CMS’s 2025–2027 portfolio marks a strategic pivot from short pilots to long-term, rule driven programs that prioritize quality performance and technology-led accountability, with major implications for capital flows, provider risk, and specialty areas like wound care. Leaders should treat ACCESS and LEAD as decade long commitments to build prospective payment and tech-enabled chronic care capacity, expect technology contracts to reshape utilization oversight, and prepare for mandatory episode accountability (TEAM) to financially capture post-surgical wound outcomes.
The landscape of Medicare reimbursement is undergoing a profound structural recalibration. For over a decade, the CMS Innovation Center (CMMI) was characterized by a “Pilot Era”: a revolving door of three-to-five-year experiments designed to test specific levers of value-based care. However, the latest updates to the CMS model portfolio suggest this era is being replaced by a more permanent, albeit more demanding, architecture. This transition is marked by a paradoxical mix of sudden volatility and unprecedented long-term commitment. In March 2025, CMS executed a “great pivot,” terminating several cornerstone models early while simultaneously locking in new initiatives for full ten-year lifecycles. For the healthcare strategist, the message is clear: CMS is moving away from flexible “innovations” and toward rigid, codified “regulations” where quality is the primary currency. Navigating this shift requires looking beyond program names to understand the underlying changes in capital flow, risk profiles, and technology integration. The following five takeaways distill the most impactful strategic shifts from the current CMS model inventory.
Is CMS Redefining Care Delivery by Letting Technology Gatekeep Clinical Decisions?
A radical movement in CMS modeling is the introduction of the Wasteful and Inappropriate Service Reduction (WISeR) model. Unlike traditional models where clinical providers are the primary participants, WISeR identifies “technology innovators” as its exclusive partners. This represents a fundamental shift in capital flow: CMS is moving toward a technology-contract model rather than a traditional provider-payer reimbursement loop. By contracting directly with tech firms to manage program integrity through technology-enabled prior authorization, CMS is effectively paying innovators to gatekeep clinical utilization. While CMS notes that WISeR may “reduce unnecessary services and protect beneficiaries from low-value care,” it introduces a significant downside risk profile regarding operational efficiency. For clinicians, the primary risk is “administrative friction”: the potential for automated oversight to delay care, particularly in areas like cellular tissue products where the model has a direct intersection with wound care.
Are ACCESS and LEAD the End of Short-Term Pilots and the Start of Scalable Reform?
One of the most significant strategic pivots is the move toward 10-year timelines for the ACCESS (Advancing Chronic Care with Effective, Scalable Solutions) and LEAD (Long-term Enhanced ACO Design) models. This represents a major departure from the typical three-year pilot cycles that often-left providers hesitant to make deep infrastructure investments. The ACCESS framework, set to begin on July 5, 2026, signals a pivot toward long-term predictability. By providing a decade-long runway, CMS is encouraging organizations to adopt prospective payments and technology-supported care at scale. These models are designed to be multi-conditioned platforms rather than single-disease silos, focusing on:
Is CMS Redefining Value by Making Quality the Core of Payment, Not a Bonus?
The financial mechanics of the 2025–2027 models indicate that quality performance has transitioned from a compliance checkbox to the core of the payment formula. In the LEAD and ACO REACH models, quality is not a “bonus” on top of savings; it is an integral component of the benchmark-based shared savings calculation. The LEAD model, for instance, incorporates a “3 percent quality withhold.” This creates a high-stakes environment where an organization could successfully manage medical spend below its target, yet see its earnings eliminated due to weak quality scores. In this new “net-neutral” framework, clinical performance and data accuracy are the only ways to reclaim the withhold, making quality the ultimate arbiter of financial viability.
What Does the March 2025 Model Termination Signal About CMS’s Future Direction?
The sudden termination of several high-profile initiatives in March 2025 has created a climate of uncertainty, signaling that CMS is narrowing its focus toward models that can be scaled through formal rulemaking rather than flexible “innovation” testing. This move drastically reduces the “future participation value” for organizations that built long-term strategies around the following sunsetting models:
- Terminated/Ending Early: Maryland Total Cost of Care, Primary Care First, ESRD Treatment Choices, and Making Care Primary (ending June 30, 2025).
