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The CMS Innovation Center has run payment experiments for 15 years. Most paid providers for activity: enrolling patients, filing reports, hitting process measures. At the end of 2025, CMS launched a model that changes the unit of payment itself. It’s called CMS ACCESS, and it pays for outcomes. Did blood pressure come down? Did HbA1C come down? Did depression scores improve? The first cohort went live weeks ago.
Underneath that idea is a much harder one. To pay for outcomes, you have to measure outcomes at the patient level, across thousands of organizations, in something close to real time. As host Lisa Bari puts it, this is a data problem before it’s a policy problem. Her guest is Dr. Will Gordon, who was the first Chief Informatics Officer at the CMS Innovation Center and a senior advisor to the CMS Administrator on technology and interoperability, and who helped design several of the models now in the field. He’s a practicing physician and clinical informaticist, now a senior advisor at Manatt Health.
Together they trace how CMS ACCESS came to be: why activity-based billing and technology-driven care fundamentally don’t fit together, why an AI agent managing blood pressure isn’t limited the way a physician’s day is, and why paying for outcomes has always been the obvious idea that turned out to be brutally hard to operationalize. They get into the mechanics (the four clinical tracks, the roughly 50% outcomes withhold, the twelve-month episode), the data infrastructure that finally makes it feasible (Model Space, bulk FHIR APIs, pre-adjudicated claims), the interoperability gaps CMS still can’t close on its own, and whether commercial and Medicaid payers will adopt the same chassis. A clear-eyed look at what it actually takes to turn good policy into something real.
