The Alliance for Connected Care wrote to Abe Sutton, Director of the CMS Center for Medicare and Medicaid Innovation (CMMI), congratulating CMS on the launch and expansion of the ACCESS (Advancing Chronic Care with Effective, Scalable Solutions) Model and asking CMMI to test a complementary payment model for technology-enabled care management.

The Alliance supports ACCESS’s move toward outcome-aligned payment, and several of our members are participating. We expect it to be a valuable test of direct-to-consumer chronic disease interventions and look forward to early data on AI-enabled care management.

But ACCESS is an addition to, not a replacement for, the care management services Medicare covers today. It wasn’t designed for higher-acuity patients with multiple complex conditions, or for those who need hybrid in-person and virtual care. For example, it doesn’t substitute for clinician-directed Remote Physiologic Monitoring (RPM) used to address a medication need or prevent a readmission, or for Remote Therapeutic Monitoring (RTM) supporting post-surgical patients during a defined episode of care.

Our request

Reflecting CMS’s questions about care management in the CY2027 Physician Fee Schedule RFI, we asked CMMI to test a pathway between fee-for-service and ACCESS that would:

  • Use risk-based or outcome-based payments to align incentives and reduce inappropriate utilization.
  • Preserve practitioner-led care, with meaningful general supervision by an ordering provider and no fee-for-service exclusion.
  • Benchmark initial payments to practitioners’ current costs, keep them at risk, and reevaluate over time.
  • Expand delivery flexibility as provider accountability grows, allowing automation and innovation to lower costs.

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