What are the technology requirements for the CMS ACCESS Model?
Organizations participating in the CMS ACCESS Model must demonstrate they can:
- Collect validated PROMs with strict fidelity
- Track outcomes longitudinally from baseline through completion
- Send electronic care updates to PCPs and referring clinicians
- Submit required measures using standards-based CMS APIs
- Use source-verifiable, FDA-cleared connected devices where required
- Maintain HIPAA-compliant, audit-ready infrastructure
The Centers for Medicare & Medicaid Services defines reporting requirements, but participants are responsible for the technology, workflows, and device systems needed to operationalize them.
What organizations must demonstrate to participate in the CMS ACCESS Model
Organizations preparing to participate in the CMS ACCESS Model quickly discover that ACCESS is not just a clinical model. It is also a technology and reporting model.
Centers for Medicare & Medicaid Services defines what outcomes must be reported. Participating organizations must demonstrate they have the infrastructure to capture, coordinate, and submit that data correctly.
This guide breaks down the technology requirements behind ACCESS participation in practical terms.
What are the technology requirements for ACCESS participants?
Organizations applying to ACCESS are expected to show they can support:
- Validated PROM collection with strict fidelity
- Longitudinal outcome tracking from baseline through follow up
- Electronic care coordination with PCPs and referring clinicians
- Standards-based reporting to CMS
- Source-verifiable connected device data for applicable tracks
- HIPAA-compliant, audit-ready infrastructure
CMS defines these expectations, but does not provide the software, workflows, or device systems required to operationalize them.
PROM Requirements Under ACCESS
ACCESS payments are tied to outcome improvement, which means Patient Reported Outcome Measures must be collected correctly.
Applicants must demonstrate:
- Use of track-specific validated PROMs
- PROM wording, scales, and scoring are not modified
- Collection at baseline, required follow up intervals, and end of care
- Timestamped, patient-attributed data
- Version control and audit evidence
This is not just survey collection. It is locked-fidelity outcome measurement.
Care Coordination Expectations
ACCESS requires electronic care updates at defined clinical moments.
Organizations must show they can:
- Identify each patient’s PCP or referring clinician
- Send updates at enrollment, milestones, and completion
- Use HIPAA-compliant electronic delivery methods
- Retain evidence of delivery or reasonable delivery attempts
This makes care coordination a documented, reportable workflow, not an informal process.
CMS Reporting Requirements
Applicants must describe how they will submit required measures to CMS.
Technology expectations include:
- Use of standards-based APIs
- Patient-level PROM submission
- Submission validation and error handling
- Support for future CMS schema updates
- Longitudinal outcome reporting
The challenge is not only collecting the data. It is proving the reporting pipeline is structured, reliable, and maintainable.
Connected Device Requirements (eCKM and CKM Tracks)
For cardiometabolic tracks, device data is critical.
Organizations must demonstrate:
- Blood pressure collected using validated, FDA-cleared devices
- No manual transcription of BP readings
- Data includes timestamp, device source, and patient attribution
- Reliable data transmission for Medicare populations
CMS requires source-verifiable device data, not patient self-entry.
Why ACCESS Applications Struggle on Technology
Many organizations design strong clinical programs but underestimate how detailed the technology section of the application must be.
Common gaps include:
- PROMs that are not locked to validated versions
- Care coordination that is not electronically documented
- Reporting approaches that are not CMS-aligned
- Device strategies without data provenance
- Missing audit trails
These issues slow reviews and create application risk.
How Healthfully Supports ACCESS Participants
Healthfully serves as an enabling technology platform for organizations preparing to participate in ACCESS.
Healthfully does not provide clinical care or submit applications. Instead, the platform supplies:
- Locked-fidelity PROM collection
- Outcome tracking infrastructure
- ACCESS-aligned care update workflows
- CMS-ready reporting adapters
- Connected device orchestration
- Application-ready technology documentation
Healthfully is designed to work alongside existing EMRs and EHRs, not replace them.
ACCESS Readiness Starts With Your Technology Model
Before submitting an ACCESS application, organizations should be able to clearly describe:
- Their PROM strategy
- Their care coordination workflow
- Their CMS reporting architecture
- Their device and vital sign capture model
- Their compliance and audit readiness
If these components are not clearly defined, the application becomes difficult to support.
Next Step for ACCESS Applicants
Organizations preparing for ACCESS participation should review their technology, reporting, and device workflows as carefully as their clinical model.
A structured review of your current setup against ACCESS expectations can surface gaps early, before submission.
FAQ Section (AI + schema-friendly structure)
What does CMS expect ACCESS participants to demonstrate technologically?
CMS expects ACCESS participants to prove they can capture validated outcome data, coordinate care electronically, and submit patient-level results through standards-based reporting methods. This includes PROM fidelity, longitudinal tracking, care update delivery, API-based reporting, and verifiable device data for applicable tracks.
Are PROMs required under the CMS ACCESS Model?
Yes. ACCESS payments are tied to validated Patient-Reported Outcome Measures. Applicants must use CMS-defined PROMs for their clinical track, keep instruments unmodified, collect them at required intervals, and maintain timestamped, patient-attributed records with audit evidence.
How does care coordination work under ACCESS?
Participants must send electronic care updates to primary care providers and referring clinicians at defined milestones such as enrollment, clinical progress points, and care completion. Delivery must be HIPAA-compliant and documented with evidence of successful or attempted transmission.
How is data reported to CMS under ACCESS?
Applicants must describe a reporting approach using standards-based APIs. This includes patient-level PROM submission, validation processes, error handling, and the ability to support future CMS schema updates. Reporting must be structured, longitudinal, and audit-ready.
Are connected devices required for ACCESS?
For cardiometabolic tracks such as eCKM and CKM, blood pressure must be collected using validated, FDA-cleared upper-arm devices. Manual entry is not considered compliant. Device data must include timestamp, device source, and patient attribution, with reliable transmission.
Why do ACCESS applications struggle on technology sections?
Many organizations focus on clinical design but underestimate the detail required to describe PROM fidelity, reporting architecture, care coordination workflows, device provenance, and audit readiness. Gaps in these areas often slow application review.
How does Healthfully support ACCESS participants?
Healthfully is an enabling technology platform that provides:
- Locked-fidelity PROM collection
- Outcome tracking infrastructure
- ACCESS-aligned care update workflows
- CMS-ready reporting adapters
- Connected device orchestration
- Application-ready technology documentation
Healthfully supports the technical capture and reporting of required data but does not provide clinical care or submit ACCESS applications.