Missing the Forest for the Models…
CMS introduced nine new value-based care models in 2025 — seven of them in the final quarter alone. On the surface, many look familiar: extensions of approaches that have already demonstrated quality improvement and cost reduction. Most of the conversation has stayed there — at the surface.
What's new is the shift from testing isolated models of care to restructuring the conditions under which care is delivered at a system level. That's a different objective entirely.
Historically, CMMI models functioned as pilots — discrete efforts to prove that better outcomes and lower costs were achievable under the right conditions. The question being tested was whether value-based care could work.
CMS is now asking something else: what would it take to make those conditions the default?
For most of the Innovation Center's 15-year history, one to three major models launched per year. Seven in a single quarter is not a continuation of that pattern. It's a break from it.
The Signal Beneath the Programs
Take the Rural Health Transformation Program — a $50 billion, five-year commitment to restructuring healthcare delivery in communities where volume-based models have consistently failed. What stands out is not a specific intervention but the underlying premise: access doesn't break at a national level. It breaks in specific communities, for specific patients, in specific moments. Fixing it requires care models built with the same granularity.
Telehealth helps where geography creates barriers, but it's a tool. The harder work is reorganizing care so people engage with it before their needs escalate into crisis — something that requires restructured workflows, locally adapted resources, and financing models designed for environments where volume alone can't sustain a practice.
Or consider the LEAD Model, which succeeds ACO REACH beginning in 2027. Its most notable feature is structural: a ten-year performance period, the longest CMS has ever tested. That timeline is not arbitrary. It reflects a recognition that meaningful health outcomes — particularly for complex, high-needs populations — often don't materialize within a single performance year. Prior models compressed long-term change into short evaluation windows. LEAD is designed around the actual arc of health improvement, and that has real implications for how organizations plan, invest, and measure success.
CMS has signaled its intention to sunset traditional MIPS entirely, transitioning to MIPS Value Pathways — specialty-specific, outcome-oriented reporting frameworks — with mandatory adoption potentially as early as 2029. The Ambulatory Specialty Model, launching in 2027, goes further: it places physicians treating heart failure and low back pain episodes under mandatory performance-based payment adjustment, with financial risk increasing over time. Voluntary reporting as a default assumption is being phased out. The question is no longer whether a clinician chooses to participate in accountability — it's what form that accountability takes.
This Isn't About Programs
It's easy to view this wave of activity through a political lens. The Trump administration's CMMI agenda is distinct in emphasis — prioritizing prevention, consumer engagement, and technology-enabled care over broad participation. Some earlier models were ended. Others were restructured.
But the scale of what's happening exceeds any single administration's preferences. It reflects something the industry has not resolved on its own.
For years, healthcare has talked about prevention, whole-person care, and proactive coordination. These haven't become the foundation of how care is delivered or financed — not because the ideas are wrong, but because the incentive structure never required it. Fee-for-service buffered providers from the downstream consequences of fragmentation. The complexity of value-based models and providers' comfort with conventional fee-for-service have slowed adoption, and as of June 2025, only 45% of Original Medicare beneficiaries were aligned to an accountable care relationship — more than a decade into the Innovation Center's existence.
If the system won't close that gap voluntarily, the structure will be redesigned until it does.
The Real Implication
This is not system transformation in the abstract. It is a transfer of accountability.
Providers and organizations are being asked to own outcomes they have historically been insulated from — clinically, operationally, and financially. The risk in this environment is not participation. It's misinterpretation.
Organizations that treat these models as programs to join, rather than signals to redesign, will underperform over time. The evidence for why is already well documented. Implementing or joining a value-based payment model requires substantial resources and infrastructure that most organizations haven't built. Providers serving vulnerable populations — including rural and low-income patients — continue to face barriers to participation precisely because their operational foundation was never designed to support these models. Layering new payment arrangements onto misaligned workflows and disconnected data doesn't produce different results. It produces the same results with additional reporting requirements.
The design has to change, not just the incentives.
Where This Goes
The organizations that succeed will move early and differently.
They'll recognize that there's a real lag between investment and measurable outcomes, and that financial performance won't align with traditional planning timelines in models designed to run a decade. The ACCESS Model runs through 2036. LEAD runs through 2036. These aren't programs to optimize quarterly. They require multi-year infrastructure decisions made now, before the picture is fully clear.
Most importantly, they'll design around people — not metrics. None of this works unless systems are built around how patients and clinicians actually experience care. That means creating conditions where the right actions are the easiest ones to take: proactive care enabled by aligned data, workflows built for coordination rather than compliance, and accountability structures that reflect the real arc of health rather than what fits in a reporting cycle.
That is the work. And it's where strategy has to move from interpretation to design.
If your organization is evaluating how to respond to these changes — structurally, not just operationally — Adverus Value Strategies works with leadership teams to translate policy shifts into actionable strategy.
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