The ACCESS Model, short for Advancing Chronic Care with Effective, Scalable Solutions, is a new 10-year CMS Innovation Center model that began on July 5, 2026. It tests a different Medicare payment approach for technology supported chronic care. Instead of paying only for individual activities or services, ACCESS uses Outcome Aligned Payments, where payment is connected to measurable improvement in a patient’s condition.
For healthcare providers, there are two important ways to interact with ACCESS:
- Participate as an ACCESS care organization
- Remain a traditional Medicare provider and refer patients to an ACCESS organization while participating in care coordination
The second option is particularly important for primary care and referring clinicians because CMS created specific Co Management Payment, or CMP, codes for eligible clinicians who review ACCESS care updates and perform documented coordination activities.
Who Can Participate in the ACCESS Model?
ACCESS is relevant to several types of healthcare organizations and clinicians.
CMS allows Medicare Part B enrolled providers and suppliers to participate, except DMEPOS suppliers and laboratory suppliers. An organization must have an active TIN and meet Medicare enrollment and other regulatory requirements. It must also designate a physician Medical Director responsible for clinical quality and compliance oversight.
Potentially relevant organizations include:
- Physician practices
- Medical groups
- Behavioral health organizations
- Organizations providing chronic disease management
- Technology enabled healthcare organizations
- Medicare enrolled specialty practices
- Other eligible Part B providers and suppliers
Organizations that are not already enrolled in Medicare Part B must complete Medicare enrollment before they can participate. CMS directs organizations through PECOS for Medicare enrollment.
Primary Care and Referring Clinicians
A practice does not have to become an ACCESS participant simply because it refers patients to an ACCESS organization.
Primary care and referring clinicians can:
- Identify appropriate patients
- Refer eligible Original Medicare beneficiaries
- Receive electronic care updates
- Review those updates
- Coordinate care with the ACCESS organization
- Document qualifying activities
- Bill the applicable ACCESS Co Management Payment when requirements are met
CMS specifically designed ACCESS to work alongside existing primary care rather than replace it.
What Conditions Does ACCESS Cover?
The initial ACCESS model contains four clinical tracks.
Early Cardio Kidney Metabolic Track
The eCKM track addresses:
- Hypertension
- Dyslipidemia
- Obesity or overweight with a marker of central obesity
- Prediabetes
CMS uses measures such as blood pressure, LDL cholesterol, HbA1c and weight to evaluate outcomes.
Cardio Kidney Metabolic Track
The CKM track covers:
- Diabetes
- Chronic kidney disease, stages 3a or 3b
- Atherosclerotic cardiovascular disease
Measures can include blood pressure, LDL cholesterol, HbA1c, weight, urinary albumin to creatinine ratio and eGFR.
Musculoskeletal Track
This track focuses on chronic musculoskeletal pain.
CMS uses patient reported measures related to physical function, pain interference and overall improvement.
Behavioral Health Track
The initial behavioral health track covers:
- Depression
- Anxiety
Outcome measures include PHQ 9, GAD 7 and a patient global impression of change measure.
New Tracks Starting April 1, 2027
CMS has announced additional ACCESS tracks for:
- Heart failure
- COPD
- Substance use disorder
- Tobacco cessation
- A follow-on period for chronic musculoskeletal pain
Current participants and applicants do not need to submit a new application for these tracks.
Guidelines for Providers Referring Patients to ACCESS
Primary care and referring clinicians should understand that ACCESS is voluntary for Medicare beneficiaries.
Eligible patients have Original Medicare and qualifying conditions. Patients can enroll directly with an ACCESS organization or enroll following a referral from their healthcare provider.
Identify the patient’s condition
First, determine whether the patient has a condition covered by an ACCESS clinical track.
For example, a provider may have a Medicare patient with:
- Hypertension or dyslipidemia
- Diabetes or chronic kidney disease
- Chronic musculoskeletal pain
- Depression or anxiety
The provider then considers whether ACCESS could provide additional chronic care support for that patient.
Confirm Original Medicare eligibility
ACCESS is designed for eligible beneficiaries with Original Medicare.
The practice should verify the patient’s Medicare status before treating the patient as an ACCESS referral. This is important because Medicare Advantage enrollment and Original Medicare participation are not interchangeable for this model.
