Table of Contents >> Show >> Hide
- Quick Refresher: What CMMI Does (and Why People Argue About It)
- Why a New Strategic Direction, and Why Now?
- The Strategy in One Sentence
- The Three Pillars (Plus What They Look Like in Real Life)
- The Taxpayer Guardrail: The Rule That Changes the Game
- Portfolio Shakeup: The Models That Got a Farewell Tour
- What the New Direction Looks Like in Practice: Early Signals You Can Actually Measure
- Who Wins, Who Sweats: Stakeholder Impacts
- The Hard Questions (Because Every Strategy Eventually Meets a Spreadsheet)
- How to Prepare: A Practical Checklist for 2026
- Conclusion
- Experiences Related to the New Direction (Realistic, On-the-Ground Scenarios)
- SEO Tags
Updated for the 2025–2026 policy cycle.
If you’ve ever wondered what happens when Washington decides your health system needs to “innovate” harder, welcome to
the Center for Medicare and Medicaid Innovation (CMMI)the federal lab where ideas about paying for care go to
audition. Some become blockbuster hits. Some get canceled after one season. And some are that weird pilot episode
everyone pretends they didn’t watch.
Under the Trump Administration, CMMI (also often called the CMS Innovation Center) has rolled out a fresh strategic
direction built around three big themes: prevention, patient empowerment, and choice/competitionwrapped in a very
unromantic but deeply motivating ribbon: protecting taxpayers. The result is a strategy that feels like a reset,
a relaunch, and a little bit of a “we’re cleaning the fridge and labeling everything” momentall at once.
Quick Refresher: What CMMI Does (and Why People Argue About It)
CMMI was created to test new payment and care delivery models in Medicare, Medicaid, and CHIP. Translation: it tries
to move the system away from “pay for every single thing” and toward “pay for better outcomes,” ideally while
spending less money overall. It runs time-limited demonstrationsalternative payment models (APMs)and evaluates
whether they improve quality and reduce costs.
That last partreduce costsis where the debate gets spicy. Some models have generated savings, but
watchdogs and lawmakers have repeatedly questioned whether the Innovation Center’s overall track record justifies its
sweeping authority. That tension matters, because the new strategy reads like a direct answer to the critics:
fewer “science projects,” more “show me the receipts.”
Why a New Strategic Direction, and Why Now?
New leadership, new slogans, same math problem
The Trump Administration’s health policy messaging has emphasized chronic disease prevention and consumer choice.
CMMI’s new direction is positioned to align with that broader agenda, including the “Make America Healthy Again”
framing that shows up across federal health communications.
In plain English: the Administration is betting that the best way to cut long-term costs is to keep people healthier
longerand the best way to keep the system honest is to make organizations financially accountable when costs and
outcomes don’t go the right way.
Pressure from Congress and the scorekeepers
The Innovation Center has faced persistent scrutiny over whether its models reliably produce net savings. Add in
recommendations for streamlining from policy experts and concerns about administrative burden, and you get a strong
incentive to publish a clearer “north star” that signals what will be funded, what will be fixed, and what will be
dropped.
The Strategy in One Sentence
CMMI’s Trump-era strategy aims to build healthier lives by pushing
evidence-based prevention, patient empowerment, and
greater choice and competitionwith every model expected to honor the foundational rule:
protect the taxpayer.
The Three Pillars (Plus What They Look Like in Real Life)
1) Promote Evidence-Based Prevention
Prevention is no longer the “nice-to-have” garnish on the plateit’s the plate. The strategy emphasizes embedding
preventive care in model design and measuring whether prevention actually changes outcomes.
What might that mean beyond the usual “annual wellness visit” pep talk?
- Prevention baked into every model: Not just primary care models, but specialty and chronic
condition models too. - Waivers and flexibility: If a rule is blocking a proven prevention approach, CMMI is signaling it
may test waivers that let clinicians do the thing that works. - Community partnerships: Because “eat better and move more” is easier when someone helps you find
food, transportation, or safe places to exercise. - “Evidence-based” alternative/holistic options: The phrase is doing a lot of work here; the key
word is still “evidence-based.”
A practical example: a model could reward a primary care group not only for controlling A1c in diabetes, but for
reducing downstream ER visitswhile also testing whether nutrition counseling or structured lifestyle programs
reduce complications over time.
2) Empower People to Achieve Their Health Goals
American health care can feel like an escape room where the clues cost $400 and the exit requires prior
authorization. This pillar targets that reality by focusing on data access, decision tools, and simpler
cost-sharingso people can make informed choices with their clinicians.
- More access to personal health data: If patients can’t see their information, they can’t manage
it. - Digital tools that don’t feel like homework: Think mobile apps, remote monitoring, and simple
nudges that support chronic disease management. - Public performance information: Publishing cost and quality performance can help patients choose
providers like they choose restaurantsexcept with fewer photos of brunch and more outcomes data. - Predictable cost-sharing: Models may test waivers that make out-of-pocket costs more
straightforward for certain services, drugs, or devices.
The big idea: empowered consumers make better decisions, and better decisions reduce avoidable utilization. But the
strategy also implies something elseorganizations will need to compete on measurable results, not vibes.
3) Drive Choice and Competition
The third pillar frames competition as a lever to improve value. CMMI signals it wants models that reward high
performers, enable more independent practices to participate, and encourage site-of-care flexibility.
- Bring in independent and rural providers: If only giant systems can play, you don’t get a fair
test of competition. - Expand advanced shared savings and prospective payments: So smaller practices aren’t crushed by
cash-flow realities. - Reduce administrative burden by standardizing model features: Less “please submit the same data
in five formats.” - Push care beyond the hospital walls: More outpatient and community-based care when appropriate.
Choice and competition can be powerful, but they’re not magic. If a market has one hospital system and two
urgent care clinics, the “competition” lever has… limited mileage. That’s why the taxpayer-protection guardrails
matter so much in the strategy’s logic.
The Taxpayer Guardrail: The Rule That Changes the Game
The strategy’s foundational principleprotecting taxpayersshows up as a set of practical constraints that signal
what future models must look like. Highlights include:
- Fiscally sound tests with a credible pathway to broader adoption if they work.
- Prioritize high-value care and reduce unnecessary utilization.
- Downside risk as a default: models should include financial risk, and providersnot only
convenersshould bear some of it. - Move toward global downside risk arrangements where accountable providers take responsibility for
total cost and outcomes. - Refine and simplify benchmarking so incentives are clearer and gaming is harder.
In other words, CMMI is signaling that “voluntary, upside-only, nice-try” models will have a tougher time getting
airtime. The era of “everyone gets a participation trophy and also bonus payments” is, at minimum, under review.
Portfolio Shakeup: The Models That Got a Farewell Tour
Before publishing the new strategic direction, CMS announced significant portfolio changes, including early
terminations by the end of 2025 for several major models. The early-ending list included:
- Maryland Total Cost of Care (a statewide total-cost approach)
- Primary Care First (advanced primary care payment)
- ESRD Treatment Choices (kidney care incentives; termination via rulemaking)
- Making Care Primary (a newer primary care model with a long runway)
CMS also signaled it may reduce the scope of the Integrated Care for Kids model and said it would not pursue two
previously announced but not yet implemented efforts (including the Medicare $2 Drug List initiative). The message
wasn’t subtle: CMMI wants a portfolio that is easier to defend on savings, scalability, and statutory alignment.
For participants, this kind of portfolio reset is disruptive. But strategically, it’s consistent: if the Center is
going to demand downside risk and fiscal discipline, it can’t keep models it believes won’t meet those thresholds.
What the New Direction Looks Like in Practice: Early Signals You Can Actually Measure
Signal #1: More comfort with “mandatory” and “risk” in the same sentence
The strategy’s taxpayer section explicitly points toward downside risk. That suggests more models that require
participating entities to have real financial skin in the gameespecially where voluntary participation might attract
only “good risk” and weaken the test.
If you’re a provider organization, the implication is clear: invest in analytics, care management, and contracting
capabilities now, not after you’re offered a model participation agreement that reads like a mortgage document.
Signal #2: Digital health gets a bigger seat at the table (ACCESS)
The Innovation Center’s push toward technology-supported chronic care shows up in the ACCESS Model, which tests an
outcome-aligned payment approach in Original Medicare for technology-enabled care aimed at preventing and managing
chronic disease. It targets common conditions like high blood pressure, diabetes, chronic pain, and depression.
From an SEO standpoint, “digital health” is a buzzword. From an operator standpoint, it’s a reimbursement question:
will Medicare pay in a stable way for tech-enabled services that keep people healthier? ACCESS is a strong hint that
CMMI wants to test exactly thatwithout waiting for the broader fee schedule to catch up.
Signal #3: Drug pricing experiments aren’t a side quest (GENEROUS, GLOBE, GUARD)
The Innovation Center has also launched or proposed models designed to reduce prescription drug spending and
out-of-pocket costs by tying pricing benchmarks to international comparisons.
- GENEROUS: a voluntary Medicaid model aimed at aligning Medicaid net prices with those paid in
select other countries, using supplemental rebates negotiated through CMS. - GLOBE: a proposed mandatory Medicare Part B model that would assess rebates when U.S. prices
exceed those in economically comparable countries. - GUARD: a proposed mandatory Medicare Part D model using a similar international benchmark
concept, applied through rebates and limited to selected geographic areas.
Whether you love these ideas or hate them, they matter because they fit the strategy’s core promise: protect the
taxpayer, improve affordability, and use CMMI’s authority to test changes at scale.
Who Wins, Who Sweats: Stakeholder Impacts
Providers and health systems
Expect stronger expectations around accountability. If your organization participates in value-based care, the new
direction pushes you toward:
- More robust care management for chronic disease and frail populations
- Sharper measurement and documentation of outcomes (not just activities)
- Contracting readiness for downside risk (including stop-loss strategy and actuarial support)
- Patient-facing tools that reduce friction and improve engagement
Plans and payers
With CMMI signaling more activity in Medicare Advantage and prescription drugs, plans should watch for model designs
that affect benchmarks, quality measures, risk adjustment, and benefit structures. If data transparency expands,
plans may face more scrutiny on network performance and value.
Patients and caregivers
The “empowerment” pillar could translate to more usable data, clearer cost-sharing tests, and potentially more care
options at home or virtually. But it also creates a new challenge: if more choice exists, the system must make that
choice understandable. Otherwise “empowerment” becomes “good luck, have fun.”
States
States sit at the intersection of innovation and political reality. On one hand, models like GENEROUS aim to reduce
drug costs and create budget flexibility. On the other, participation can require standardized coverage criteria and
operational coordinationhard work even on a quiet week, and states rarely have quiet weeks.
The Hard Questions (Because Every Strategy Eventually Meets a Spreadsheet)
1) Does prevention save money fast enough?
Prevention can improve lives quickly, but savings often show up later. CMMI’s emphasis on measurement suggests it
wants intermediate outcomes (like avoided acute events, improved function, days at home) that can be tracked before
long-term cost curves bend.
2) Can “choice and competition” work in markets with limited competition?
Competition is uneven across the country. In some regions, the “market” is basically one big health system and a
billboard. CMMI may need model designs that encourage new entrants or enable independent practices to survive
financially while taking on risk.
3) What counts as “evidence-based” alternative medicine?
The strategy’s wording matters. Evidence-based approaches are, by definition, tied to credible data. Expect this to
become an implementation fight: what qualifies, what doesn’t, and how outcomes will be evaluated.
4) How do you require downside risk without crushing small practices?
Downside risk can be a catalystor a cliff. The strategy’s mention of prospective payments and shared savings
mechanisms hints at ways to support smaller providers, but model design will determine whether they can participate
without betting the building.
How to Prepare: A Practical Checklist for 2026
- Map your revenue exposure to models that may end or change.
- Upgrade prevention workflows (screening, nutrition support, medication adherence, fall
prevention, behavioral health integration). - Invest in patient-facing infrastructure: data access, digital engagement, remote monitoring
pathways, and easy-to-understand cost information. - Build risk muscles: attribution, benchmarking, actuarial modeling, and care redesign.
- Reduce admin drag by standardizing data capture and quality measurement internally.
- Watch drug pricing pilots closely if you’re a plan, manufacturer, provider administering Part B
drugs, or a Medicaid agency.
Conclusion
CMMI’s new strategic direction under the Trump Administration is not a gentle tweakit’s a signal flare. Prevention
becomes the centerpiece, empowerment becomes a design requirement, and competition becomes a policy lever. But the
defining feature is the taxpayer-first guardrail: more downside risk, more insistence on fiscal soundness, and more
pressure to prove that a model can scale.
If you’re in health care, you don’t need to agree with every element of the strategy to take it seriously. CMMI is
telling the market what it plans to reward, what it plans to measure, and what it plans to walk away from. The smart
move is to treat this like a weather report: you can argue about whether it should rain, but you should
probably still bring an umbrella.
Experiences Related to the New Direction (Realistic, On-the-Ground Scenarios)
When policy shifts, it doesn’t arrive as a neatly formatted memo for most people. It shows up as a calendar invite
titled “URGENT: Model Transition,” a dashboard that suddenly has three new tabs, and a CFO who starts using the
phrase “downside risk” the way normal people say “traffic.”
For primary care practices, the experience can feel like being told the treadmill is now the main
event. A practice that spent years building workflows around an innovation model may have to pivot quicklymoving
patients into other accountable care arrangements, renegotiating care management budgets, and retraining staff on
what “success” looks like. Instead of just documenting services provided, teams find themselves tracking prevention
outcomes with new intensity: blood pressure control, closed care gaps, medication adherence, reduced avoidable ED
utilization. The clinical work is familiar; the scoreboard is not.
For hospitals, especially those in rural or smaller markets, “choice and competition” can sound
inspiring until you remember you’re competing with physics. Distance, workforce shortages, and thin margins are
undefeated opponents. The strategy’s push toward outpatient and community-based care can translate into very real
conversations about redesigning service linesinvesting in home-based care partnerships, improving transitions, and
avoiding admissions that used to keep the lights on. The emotional whiplash is real: doing the right thing for
patients can collide with the reality of fixed costs.
For Medicare beneficiaries and caregivers, empowerment tends to feel less like a philosophical
concept and more like “someone finally made the instructions readable.” Better data access and simpler tools can
reduce the frustration of managing chronic diseaseespecially when combined with predictable cost-sharing tests.
But there’s also a learning curve: more information is only helpful if it’s digestible. People don’t want a 47-page
report card; they want clear choices and a clinician who can translate the options without requiring a second
appointment just for decoding.
For Medicaid agencies, models aimed at drug affordability can feel like both opportunity and
operational marathon. The promise of lower net drug costs is compelling, but participation can require aligning
coverage approaches and negotiating in ways that aren’t “plug-and-play.” Teams have to weigh budget impact, political
constraints, and the practical question: can we implement this without breaking everything else that’s already held
together by duct tape and heroic staff effort?
For health tech and value-based care vendors, the vibe is cautiously optimistic. A model like ACCESS
signals that technology-enabled chronic care might finally get a reimbursement pathway that feels stable enough to
build around. Vendors, however, are learning the hard truth of federal pilots: you don’t win by showing a cool demo.
You win by proving outcomes, reducing total cost of care, integrating with clinical workflows, and surviving
procurement timelines that move at the speed of committee.
Across all these experiences, the pattern is the same: the strategy is pushing the system toward prevention and
accountability, while daring organizations to prove they can do it with less waste and more measurable value. That’s
a high barbut in a system where costs keep rising, it’s also the kind of bar that policymakers are increasingly
unwilling to lower.
