Just one week after CMS announced a major expansion of its ACCESS Model, William Gordon, senior advisor at Manatt Health and one of the model’s architects, spoke in Arlington at the Civitas Networks for Health 2026 Annual Conference to explain what the growing program could mean for technology-enabled care and the health information infrastructure needed to support it.
The Advancing Chronic Care with Effective, Scalable Solutions (ACCESS) Model, which launched in July, is a 10-year national demonstration that introduces outcome-aligned payments for technology-supported chronic care for people with Original Medicare. CMS’ latest expansion adds new tracks for heart failure, chronic obstructive pulmonary disease, substance use disorder and tobacco cessation beginning in April 2027.
Gordon, a physician and former CMS chief informatics officer who helped design ACCESS, said the expansion further signals that CMS is “doubling down” on outcome-aligned payments and giving organizations greater flexibility to use technology to deliver care.
Under ACCESS, participating organizations receive recurring payments for managing eligible chronic conditions, with up to half of their potential payment tied to measurable clinical outcomes. Care can be delivered in person, virtually, asynchronously or through connected devices.
But that flexibility comes with another important component: interoperability.
Interoperability Is a Requirement
ACCESS participants must make a good-faith effort to identify a beneficiary’s primary care provider or referring clinician and proactively share standardized care updates through a secure exchange mechanism. Query-based exchange alone does not meet the requirement.
Participants must also establish bidirectional connectivity with a health information exchange or health information network covering their care delivery geography within 12 months of entering the model. They must be able to exchange care plans, care updates and other clinical information with patients’ existing providers and care teams.
Those requirements are intentional. Gordon said one concern raised during development of ACCESS was that bringing new technology-enabled providers into Medicare could further fragment care. The interoperability requirements are designed to help those organizations operate alongside, rather than separately from, patients’ existing care teams.
That creates a significant role for HIEs and health data utilities (HDU). HIEs can help ACCESS participants obtain clinical information needed to establish eligibility and baseline measures, route care plans to existing providers, support closed-loop referrals and escalation when patients need a higher level of care, and gather the data needed to measure and report outcomes to CMS.
The infrastructure could be particularly important for national and virtual-first organizations that may be delivering technology-enabled care across dozens of local healthcare markets without established relationships with providers in those communities.
Connecting a More Distributed Care System
Gordon said ACCESS also points toward a broader change in how healthcare could be delivered.
The traditional model has largely centered care around established health systems, practices and EHRs. ACCESS introduces another possibility: technology-enabled organizations providing specialized, longitudinal care alongside traditional providers, with payment tied to outcomes rather than individual services.
“The future ecosystem is one of a mixed network of traditional and technology providers,” Gordon said.
That creates more flexibility in where and how care is delivered, but it also increases the need to connect information across organizations and geographic boundaries.
For HIEs and HDUs, Gordon argued, that could mean an expanding role in providing the infrastructure that allows a more distributed healthcare system to function as a coordinated one.