Identify an appropriate ACCESS organization
The provider identifies an ACCESS participant that offers care for the patient’s condition.
The organization may provide technology supported monitoring, coaching, behavioral health support, chronic condition management, or other services covered by the applicable ACCESS track.
The referring provider should understand what the organization offers and how it will communicate clinical information back to the practice.
Support patient enrollment
The patient must choose to participate.
The provider can explain why the ACCESS service may be useful and help connect the patient with the ACCESS organization. The ACCESS organization then handles the applicable enrollment process.
The important point is that the provider is not automatically enrolling every eligible Medicare patient into ACCESS.
Receive ACCESS Care Updates
Once the patient participates, the ACCESS organization can send relevant information to the patient’s primary care or referring clinician.
A Care Update can contain information that helps the clinician understand what happened during the patient’s ACCESS care and whether something may require clinical attention.
This creates a communication loop between the ACCESS organization and the patient’s existing healthcare team.
Review the Care Update
The clinician reviews the information and determines whether action is needed.
Simply receiving or opening an update does not automatically create a billable CMP service.
For CMP billing, CMS requires the practitioner to review the applicable ACCESS Care Update and perform at least one qualifying care coordination activity.
Perform qualifying care coordination
This is the clinical part of the process.
For example, after reviewing the update, the clinician might:
- Reconcile the patient’s medications
- Adjust a medication when clinically appropriate
- Update the patient’s problem list
- Change monitoring instructions
- Coordinate with another healthcare professional
- Communicate with the ACCESS organization
- Agree or disagree with an ACCESS recommendation and document the clinical reasoning
CMS requires at least 5 minutes spent on the required review and coordination activity for CMP billing.
Document the work
The provider should document what actually happened in the medical record.
The documentation should support the claim. A note saying only “ACCESS report reviewed” would not adequately describe the clinical coordination performed.
Submit the CMP claim when eligible
If the provider meets CMS requirements, the billing team can submit the appropriate Co Management Payment code.
For example:
- G0676: eCKM or CKM
• G0677: Musculoskeletal
• G0678: Behavioral Health
The billing team should also check the applicable frequency limitations and other CMS claim requirements before submission.
What “ACCESS does not replace the existing clinical relationship” means
This is probably the most important concept.
Imagine a primary care physician manages a patient’s diabetes. The patient also enrolls with an ACCESS organization that provides technology supported chronic care.
The ACCESS organization may monitor the patient and send the physician a care update.
The physician still remains responsible for the patient’s primary care decisions within their existing clinical relationship. The ACCESS organization adds another layer of support and information. It does not automatically become the patient’s replacement primary care provider.
Providers should create coordinated chronic care, where information from the ACCESS organization can reach the patient’s existing clinician and the clinician can act on clinically relevant information when appropriate.
ACCESS Co Management Payment for Providers
One of the most important billing changes for primary care and referring clinicians is the new Co Management Payment.
CMS allows eligible Medicare Part B practitioners to bill CMP HCPCS codes when they review an ACCESS Care Update and perform at least one qualifying care coordination activity.
Eligible practitioners include:
- Physicians
- Nurse practitioners
- Physician assistants
- Certified clinical nurse specialists
- Clinical psychologists and independently billing psychologists
- Licensed clinical social workers
- 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
FQHCs and RHCs become eligible for CMP billing for dates of service beginning October 1, 2026. Certain pharmacies also become eligible at that time.
What Must a Provider Do Before Billing CMP?
CMS requires more than simply receiving an ACCESS update.
The practitioner must:
- Review the ACCESS Care Update for the beneficiary and applicable track.
- Perform at least one qualifying care coordination activity.
- Spend at least 5 minutes on the review and related coordination activity.
- Document the work.
- Submit the appropriate CMP code according to CMS billing requirements.
Qualifying activities can include medication reconciliation or adjustment, updating the problem list, modifying monitoring instructions, coordinating with other clinicians, communicating with the ACCESS organization, or documenting agreement or disagreement with ACCESS recommendations and the clinical rationale.
