Technical Requirements
This guide outlines the technical infrastructure, API integration, and reporting requirements for organizations participating in the ACCESS Model. Ensuring your systems meet these requirements is essential for successful model participation.
Implementation Guide Coming Soon
CMS will release a detailed implementation guide with technical specifications, API documentation, and integration timelines in early 2026. Sign up for the ACCESS Model interest form to receive notifications.
Technology Infrastructure Overview
ACCESS participants need robust technology infrastructure to support remote patient monitoring, virtual care delivery, and seamless data exchange with CMS and other providers.
Core Infrastructure Requirements
Participating organizations must have technology infrastructure to support:
- Remote patient monitoring — Systems to collect and analyze patient health data from connected devices
- Virtual care delivery — HIPAA-compliant telehealth and asynchronous communication platforms
- CMS API integration — Standards-based connections for eligibility, enrollment, and outcome reporting
- Electronic health records — Systems for care documentation and clinical decision support
- Secure communications — Encrypted channels for patient and provider messaging
- Health Information Exchange — Integration with HIEs or CMS Aligned Networks for care coordination
API Integration Requirements
ACCESS participants must integrate with CMS-hosted APIs to manage eligibility verification, patient enrollment, and outcome reporting.
Standards-Based APIs
FHIR-Based Integration
ACCESS uses HL7 FHIR (Fast Healthcare Interoperability Resources) standards for data exchange, enabling modern, RESTful API integration that aligns with broader healthcare interoperability initiatives.
CMS will provide standards-based Application Programming Interfaces (APIs) for:
| Function | Description |
|---|---|
| Eligibility Verification | Check patient Medicare enrollment and qualifying conditions |
| Patient Enrollment | Register patients in clinical tracks and manage enrollment status |
| Baseline Submission | Submit initial clinical measurements for outcome tracking |
| Outcome Reporting | Report clinical outcomes at defined intervals |
| Care Coordination | Exchange care updates with referring providers |
Integration Timeline
Technical Onboarding
Complete technical onboarding and receive API credentials from CMS after application approval.
Development Environment
Access CMS sandbox environment for API testing and integration development.
Certification Testing
Complete required certification tests to validate API integration before going live.
Production Access
Receive production API credentials and begin live operations.
Reporting Requirements
Participants must report required measures to CMS at defined intervals throughout the care period.
What You'll Report
Each clinical track has specific reporting requirements tied to outcome measures:
eCKM Track:
- Blood pressure readings
- Lipid panel results
- Weight measurements
- HbA1c values (for prediabetes)
CKM Track:
- Blood pressure readings
- Lipid panel results
- Weight measurements
- HbA1c values
- eGFR and UACR data (for CKD and diabetes)
MSK Track:
- Validated Patient-Reported Outcome Measures (PROMs) for pain intensity, interference, and function
BH Track:
- PHQ-9 scores (depression)
- GAD-7 scores (anxiety)
- WHODAS 2.0 12-item functional assessment
Reporting Intervals
Timely Reporting Required
Failure to submit required reports within specified timeframes may affect payment and continued participation eligibility.
| Report Type | Timing | Description |
|---|---|---|
| Baseline | At enrollment | Initial clinical measurements establishing starting point |
| Progress | Defined milestones | Interim measurements during care period |
| Outcome | End of care period | Final measurements for payment determination |
| Care Updates | Key clinical events | Updates shared with referring providers |
Care Coordination Technology
ACCESS requires electronic care coordination with primary care providers and referring clinicians.
Health Information Exchange Integration
Participants must integrate with a Health Information Exchange (HIE) or CMS Aligned Network to:
- Share care plans with referring providers
- Send electronic updates at treatment initiation
- Notify providers of clinical milestones
- Provide completion summaries
- Enable secure access to patient progress information
Required Care Updates
ACCESS participants must electronically share care updates at:
- Treatment initiation — Care plan and initial assessment
- Clinical milestones — Significant progress or changes in care
- Treatment completion — Final outcomes and recommendations
- Adverse events — Any safety concerns requiring PCP notification
Data Security Requirements
All ACCESS participants must implement robust security measures to protect patient data.
Security Standards
What security certifications are required?▼
While specific certifications are not mandated, participants must demonstrate compliance with HIPAA Security Rule requirements. Many organizations pursue SOC 2 Type II certification or HITRUST CSF certification to demonstrate security maturity, though these are not required.
What encryption standards apply?▼
All patient data must be encrypted in transit (TLS 1.2 or higher) and at rest (AES-256 or equivalent). API communications with CMS must use secure, authenticated connections.
Are there specific access control requirements?▼
Organizations must implement role-based access controls, maintain audit logs of data access, and follow the minimum necessary standard for PHI access. Multi-factor authentication is strongly recommended for systems accessing patient data.
HIPAA Compliance
Participants must be HIPAA-covered entities and comply with:
- Privacy Rule — Appropriate use and disclosure of PHI
- Security Rule — Administrative, physical, and technical safeguards
- Breach Notification Rule — Timely notification of any data breaches
- Business Associate Agreements — Written agreements with all vendors handling PHI
Device and Software Requirements
Remote Monitoring Devices
If using connected devices for remote patient monitoring:
- Devices must be FDA-authorized for their intended clinical use (or subject to FDA enforcement discretion under TEMPO)
- Data transmission must be secure and encrypted
- Device accuracy must meet clinical requirements for outcome measurement
- Patient training and support must be provided
Software Requirements
Clinical software used in ACCESS should:
- Support FHIR-based data exchange
- Integrate with your EHR system
- Maintain audit trails for compliance
- Support required outcome measure collection
- Enable secure patient communication
ACCESS Tools Directory
CMS will launch an ACCESS Tools Directory — a resource within the participant portal to help organizations identify software, hardware, and compliance tools that may support model participation. Listings are voluntary and non-endorsing.
Compliance and Monitoring
CMS Oversight
CMS will monitor participant performance and compliance through:
- API-based reporting review
- Quality metric analysis
- Audit and validation activities
- Patient safety monitoring
- Outcome trend analysis
Participant Responsibilities
Organizations must:
- Maintain accurate and timely reporting
- Respond to CMS information requests
- Cooperate with program integrity activities
- Support model evaluation efforts
- Report any compliance concerns promptly
What happens if we have technical issues with reporting?▼
Contact the ACCESS Model technical support team immediately if you experience issues with API integration or reporting. CMS will work with participants to resolve technical problems, but persistent reporting failures may affect payment and participation status.
Can we use third-party vendors for technical integration?▼
Yes, you may work with vendors to support API integration and technical operations. However, ensure appropriate Business Associate Agreements are in place and that your organization maintains oversight of all data handling activities.
Getting Technical Support
CMS Resources
ACCESS Model Technical Resources
Official CMS page with technical documentation and updates
Interest Form
Sign up to receive technical implementation guides and updates
Contact Information
Technical Support:
- Email: ACCESSModelTeam@cms.hhs.gov
- Subject Line: Include "Technical Support" for faster routing
Checklist: Technical Readiness
Use this checklist to assess your organization's technical readiness:
- EHR system capable of FHIR-based data exchange
- Telehealth platform for virtual care delivery
- Remote patient monitoring infrastructure (if applicable)
- HIE or CMS Aligned Network integration capability
- HIPAA-compliant security controls in place
- Technical team available for API integration
- Data analytics capability for outcome tracking
- Patient communication platform (secure messaging)
Next Steps
FDA & TEMPO Compliance
Understand FDA requirements for digital health devices
Medicare Enrollment Guide
Ensure your Medicare Part B enrollment is complete
Check Eligibility Requirements
Review all requirements before applying