What Is the CMS ACCESS Model for Behavioral Health?
As of October 2026, the CMS Advancing Chronic Care with Effective, Scalable Solutions (ACCESS) model is a 10-year voluntary Medicare payment model that replaces traditional fee-for-service billing with outcome-aligned payments for participating practices treating depression and anxiety. Participants bill model-specific G-codes instead of standard CPT codes and receive recurring payments tied to measurable patient improvement on the PHQ-9 and GAD-7 scales.
- How payment works: Practices receive outcome-aligned payments that scale based on the percentage of patients hitting PHQ-9 and GAD-7 improvement targets, with a 50 percent threshold in year one.
- Who qualifies: Any Medicare Part B enrolled provider or supplier under a single TIN that treats depression or anxiety, including psychiatrists, nurse practitioners, and licensed counselors.
- Key deadline: The next ACCESS entry point is October 1, 2026, for applications received before that date. Applications received after October 1, 2026 are considered for January 1, 2027 participation.
What Changed in October 2026
The CMS Innovation Center launched the ACCESS model on July 5, 2026, with rolling participation dates including August 17 and October 1, 2026. The model represents a fundamental shift in how CMS reimburses behavioral health care for Medicare fee-for-service beneficiaries. Instead of paying per visit using standard CPT codes like 90837 or 90834, participating practices bill model-specific G-codes and receive outcome-aligned payments tied to whether patients actually improve.
As Behavioral Health Business reported, CMS selected 150 organizations across all four clinical tracks, with 85 participating in the behavioral health track. Seventeen of those were selected exclusively for behavioral health. The model is designed to test whether tying payments to health outcomes, specifically improvement on standardized depression and anxiety screening tools, can accelerate adoption of technology-enabled care and improve results for Medicare beneficiaries.
According to the September 2026 Behavioral Health Law Ledger published by Greenberg Traurig, the behavioral health track is initially limited to depression and anxiety. A provider participating in this track must manage all qualifying behavioral health conditions the enrolled beneficiary has within the track. That means a practice cannot selectively treat only anxiety or only depression for a given patient.
Does the ACCESS Model Apply to Psychiatry Practices?
Yes. Any Medicare Part B enrolled provider or supplier that treats depression or anxiety is eligible to participate, which includes psychiatrists, psychiatric nurse practitioners, psychologists, licensed clinical social workers, and licensed professional counselors. The participation requirement is organizational: the practice applies under its taxpayer identification number, and all eligible providers under that TIN can participate.
For psychiatry practices specifically, this model changes the billing equation in a meaningful way. Under fee-for-service, a psychiatrist billing 90837 (60-minute psychotherapy) receives approximately $167 per session at the 2026 Medicare national non-facility rate. Under the ACCESS model, that same encounter is billed with a model G-code, and payment scales based on whether the practice meets outcome thresholds across its enrolled patient panel. A practice that achieves improvement targets on 50 percent or more of its patients receives full payment. Below that threshold, payment scales proportionally.
The practices that have the most to gain are those already tracking PHQ-9 and GAD-7 scores systematically, because they can demonstrate the improvement CMS is paying for. The practices that face the most risk are those that do not currently use standardized outcome measures, because they would need to build that infrastructure before the payment model rewards them for it. One question we hear constantly from practice managers is whether outcome tracking will add administrative burden. In the ACCESS model, it is not optional burden. It is the basis of payment.
How Outcome-Aligned Payment Works
The ACCESS model uses what CMS calls Outcome-Aligned Payment, or OAP. Instead of paying per service delivered, CMS pays a recurring amount during a 12-month care period for each enrolled beneficiary. The payment amount scales with the percentage of patients whose PHQ-9 or GAD-7 scores improve by clinically meaningful thresholds.
For year one, CMS set the Outcome Achievement Threshold (OAT) at 50 percent. That means 50 percent of a practice’s enrolled patients must show a clinically significant improvement (generally a 5-point reduction on the PHQ-9 for depression) for the practice to receive full payment. A practice achieving 40 percent would receive 80 percent of the full payment, scaled proportionally. CMS has indicated the threshold may increase in subsequent years as the model matures.
| Factor | Fee-for-Service (Current) | ACCESS Model (New) |
| Payment basis | Per visit (CPT code) | Per patient outcome (G-codes) |
| Revenue predictability | Volume-dependent | Panel-dependent, recurring |
| Billing codes | Standard CPT (90837, 90834, etc.) | Model-specific G-codes |
| Outcome tracking required | Not required for payment | PHQ-9 and GAD-7 required |
| Patient cost-sharing | Standard copay/coinsurance | Can be waived under safe harbor |
| Duration | Per encounter | 12-month care period per patient |
A significant feature of the ACCESS model is the patient incentive safe harbor, which allows participants to waive beneficiary cost-sharing entirely. For psychiatry practices, this removes a common barrier to treatment adherence. Patients who would otherwise skip sessions because of copay costs can be enrolled without that financial friction, which directly supports the outcome thresholds the practice needs to meet.
What Do Psychiatry Practices Need to Do to Prepare?
Whether your practice is considering ACCESS participation or simply wants to understand how outcome-based payment will affect psychiatry billing, these steps prepare your operations for the shift.
- Implement standardized PHQ-9 and GAD-7 screening at every visit. These are the specific instruments CMS uses to measure outcomes. If your practice does not already administer them routinely, start now. The data you collect today builds the baseline the model measures improvement against.
- Confirm your Medicare Part B enrollment is current. Participation requires enrollment under a single TIN. If your practice’s Medicare enrollment has lapsed or is pending revalidation, resolve it before applying.
