’s go through the landscape.

The Category That Will Probably Make the Most Money: Scaled Virtual-First CKM and eCKM Specialists