More About the CMS Access Program

by Elena Dicus

ACCESS Technology Requirements: Build, Buy, or Both?

Are you interested in the ACCESS program and already read our first blog post on the subject? Ready to learn more? Given that the first application is due on April 1^st, if this seems complicated, you may want to think about the second application period on January 1, 2027.

Technology requirements are at the core of any assessment of ACCESS program participation. For many practices, your various systems may already provide elements of the required technology and functionality. You will need to carefully review the detailed requirements for each aspect of the program, assess against your current technology and platforms, and find any gaps. Then, assess solutions that fill the gaps. This is likely the most cost-effective approach although it will also entail more ongoing oversight and management by your practice or IT support. Alternatively, vendors are developing plug-and-play solutions; these solutions are likely specific to each track, so your practice will need to consider the economic viability of multiple platforms if your practice will participate in multiple tracks.

Health Data

Step 1: Identifying and Verifying Eligible Patients

Practices will need to find potentially eligible patients based on inclusion and exclusion criteria. These are defined at the overall ACCESS program level and practices can also request additional specific exclusions during the application, which CMS will consider. For example, exclusion criteria for MSK include eight criteria ranging from pregnancy to significant trauma, to the affected area, to frailty.  For many practices, your EMR will provide patient lists, but you will also likely want to review the list of patients to assess which patients may have barriers to participation and which may be highly motivated to engage. Notably, your practice does not need a Certified Electronic Health Record Technology (CEHRT) EMR to participate.  When potential enrollees are found, practices will need technology to confirm patient eligibility for the program. Before enrolling any patient, practices must query CMS Eligibility and Alignment APIs to verify coverage, exclusions, and randomization status (CMS will randomize a set of patients to a control group). This requires active API integration prior to any care delivery.  APIs are a coded connection between your EHR or billing system and CMS’ system.

Step 2: Enrolling Patients and Submitting Baseline Data

Once a patient has been identified as eligible, practices could reach out patients proactively or discuss the program with patients at an upcoming visit.  The ACCESS Provider is then responsible for validating that the beneficiary meets clinical eligibility requirements for the track (each track has specific qualifying criteria or diagnoses).  Before initiating enrollment (referred to in the ACCESS program as alignment), the ACCESS Provider must obtain and document the beneficiary’s informed consent. Consent may be provided verbally or in writing and must be documented in the patient’s record.  There are specific elements of consent unique to the ACCESS program that must be recorded.   Your practice must then use another API to align the beneficiary with your practice.  Within a defined number of days after enrollment (typically 60 days), your practice must submit baseline clinical and patient-reported outcome (PRO) measures through specific APIs; these APIs are the only way the data can be submitted. Depending on the specific measure, the data must have been collected within the past 15 days to two years.  These baseline data establish the analytic starting point for outcome measurement and are required to maintain enrollment.  If baseline data are not submitted within the initial required timeframe, CMS will treat it as if your practice has not enrolled the patient.

Step 3: Ongoing Reporting and Outcome Measure Submissions

In the ACCESS program, each patient has a unique enrollment year based on their date of enrollment rather than a consistent annual program period.  During the enrollment year your practice must submit monthly claims.  Each claim is an attestation of "active care delivery" and compliance with model requirements. Active care delivery is defined as the ongoing provision of services consistent with ACCESS Model such as patient engagement, monitoring, and timely collection and reporting of quality measures. Additionally, ACCESS participants must submit required outcome measure data (referred to as Outcome Aligned Payments or OAP) at required intervals. 

Each track includes a targeted set of condition-specific OAP measures which must be submitted within defined timeframes to remain eligible to bill monthly claims. These measures include,for example, regular blood pressure and weight for the cardio-kidney-metabolic tracks and PROMs and pain measurements for MSK. PROM data collection for the MSK and BH tracks must meet specific question and user interface requirements that likely need a technology platform for your practice support data collection. Lastly, all clinical data must be submitted via a CMS designated API with standardized data elements. Both monthly billing and OAP measure reporting are mandatory for remaining in the program.

Step 4: Coordinating Care with PCPs and Referring Clinicians

Finally, practices must share regular clinical updates with patients' PCPs using specified technology.  ACCESS Participants are required to support care coordination by making reasonable efforts to identify beneficiaries’ existing care team members—specifically any primary care practitioner (PCP) and referring clinician, if applicable—and to share standardized clinical updates at key points in care.  This requires that you ask the patient about care team members, confirm CMS-supplied data about patients’ care team members, and document all efforts to identify care team members in the patient's record.  Additionally, you must obtain the patient's consent to sharing updates and document consent in the patient's record. The updates must use direct secure messaging technology and within twelve months of starting the ACCESS program, your practice must establish or maintain connectivity to a health information exchange (HIE) that enables bidirectional electronic exchange.  Direct faxing or portal messages will not meet this requirement.  Many HIEs offer direct secure messaging capabilities so joining an HIE from the start, if your practice does not already participate in one, would allow you to meet both requirements. CMS will provide a recommended template for care coordination updates.

Assessing Your Current Technology: Does it Meet ACCESS Requirements?

For groups considering whether to participate, an understanding of the core technology requirements is critical.  Practices may choose to partner with a single technology vendor or develop/obtain these components through a vended platform or on their own, but an understanding of the requirements is essential either way. Below is a checklist summarizing the technology requirements and an assessment of the complexity of each requirement considering the likely time, resource-intensity of adding each requirement if a practice does not already have it in place.

Technology requirement	What the technology is used for	Complexity assessment
CMS Eligibility API Integration	Verify beneficiary coverage criteria before enrollment	Moderate
CMS Alignment API Integration	Used to enroll beneficiaries before initiating services	Moderate
FHIR-Based Outcome Aligned Payment Reporting API	Must be used for submitting baseline, quarterly, and end-of-period submissions	High
Health Information Exchange (HIE) Connectivity	Enables bidirectional electronic exchange for sharing care coordination updates with PCP and referring clinicians	Moderate
Direct Secure Messaging	Share care coordination updates with PCPs and referring clinicians	Moderate
Connected Blood Pressure Cuff (eCKM/CKM tracks only)	Validated, upper arm cuff that supports timestamped, source-verifiable transmission	Moderate
PROM Administration System (MSK and BH tracks)	Validated instruments (must be administered digitally or via mixed-mode web/phone/paper. Wording, response options, and layout cannot be modified	Moderate–High