- Evaluate your EHR’s ability to track and report patient outcomes. The model requires outcome data submission. Your EHR needs to capture PHQ-9 and GAD-7 scores at each visit and support the reporting CMS requires for outcome-aligned payment calculation.
- Understand the G-code billing requirements. ACCESS participants bill model-specific G-codes instead of standard CPT codes for aligned beneficiaries. Your billing team needs to understand which codes apply and how they map to the care delivered.
- Assess whether your patient panel supports the outcome threshold. The 50 percent improvement threshold is achievable but not automatic. Review your current patient outcomes to determine whether your panel’s acuity and engagement levels position you to meet the target.
- Consult your billing partner about model-specific coding. The transition from CPT to G-code billing requires changes to your claims workflow. Practices that handle billing internally may need support during the transition period.
Whether your practice is evaluating the ACCESS model or staying with fee-for-service, the billing landscape for psychiatry is getting more complex. We match practices with billing companies that specialize in behavioral health coding, compliance, and revenue cycle management.
Common Concerns About the ACCESS Model
The most immediate concern we hear from psychiatry practice managers is whether outcome-based payment penalizes practices that treat more complex patients. The answer is nuanced. CMS uses randomized assignment of beneficiaries, which means a practice’s patient panel is compared against a control group rather than against an absolute benchmark. A practice treating patients with treatment-resistant depression is not expected to hit the same raw improvement numbers as one treating mild-to-moderate cases. The comparison is relative.
The second concern is administrative complexity. Switching from CPT-based billing to G-code billing for ACCESS-enrolled patients while maintaining fee-for-service billing for non-enrolled Medicare patients creates a dual-track billing workflow. A practice with 100 Medicare patients where 30 are ACCESS-enrolled and 70 are not needs to run both systems simultaneously. This is where the billing infrastructure matters, and it is exactly the kind of complexity that leads practices to work with a specialized billing partner rather than trying to manage it in-house.
The third concern is whether this model signals where Medicare is heading for all behavioral health. The honest answer is that it probably does. CMS has been moving toward value-based care across every specialty, and behavioral health has been one of the last holdouts because outcome measurement in mental health is harder to standardize than in medical specialties. The ACCESS model is the test case. Practices that build outcome tracking and G-code billing capability now will be better positioned for whatever comes next.
Fee-for-Service vs. Outcome-Based Billing
For psychiatry practices not participating in the ACCESS model, fee-for-service billing remains the standard. Practices continue to bill using CPT codes like 90837 and 90834, receive payment based on the CY 2026 Physician Fee Schedule conversion factor, and manage their revenue through volume. The ACCESS model does not change anything for non-participating practices.
The decision of whether to participate depends on your practice’s readiness. Practices with strong outcome tracking, a stable patient panel, and a billing team that can handle G-code transition are well-positioned. Practices still building their Medicaid and behavioral health billing infrastructure may benefit more from strengthening their fee-for-service operations first and monitoring how early ACCESS participants perform.
In our experience matching providers with billing partners, the practices that struggle most with any billing transition are the ones that try to manage it without dedicated expertise. The ACCESS model adds complexity on top of an already complicated psychiatry billing environment, where add-on codes, time-based documentation, and payer-specific prior authorization requirements already demand specialized knowledge. Whether a practice stays with fee-for-service or moves toward outcome-based payment, the billing partner needs to understand psychiatry-specific coding.
Frequently Asked Questions
The ACCESS model is a 10-year voluntary Medicare payment model launched in July 2026. It replaces fee-for-service billing with outcome-aligned payments for practices treating chronic conditions including depression and anxiety. Participants bill model-specific G-codes and receive payments tied to measurable patient improvement.
Yes. Any Medicare Part B enrolled provider or supplier under a single TIN that treats depression or anxiety can participate. This includes psychiatrists, psychiatric nurse practitioners, psychologists, licensed clinical social workers, and licensed professional counselors.
No. Only enrolled beneficiaries assigned to the behavioral health track are billed under the model’s G-codes. Other Medicare patients and all non-Medicare patients continue to be billed under standard fee-for-service CPT codes. Practices run both billing tracks simultaneously.
The behavioral health track uses PHQ-9 scores for depression and GAD-7 scores for anxiety. A 5-point reduction on the PHQ-9 is generally considered clinically meaningful. In year one, 50 percent of enrolled patients must meet improvement thresholds for the practice to receive full payment.
Yes. Participants may waive beneficiary cost-sharing under the CMS-sponsored model patient incentive safe harbor. However, the policy must be applied uniformly to all enrolled beneficiaries, and anticipated costs must be disclosed before enrollment if the practice collects cost-sharing for non-model patients.
The next entry point is October 1, 2026. Applications received after October 1 but before the subsequent deadline will be considered for participation beginning January 1, 2027. The model runs for 10 years with rolling entry opportunities.
Next Steps
If your psychiatry practice treats Medicare patients with depression or anxiety, start by implementing PHQ-9 and GAD-7 screening at every visit, regardless of whether you plan to participate in the ACCESS model. The outcome data is valuable for quality reporting, payer negotiations, and future value-based care opportunities. If you are considering participation, confirm your Medicare Part B enrollment status and evaluate your EHR’s outcome tracking capabilities. For billing support during the transition, our matching service connects practices with billing companies that specialize in behavioral health coding and compliance across all 50 states.
Psychiatry billing is getting more complex, whether your practice stays with fee-for-service or moves toward outcome-based payment. Get matched with billing companies that specialize in behavioral health coding and compliance. Billing Service Quotes has connected more than 2,000 providers across all 50 states, with over 15 years in medical billing and rates starting as low as 2.95 percent. Finding a match is 100 percent free for providers.
