Three weeks after the CMS ACCESS launch, primary care physicians are asking the same five questions. Not about whether the program is a good idea. About what it actually means for their patients and their practice, starting now.
The American Medical Association, the American Academy of Family Physicians, and CMS's own physician FAQ page have all published guidance in response to these concerns. The answers are clearer than most of the market commentary suggests. Here is what physicians need to know.
1. Will My Patients Tell Me They Enrolled?
Probably not proactively. And they are not required to.
Patients can enroll directly with an ACCESS participant by phone or online. No referral is required. A Medicare patient with hypertension, prediabetes, or chronic kidney disease in your panel can attest to any enrolled ACCESS participant today without your knowledge or sign-off.
This is the detail that concerns most primary care physicians, and the concern is legitimate. A patient whose care plan is being actively managed by an organization you have never heard of, without any obligation to notify you, is a patient whose medication changes, remote monitoring readings, and specialist referrals may be happening outside your clinical record.
What CMS has built as a safeguard is a mandatory care update requirement. ACCESS health care providers are required to proactively share care updates with referring clinicians at key points via HIPAA-compliant secure electronic methods such as Direct Secure Messaging, network-supported push mechanisms, or HIPAA-compliant eFax. By July 2027, all participating ACCESS organizations will be required to connect to a Health Information Exchange or similar trusted network, making clinical and medication data queryable through your existing EHR workflows.
The operative word is "required." Whether participating organizations deliver on that requirement depends on who they are and how their operating model is built. The update obligation exists in the program rules. Execution varies by participant.
2. Does ACCESS Change My Billing or My FFS Revenue?
No, with one important clarification.
If you are an eligible Medicare Part B-enrolled practitioner, you can refer patients and bill co-management payments. Referring a patient to ACCESS does not change your relationship with them. Your patient can continue to see you and any other health care provider that accepts Medicare.
The FFS billing restriction applies to ACCESS participants, not to referring physicians. The enrolled organization, the one managing the patient between visits, cannot bill traditional Medicare fee-for-service for the chronic condition being managed during the ACCESS care period. Your practice faces no such restriction. Every office visit, specialist referral, lab, and procedure your team bills today continues at standard rates.
On top of existing billing, ACCESS creates a new co-management payment for referring physicians. Primary care is expected to participate mainly via referrals and co-management, including a new payment approximately every four months for reviewing updates and coordinating care, without cost-sharing. CMS pays approximately $100 per patient per year for documented review and care coordination activity. No outcome risk. No enrollment requirement. No new administrative burden beyond documenting the review.
The revenue math is straightforward. Your existing billing is untouched. A new co-management stream is additive. The only condition is that the ACCESS participant you are working with keeps you in the clinical loop with structured, timely care updates.
3. Who Is Actually Managing My Patients Between Visits?
That depends on which ACCESS participant your patient chose, and the range is wide.
Nearly 200 organizations are participating in the CMS ACCESS Model. Some of the names involved include Alyka Health, Headspace, Liza Health, Noom, Weight Watchers, and Withings. These organizations sit alongside clinical platforms, specialty care companies, and health system-backed programs in the same participant directory.
CMS does not mandate clinical depth. The program sets outcome thresholds and payment rules. It leaves the quality of between-visit care to the market. A patient enrolled with a consumer wellness app receives a different level of clinical management than one enrolled with a program that monitors biometrics in real time, adjusts medications per evidence-based protocols, and routes escalations to a licensed clinician within hours.
Both count as ACCESS participation. Both generate the mandatory care update obligation. What differs is whether your patient is receiving continuous clinical management or periodic app-based check-ins rebranded as chronic care.
CMS plans to publicly post outcome data for all participating organizations, giving referring physicians a basis for evaluating which partners deliver results. That public outcomes data will not be available until Winter 2028. Until then, the participant directory and each organization's own published clinical model are the primary tools physicians have for making informed referral decisions.