ACCESS CMP HCPCS Codes
CMS currently identifies three main CMP codes:
- G0676: eCKM or CKM care update review and care coordination
• G0677: MSK care update review and care coordination
• G0678: Behavioral Health care update review and care coordination
CMS lists an allowed amount of $30 for each of these codes, subject to applicable Medicare payment adjustments. Modifier AC can provide an additional $10 for qualifying initial onboarding support and device or application setup.
CMP payments are generally available up to three times every 12 months per beneficiary per ACCESS track. A clinician may bill for more than one ACCESS track for the same beneficiary when the required activities are distinct and separately performed.
Documentation Requirements
Documentation will be particularly important because CMP payment depends on the actual work performed.
The medical record should make it possible to establish:
- Which ACCESS patient and track the clinician reviewed
- Date of the review
- ACCESS Care Update reviewed
- Clinical information considered
- Coordination activity performed
- Any medication or treatment changes
- Communication with the ACCESS organization or other clinicians
- Clinical agreement or disagreement with recommendations when applicable
- Time spent, including the required minimum of 5 minutes
- Follow up instructions or monitoring changes
The record should describe the actual clinical activity rather than simply stating that an ACCESS report was reviewed.
For billing teams, the safest workflow is to connect the claim to documentation before submitting it.
Important Medicare Billing Rule for ACCESS Participants
Healthcare organizations that actually participate in ACCESS need to understand a major difference from ordinary Medicare FFS billing.
ACCESS payment is an alternative payment approach for aligned beneficiaries during an active ACCESS care period. ACCESS participants and affiliated entities generally cannot continue submitting traditional Medicare FFS claims for other services furnished to those same aligned beneficiaries during that active care period.
CMS states that only the applicable ACCESS G codes may be billed for aligned beneficiaries during those periods.
This makes patient alignment and billing status extremely important.
A billing department should not assume that an ACCESS beneficiary can be handled exactly like every other Medicare FFS patient.
HIPAA and Data Exchange Requirements
ACCESS relies heavily on electronic exchange of clinical information.
Participating organizations must comply with applicable HIPAA requirements and maintain appropriate administrative, technical and physical safeguards for protected health information. CMS also expects secure, interoperable systems for enrollment, eligibility, clinical data exchange, reporting and care coordination.
Care updates to primary care and referring clinicians should use HIPAA compliant electronic methods. CMS identifies options such as Direct Secure Messaging, network supported exchange mechanisms and HIPAA compliant electronic fax.
Medicare Enrollment Is a Core Requirement
An organization considering ACCESS participation should review its Medicare enrollment status early.
CMS requires ACCESS participants to be enrolled in Medicare Part B. Organizations not already enrolled must complete the Medicare enrollment process. CMS notes that organizations can use PECOS and that applicants should obtain an NPI through NPPES before submitting a Medicare enrollment application when necessary.
The organization must also meet standard Medicare participation requirements.
Individual physicians and non-physician practitioners furnishing or supervising ACCESS care must be individually Medicare enrolled and have their billing rights reassigned to the ACCESS participant organization.
What Billing and RCM Teams Should Watch
For medical billing companies, practice administrators and RCM teams, ACCESS introduces several operational issues.
Patient Alignment
Your system needs to distinguish ACCESS aligned beneficiaries from ordinary Medicare FFS beneficiaries.
Track Identification
The billing team needs to know whether the patient’s care falls under eCKM, CKM, MSK or BH.
G Code Accuracy
Claims need the correct ACCESS code for the clinical track and service performed.
Documentation
The claim should have corresponding documentation showing that the required review and coordination occurred.
Frequency Limits
CMP claims cannot simply be billed whenever an ACCESS update arrives. CMS establishes frequency limitations, including the three payments per 12 months per beneficiary per track rule.
Diagnosis Coding
For FQHC and RHC CMP billing, CMS specifically requires an applicable track diagnosis and states that claims without a valid qualifying diagnosis can be denied.
FQHC and RHC Claims
Beginning October 1, 2026, FQHCs and RHCs submit CMP claims as institutional claims. CMS specifies electronic 837I submission or CMS 1450, also known as UB 04, when paper submission is permitted.
ACCESS and ACOs
ACCESS can also matter to organizations participating in accountable care arrangements.
CMS describes ACCESS as complementary to ACO and other risk bearing models. Risk bearing organizations can refer aligned beneficiaries to ACCESS participants as an additional chronic care resource.