- Modified or Reduced: Integrated Care for Kids (IC4K). This consolidation suggests a shift toward a leaner portfolio where CMS prioritizes models that offer the greatest “rulemaking-based” stability over experimental flexibility.
Are Providers Prepared for Wound Care Risk Hidden Inside Broader CMS Models?
While no standalone “Wound Care Model” exists, CMS is addressing this high-cost specialty through a “shadow” strategy that targets the practical intersections of chronic disease and surgical recovery. Strategists must distinguish between the voluntary opportunities of ACCESS and LEAD and the mandatory requirements of the TEAM (Transforming Episode Accountability Model).
- Mandatory Episode Accountability: Under TEAM, acute care hospitals in selected regions are held accountable for the “entire surgical episode.” This means hospitals now carry the financial burden for post-surgical complications, including surgical site infections and wound dehiscence, creating a powerful incentive for better wound management.
- Voluntary Chronic Management: ACCESS and LEAD address wound care indirectly by focusing on the underlying drivers: diabetes, vascular disease, and the needs of homebound, dually eligible beneficiaries. By linking post-surgical complications to the mandatory TEAM model, CMS is financially capturing wound care within a broader framework of surgical accountability.
Conclusion: A Leaner, More Accountable Future
The trajectory of the CMS Innovation Center is clear: the era of fragmented experimentation is ending. It is being replaced by a portfolio characterized by technological integration, decade-long commitments, and a relentless focus on outcomes. For healthcare leaders, this evolution poses a critical strategic question: Will the move toward technology-led, outcome-aligned models finally resolve the tension between administrative friction and patient care, or will the new “architecture of accountability” prove too heavy for traditional providers to sustain? One reality, however, remains non-negotiable: in this new era, quality performance is the only currency that matters.
From the authorI see a significant shift in CMS strategy moving from short, experimental pilots to longer, more disciplined models where quality, data integrity, and operational accountability drive financial outcomes. For organizations in wound care and other complex specialties, success will depend less on chasing one-off initiatives and more on building durable infrastructure for chronic care, episode management, and documentation accuracy.
Frequently Asked Questions
What changed in CMS strategy after March 2025?
How do ACCESS and LEAD affect provider investment decisions?
What is the WISeR model and why does it matter to clinicians?
How does quality performance affect payments now?
How is wound care being addressed without a standalone model?
Julie Rhodovi, MBA, CWCA, LBBH
Julie Rhodovi is an accomplished, senior executive with health care strategy development, revenue cycle, payor and government relations experience. She has a proven ability to implement change strategies and improving process performance through variability and defect reduction. Julie’s results show consistent and high-quality revenue streams. She designs and implements programs to build and nurture positive relationships with outside health plans and private revenue resources.
Julie worked with Gordian Medical, Inc dba American Medical Technologies (AMT) from 2006 to 2022. As the Senior Vice President of Payor and Strategic Partnerships, she was accountable for identifying and developing partnerships that enable patient-centered care sources and opportunities. In her time with AMT, she successfully brought on alliances with the largest nursing home chain in the country, created and built the third-party private payor department within the organization, and created and built a revenue cycle system and process of operation. Within her time, Julie’s contributions to the organization brought third-party private payor revenue from $120K annually to $70M. Additionally, Julie’s revenue cycle changes increased collection rate by 20%, creating an increase of $24M annually. Julie has created strategic partnerships and prospects to further the organization’s footprint by bringing key-turn opportunities for growth through relationship building of payors and further collaboration.
Julie has worked in the long-term care setting and the managed care/payer field for over 30 years, with direct experience in the building and launching of a Medicare Advantage plan and alternative reimbursement models.
Julie is a Certified Wound Care Associate (CWCA) with the American Board of Wound Management (ABWM) and past treasurer with the ABWM. She currently is on the Board of Trustees of the Foundation for ABWM. Julie is on the Board of Directors and the Vice-Chair of the Alliance of Wound Care Stakeholders and is a member of Chief and Women Business Leaders. Most recently, Julie is a founding member of the Post-Acute Wound and Skin Integrity Council (PAWSIC), and sits on the executive board as treasurer. Currently, Julie is consulting in the regulatory and reimbursement space of healthcare.
Julie holds a Master’s in Business Administration with a concentration in health management and is a certified six sigma lean black belt in healthcare (LBBH).