The Centers for Medicare & Medicaid Services (CMS)’s ACCESS model marked a significant shift: Traditional Medicare paying for clinical results, not just services delivered.

As AI continues to reshape the economics of care delivery, ACCESS can pave a pathway for the healthcare sector to shift to outcome-based payment models for chronic condition management, whether delivered by a traditional provider or technology company.

In a September 2026 comment letter to CMS, the Center offered recommendations for the agency’s 2027 Medicare Physician Fee Schedule proposed rule. Specifically:

• CMS should not proceed with the current proposal to only pay for remote monitoring services when clinical staff are direct employees of the billing practitioner or practice, or with the rate cuts as proposed. These changes effectively prohibit qualified, contracted personnel from furnishing remote monitoring services and threaten access to high-value health technologies for Medicare beneficiaries, in addition to curbing low-value services.
• CMS should evolve remote monitoring services to be outcomes-aligned by: introducing a six-month duration limit with an active redetermination of medical necessity, ensuring similar, viable payment rates across fee-for-service remote monitoring and the ACCESS model, requiring clinical outcome reporting for services, and ensuring a pathway for traditional providers to be paid based on outcomes, as is done in ACCESS, which traditional providers do not have an option for today. Over time, all chronic condition management with well-established clinical outcomes should transition to an outcome-based payment model.
• CMS should strengthen the ACCESS model so that it can serve as a primary pathway for evidence-based, technology-enabled chronic condition management for Medicare beneficiaries. CMS should consider developing new model tracks and introducing risk adjustment or sub-tracks for highly complex patients.
• CMS must accelerate the transition of technology-enabled services toward outcome-based payment models as AI is increasingly changing the underlying economics of healthcare delivery. Fee-for-service payment—today’s predominant payment model—was not designed for technologies that can perform clinical work that previously required human labor and expertise.