This blog article was updated on Jan 7, 2025
We'll continue updating this guide as CMS releases more details about ACCESS requirements and reporting.
The era of billing for "minutes spent" in behavioral health is ending. With the launch of the CMS Advancing Chronic Care with Effective, Scalable Solutions (ACCESS) Model, Medicare is transitioning toward a 10-year pilot program where payment is tied directly to clinical results rather than service volume.
For behavioral health (BH) organizations, the clock is ticking: Applications for the first performance period must be submitted by April 1, 2026. If your organization is still relying on a traditional Electronic Health Record (EHR) system designed for fee-for-service documentation, you are likely ill-equipped for this new regulatory reality.
What is the CMS ACCESS Model?
The ACCESS Model is a nationwide, voluntary 10-year test of Outcome-Aligned Payments (OAPs). Starting July 5, 2026, Medicare will provide recurring monthly payments to participating Part B providers who use technology to manage chronic conditions—specifically targeting depression and anxiety in the behavioral health track.
Unlike traditional billing, where revenue is guaranteed by the appointment, the ACCESS Model requires clinicians to achieve measurable health outcomes from a patient’s baseline to receive full reconciliation payments.
The Three Reasons Your EHR Fails the ACCESS Model
While most EHRs claim to be "outcome-focused," they were built as digital filing cabinets for legacy billing. Here is why they are a liability in the ACCESS framework:
1. Lagging Indicators vs. Predictive Intervention
The ACCESS Model rewards organizations for hospitalization avoidance and symptom improvement. Standard EHRs only record "lagging indicators"—manual survey scores (like PHQ-9) captured during an appointment. By the time a score spikes in your EHR, the patient may already be in crisis. To succeed, you need a system that provides leading indicators to intervene before symptoms reach an acute state.
2. Manual Reporting vs. FHIR API Requirements
The CMS ACCESS Model is a "hard gate" for data capability. Participants are required to report clinical outcomes—including vitals and survey scores—electronically through CMS-hosted FHIR-based APIs. Many legacy EHRs lack the real-time, high-fidelity interoperability required to maintain these recurring automated data flows.
3. Subjectivity and "Masking"
CMS has defined the following core measures for the BH track:
- PHQ-9 (Patient Health Questionnaire for depression)
- GAD-7 (Generalized Anxiety Disorder for anxiety)
- WHODAS 2.0 (12-item functional assessment)
EHRs treat these as static data points. However, patients often "mask" symptoms on subjective surveys. If your system cannot detect objective physiological distress when a patient reports they are "fine," you will miss the opportunities for early intervention that secure your Outcome-Aligned Payments.
To ensure your Behavioral Health (BH) organization is prepared for the July 2026 launch of the CMS ACCESS Model, use this checklist to verify eligibility and technical readiness.
I. Organizational Eligibility & Enrollment
- Medicare Part B Enrollment: Your organization must be a legal entity enrolled in Medicare Part B as a provider or supplier (excluding laboratory or DMEPOS-only entities).
- Active TIN: The organization must have an active Taxpayer Identification Number (TIN) that will serve as the primary identifier for model participation.
- Medical Director Appointment: You must designate a Clinical Director who is a Medicare-enrolled Medical Doctor (MD) or Doctor of Osteopathy (DO) responsible for clinical governance and oversight.
- Licensure Compliance: Ensure all individual practitioners (NPIs) delivering care are practicing within their specific state licensure and scope.
II. Technical "Hard Gates"
- FHIR API Readiness: Your organization must possess the infrastructure to report clinical outcomes (e.g., PHQ-9 and GAD-7 scores) electronically via CMS-hosted FHIR-based APIs.
- Bidirectional Data Sharing: You must be capable of electronically sharing care plans and clinical updates with a beneficiary's other healthcare providers (e.g., their primary care physician).
- Outcome Measurement Tracking: Confirm your system can consistently capture the required BH track metrics:
- PHQ-9 (Depression)
- GAD-7 (Anxiety)
- WHODAS 2.0 (Functional Assessment)
III. Program Selection & Patient Management
- Select the BH Track: Formally opt into the Behavioral Health Track, which targets patients with Original Medicare diagnosed with depression or anxiety.
- Beneficiary Enrollment Strategy: Develop a workflow for Direct Beneficiary Enrollment or managing referrals from community providers.
- Tech-Enabled Care Plan: Define how you will use technology-supported interventions—such as Bio-Linguistic Telemetry or remote coaching—to drive the "measurable improvement" required for full payments.
How to Fix the Gap Before April 1st
To qualify for the ACCESS Model, your clinical team needs more than just a place to store notes; they need a Scientific Engine like Mozu Health's COADIA.
By utilizing Bio-Linguistic Telemetry, Mozu Health provides clinicians with a 21-day predictive window for symptom spikes. This allows providers to adjust treatment plans (e.g., medication titration or therapy frequency) proactively. This "Human-in-the-Loop" approach ensures that by the time a patient's next PHQ-9 is recorded, they are trending toward the improvement targets required for CMS reimbursement.
Key Deadlines to Remember:
- January 12, 2026: CMS begins accepting ACCESS Model applications.
- April 1, 2026: Final deadline for the first performance period.
- July 5, 2026: ACCESS Model performance period begins.
Don't let a legacy EHR disqualify you from the most significant reimbursement shift in a generation.
Learn more about the CMS/FDA partnership and the ACCESS model requirements at the official source:
