Field notes on the CMS ACCESS Model

The ACCESS reporting rules,
read closely.

Short, sourced explainers on the model's reporting deadlines, validity windows, and provenance rules — each one traced back to CMS's own documents, so you can read the source yourself. This is the reference we kept wanting while we built the rail.

The series

What a valid ACCESS submission actually requires

Short reads that walk the rules in the order they bite: first the two clocks that govern when you submit, then the windows and methods that govern whether a reading is eligible in the first place. Best read in order.

5
Deadlines

425 days, measured backward: the end-of-period submission math

The ACCESS end-of-period measure has a hard outer deadline at Day 425 — but the *early* window that most teams should actually target is measured backward from a different day. Here's the math, straight from the Payment paper.

Read it
Source: CMS ACCESS "Payment Amounts & Performance Targets" paper (p.7)
6
How it works

What "data that survives reconciliation" means

In the ACCESS model, a submission can be accepted the day you send it and still fail eleven months later at reconciliation. That gap — between "accepted today" and "survives the year-end audit" — is a specific, buildable engineering problem. Here's how we think about it.

Read it
Source: CMS ACCESS Model page, Technical FAQ, RFA & Payment paper (mechanics carried in B1-B5)
7
Trust & security

Where your PHI lives when you pilot a reporting vendor

The first question a security reviewer asks a reporting vendor is "where does our PHI sit in your cloud?" For an ACCESS-model pilot with us, the honest answer is: it doesn't. Here's the architecture, the one narrow data channel, and — read this part — the list of what we don't have yet.

Read it
Source: CMS ACCESS Model page & Technical FAQ; HIPAA Security Rule (posture)
8
The economics

What a missed reporting window actually costs

Half of the Medicare portion of every Outcome-Aligned Payment (OAP) is withheld until CMS reconciles your outcomes — and a beneficiary you never reported still counts against your attainment threshold. Here's how a single slipped window turns into dollars, walked through honestly, with the numbers CMS actually published (and the one it hasn't).

Read it
Source: CMS ACCESS "Payment Amounts & Performance Targets" paper (payment mechanics)
9
Trust & security

What our validation engine checks, and how we test that it does

8 measure types, 12 verdict codes, 4 rule families, 47 conformance scenarios. Here is the actual coverage map of our ACCESS validation engine — what it checks, how each check is tested, and the specific things this evidence does not tell you.

Read it
Source: our own validation coverage summary (approved for publication); rule mechanics per CMS ACCESS RFA & Payment paper
10
How it works Start here

Before you apply to ACCESS: the reporting burden you are signing up for

If you are deciding whether to apply to the CMS ACCESS Model, the clinical work is the part you can already picture. The reporting obligations are the part that surprises people. Here is what has to be true operationally, per CMS's own documents — every rule sourced, no deadline we can't stand behind.

Read it
Source: CMS ACCESS "Payment Amounts & Performance Targets" paper (p.6-7) & RFA (Appendix C)
12
The economics

ACCESS has a comparison group, and it sits in the eligibility criteria

CMS runs the ACCESS Model as a randomized evaluation with beneficiary-level randomization — a share of people who try to enroll are assigned to a comparison group and are ineligible for 12 months. The RFA publishes the year-1 rate. Here is what it does to a panel forecast, including ours.

Read it
Source: CMS ACCESS RFA v1.1 (p.16 Program Exclusions, pp.39-40 Evaluation) & Technical FAQ
13
The rules

The Day-60 paragraph has three sentences. We were quoting two.

CMS sets out what happens when a baseline reporting deadline is missed under the ACCESS Model, and the passage does not end where we used to end it. Here is the full paragraph, the remedy CMS names inside it, the part CMS has not specified, and the correction we owed our own readers.

Read it
Source: CMS ACCESS Model Payment Amounts and Performance Targets (p.7 Baseline Reporting) & RFA v1.1 (p.52 fn.38)
Reading this because you're in ACCESS

We turn these rules into a rail so your team doesn't have to track them.

Device, lab, and PROM data in; compliant FHIR submissions out — validity windows, cadence clocks, and provenance rules enforced before CMS ever sees the bundle. We're onboarding a small founding cohort of design partners this quarter.