Most of the conversation about CMS ACCESS has focused on the participating organizations, the outcome risk, and the technology requirements. The question physicians ask most is simpler and more practical.
What does this mean for my practice's revenue?
The answer is straightforward. CMS ACCESS creates a new recurring payment stream for referring physicians and practices, approximately $100 per patient per year, for documented review and care coordination activity. No outcome risk. No change to existing Medicare billing. No new administrative infrastructure required.
This post explains exactly how the co-management fee works, what it requires, and how to make sure your practice actually earns it.
What the ACCESS Co-Management Fee Is
When a Medicare patient enrolls with an ACCESS participant, CMS creates a co-management payment for the referring clinician. This is a separate payment, on top of standard fee-for-service billing, that compensates the referring provider for reviewing clinical updates, documenting care coordination activity, and maintaining oversight of the patient's care plan during the ACCESS program period.
The co-management fee structure pays approximately $30 per service, billable up to three times per 12-month care period, plus a one-time $10 initial visit modifier per patient at enrollment. That adds up to approximately $100 per patient per year.
The payment does not require a referral to trigger enrollment. A patient can attest directly to an ACCESS participant without your practice's involvement. But co-management revenue only flows to providers who receive the care update from the ACCESS participant and who complete the required documentation for each billing event. A structured relationship with an ACCESS participant guarantees that payment flows to your providers.
What Qualifies for the Co-Management Payment
Each co-management billing event requires documented review of an ACCESS Care Update delivered by the participating organization. There are four types of updates that trigger a billable co-management service:
Care initiation update. Delivered when the patient enrolls and the care program begins. This confirms the patient's enrollment, the conditions being managed, the care plan, and the initial clinical baseline. Reviewing and documenting this update qualifies for the first co-management billing event.
Care update. Delivered during the regular course of the care program to provide an update to the provider on the status of the patient and care activities completed or in progress. The provider reviews the alert, documents the activity, and signs a note confirming clinical oversight. This qualifies for a co-management billing event.
Clinical escalation alert. Delivered when a deterioration event occurs: a reading outside target range, a medication change, an acute clinical development. The provider reviews the alert, documents the activity, and signs a note confirming clinical oversight. This qualifies for a co-management billing event.
Care period summary. Delivered at the end of the 12-month care period, summarizing clinical progress, outcome attainment, and any ongoing care plan recommendations. Reviewing and documenting this update qualifies for the final co-management billing event.
Each review is designed to take a minimum of five minutes, which must be captured in the documentation. CMS does not require a face-to-face visit. The documentation requirement is structured to fit into existing clinical workflows, not add a new administrative layer on top of them.
What the Math Looks Like Across a Practice
The co-management fee is modest per patient. Across a Medicare panel with a meaningful chronic disease burden, it adds up quickly.
A primary care practice with 500 Medicare patients who have qualifying chronic conditions under Early CKM or Advanced CKM is a reasonable starting point for many practices. At approximately $100 per patient per year, that represents $50,000 in co-management revenue annually, on top of existing FFS billing, with no outcome risk and no change to how the practice operates.
For a larger group practice managing 2,000 qualifying Medicare patients, the co-management revenue approaches $200,000 annually. That figure does not include the FFS visit volume that proactively managed patients generate as they stay engaged with their primary care team rather than deferring appointments or presenting through the emergency department.
The co-management fee is additive. Every office visit, specialist referral, lab, and procedure the practice bills today continues at standard Medicare rates. ACCESS billing exclusions apply to the ACCESS participant, not to the referring provider. The practice's existing revenue base is untouched.
What Can Go Wrong
The co-management revenue is real and straightforward to earn. There are two ways practices miss it.
Choosing an ACCESS partner who does not deliver structured care updates. The co-management payment requires documentation of a care update review. If the ACCESS participant your patients are enrolled with does not deliver structured, timely updates through your existing EHR workflow, your practice cannot complete the documentation and cannot bill. Patients are enrolled, the participant is paid, and your practice earns nothing for the clinical relationship you spent years building.
This is not a theoretical risk. More than 150 organizations are enrolled as ACCESS participants. They include consumer wellness apps and digital health platforms that have no obligation to deliver bidirectional PCP communication beyond the minimum program requirements. Some will deliver it well. Others will not.
Not knowing which patients are enrolled. Patients can attest directly to ACCESS participants. Your practice may not know a patient has enrolled until the first care update arrives, or until the patient mentions it at their next appointment. Practices without a systematic way to identify their enrolled patients cannot proactively manage the co-management billing cycle or ensure updates are being received and documented.
Both problems have the same solution: a structured partnership with an ACCESS participant whose operating model is built around the referring provider, not around the patient in isolation.
What a Structured Partnership Looks Like
Innovaccer operates through Story Health Partners, its CMS-accepted physician entity, as a first-cohort ACCESS participant. The co-management model is built around three commitments to referring practices.
Every care update reaches the referring provider through their existing EHR workflow, not a separate portal, not a fax queue, not a monthly PDF summary. Structured updates arrive at care initiation, at regular update intervals, at any clinical escalation, and at care period close.
Every specialist referral generated during the ACCESS care period routes back into your practice's network. Patients managed under ACCESS do not generate referral volume for someone else's specialists, labs, or pharmacies.
Your practice carries no outcome risk. If enrolled patients do not meet their clinical targets, Innovaccer carries the financial consequence under the Story Health Partners structure. Your co-management revenue and FFS billing are not tied to whether patients hit their blood pressure or HbA1c goals.
How to Find Out What Your Practice Can Earn
The co-management revenue opportunity is specific to your Medicare panel: how many patients qualify, which tracks they fall into, and what the billing cycle looks like across a 12-month period.
The starting point is a population analysis: mapping your attributed Medicare patients against Early CKM and Advanced CKM eligibility criteria, identifying the qualifying population, and modeling the co-management revenue that population represents.
That analysis takes a 20-minute conversation and produces a practice-specific revenue model before any commitment is made.
Book an opportunity analysis with Innovaccer's ACCESS team. We will map your eligible Medicare patients by condition, model your co-management revenue across a 12-month period, and walk through exactly how the partnership works. No commitment required.