There is an important timing issue. CMS anticipates that ACCESS Outcome Aligned Payments will not affect ACO benchmark and performance year calculations for 2026 and 2027. Beginning in 2028, ACCESS expenditures will be included in ACO benchmark and performance year calculations.
Organizations operating in an ACO environment should therefore review the ACCESS rules alongside their existing ACO agreements and compliance policies.
Bottom
The CMS ACCESS Model changes the way participating organizations are paid for technology supported chronic care. It is not simply another Medicare billing code program.
For an ACCESS participant, Medicare enrollment, clinical oversight, technology infrastructure, patient alignment, outcome measurement, documentation and specialized billing all matter.
For a primary care or referring clinician, the most relevant opportunity may be referral and ongoing coordination. Eligible clinicians can review ACCESS care updates, perform qualifying coordination work and bill the applicable CMP code when CMS requirements are met.
Because ACCESS launched in July 2026 and CMS is continuing to add operational guidance, providers and billing teams should use the current CMS ACCESS materials rather than relying on older chronic care or remote monitoring billing rules. CMS’s main ACCESS page, technical FAQs and CMP billing guidance are the key references for current requirements.
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Frequently Asked Questions
What is the CMS ACCESS Model?
The CMS ACCESS Model, or Advancing Chronic Care with Effective, Scalable Solutions, is a voluntary Medicare model that supports technology enabled chronic care. It uses outcome aligned payments for participating organizations and also allows eligible primary care and referring clinicians to receive Co Management Payments for qualifying care coordination activities.
Which healthcare providers can participate in the ACCESS Model?
Eligible Medicare Part B enrolled providers and suppliers can participate as ACCESS organizations, subject to CMS requirements. Primary care and referring clinicians can also work with ACCESS organizations without becoming ACCESS participants themselves. Eligible clinicians may review ACCESS Care Updates and bill applicable Co Management Payment codes when they meet CMS requirements.
Does a primary care provider have to join ACCESS to refer a patient?
No. A primary care or referring clinician does not have to become an ACCESS organization simply because they refer a patient. The clinician can refer an eligible Original Medicare beneficiary to an appropriate ACCESS organization and continue managing the patient’s existing care relationship.
Can providers bill for reviewing an ACCESS Care Update?
Eligible clinicians may bill a Co Management Payment when they meet CMS requirements. Reviewing the update alone is not enough. The clinician must review the applicable Care Update, perform at least one qualifying care coordination activity, spend at least the required minimum time, and document the work.
What are the ACCESS Co Management Payment codes?
CMS identifies three primary CMP codes based on the clinical track: G0676 for eCKM or CKM, G0677 for musculoskeletal care, and G0678 for behavioral health. Providers should verify current CMS billing guidance before submitting a claim because model requirements can change.
How much time must a clinician spend to bill a CMP?
CMS requires at least 5 minutes for the required Care Update review and qualifying care coordination activity. The medical record should support the work performed and the time requirement.
How often can a provider bill a CMP?
CMS generally limits CMP payments to three times during a 12-month period for a beneficiary within an ACCESS clinical track. Additional rules can apply when a beneficiary participates in more than one track, so billing teams should check the current CMS guidance before submitting claims.
Does ACCESS replace the patient’s primary care provider?
No. ACCESS is designed to add chronic care support and coordination around the patient’s existing healthcare relationships. A referring clinician can continue managing the patient’s care while receiving relevant information from the ACCESS organization and acting on it when clinically appropriate.
What documentation should providers maintain for ACCESS billing?
Documentation should show that the clinician reviewed the applicable ACCESS Care Update and performed a qualifying coordination activity. Depending on the situation, this may include medication reconciliation, treatment or monitoring changes, communication with another clinician or the ACCESS organization, and the clinical reasoning behind a decision.
What should a medical billing team check before submitting an ACCESS claim?
The billing team should verify the patient’s applicable ACCESS track, eligibility, correct CMP code, provider eligibility, documentation, frequency limitations, diagnosis requirements where applicable, and any other current CMS claim requirements. ACCESS claims should not be processed using assumptions from ordinary Medicare billing because the model has its own payment and participation rules.