The practical implication is this: physicians who choose an ACCESS partner proactively, rather than waiting to see who their patients enroll with, retain more control over the quality of between-visit care their patients receive.
4. What Clinical Updates Will I Actually Receive?
The ACCESS program mandates three types of updates from participating organizations to referring clinicians.
A care initiation update at enrollment, confirming the patient has enrolled and the care program has begun. A clinical escalation alert when a deterioration event occurs, a reading outside target range, a medication change, or an acute clinical development that requires the referring physician's awareness. A care period summary at the end of the 12-month care period.
These care updates are delivered via HIPAA-compliant electronic methods such as Direct Secure Messaging, network-supported push mechanisms, or HIPAA-compliant electronic fax. By July 2027, all participating ACCESS organizations will be required to connect to a CMS Aligned Network, Health Information Exchange, or similar trusted network. Clinical and medication data, including blood pressure, HbA1c, LDL-C, weight, patient-reported outcome measures, and medications where applicable, should be queryable through your existing EHR workflows.
The 2027 HIE connectivity requirement is the structural guarantee. Until it is in place, the speed and format of updates depend on the participant's own infrastructure. Organizations delivering updates via Direct Secure Messaging into your EHR inbox are operationally different from those sending a PDF by fax at care period close.
The AAFP specifically raised the question of transparency between ACCESS participants and primary care physicians as a central concern in its advocacy to CMS. The AAFP is advocating to make sure the ACCESS model does not disrupt the physician-patient relationship, and has asked CMS for clarity on how the agency will promote transparency between ACCESS participants and primary care physicians about the technologies used in the model. That advocacy shaped the mandatory update requirements now embedded in the program rules.
5. What Happens to My Patients If the ACCESS Participant Does Not Perform?
Your patients continue receiving care. Your billing is unaffected. The financial consequence of poor performance falls entirely on the ACCESS participant.
ACCESS participants can earn full payment if a minimum share of their aligned patients meet their OAP measure targets. This minimum share is called the Outcome Attainment Threshold. The OAT for the first model year is 50 percent. This means an organization can earn 100 percent of payments if at least 50 percent of their aligned beneficiaries whose 12-month care period ended during the assessment period meet all required outcome targets. If fewer than 50 percent of patients meet their targets, the organization's payment will be reduced proportionally.
The withhold structure reinforces this. CMS distributes 50% of outcome-aligned payments upfront and releases the withheld 50% after reconciliation against clinical outcome targets. An ACCESS participant that fails to move clinical numbers loses the withheld revenue. That financial exposure belongs to the participant, not to the referring physician.
For physicians evaluating which ACCESS participant to refer into, the OAT structure is a useful signal. An organization confident enough in its clinical model to absorb the 50% withhold risk is a different category of partner from one whose financial model depends on enrollment volume rather than outcome performance. Ask potential partners directly: who absorbs the outcome risk if your patients do not hit their targets?
The One Thing Physicians Should Do Right Now
The five questions above have clear answers from CMS. The one that does not have a simple answer is the practical one: which ACCESS participant should be managing your patients?
CMS will not publish risk-adjusted outcomes data until Winter 2028. Until then, physicians evaluating ACCESS partners should ask three questions directly. Does the participant deliver real-time, EHR-integrated clinical updates or periodic summaries? Does the participant route specialist referrals back to my network or out of it? And who absorbs the outcome risk if patients do not hit their targets?
Innovaccer operates through Story Health Partners, its CMS-accepted physician entity, and absorbs all outcome risk. Every clinical update flows back to referring providers through existing EHR workflows in real time. Every specialist referral routes back in-network. Referring physicians earn approximately $100 per patient per year in co-management fees with no outcome risk, no change to FFS billing, and no implementation burden.
Your patients are enrolling in ACCESS now. The question is whether they are enrolling with a partner that keeps you at the center of their care or one that manages around you.