Get a health technology company into Medicare Part B for ACCESS

To participate in ACCESS, a health technology company needs a Medicare Part B-enrolled TIN eligible to bill under the Physician Fee Schedule, with a Medicare-enrolled physician medical director and every treating clinician enrolled and reassigned to it. Most applicants have never billed Medicare (CMS says so of the first cohort), and for a company in a corporate-practice state, the TIN that qualifies is an affiliated professional entity, not the technology company itself. This guide is about putting that entity in place, whatever the product: a device, a software platform, a telehealth service, or a care-management program. The model’s tracks, payments, and dates are on the ACCESS reference page; the reasoning behind the entity question is in NPI, enrollment, and licensure.

Prerequisites

A clear picture of what the company itself does (sells or licenses a product, or delivers care) because that decides whether it needs to be the participant at all (step 1)
The professional entity formed, with EIN and Type 2 NPI, or a plan to form it in time
A physician (MD or DO) willing to serve as medical director, individually Medicare-enrolled
A list of states where you will enroll beneficiaries, and the licensure plan for each

Steps

Decide which entity is the participant

The participant must be able to furnish physician services lawfully in every state where it operates: the RFA requires a legal entity “authorized to conduct business in each state in which it operates” and compliance with “licensure and scope-of-practice standards under 42 C.F.R. § 424.516.”¹

If you are…	The participant is…
A device or software company whose product clinicians use, but that does not itself deliver care	Nobody: you are not the participant. Enrolled participants use your product; list it in the ACCESS Tools Directory or, for devices, consider the FDA TEMPO pilot. No Part B enrollment is needed, and you cannot bill Medicare for what your customers do.
A health technology company that delivers care and has an MSO-PC structure	The professional entity. The MSO is not a Part B supplier and, in CPOM states, cannot employ the clinicians whose reassignments the model requires.
A health technology company in a permissive state with a lay-owned group practice already enrolled	That enrolled group, provided its state permits it to furnish the services: verify against the state map for every state you will serve, not only the one you are domiciled in.
A physician group adding a technology partner	The group. The platform is a vendor or MSO.
A multi-state PC network	One TIN per participation. The RFA defines participation at the TIN level; a group with several state PCs must decide which PC applies and whether its clinicians can be licensed and reassigned to it across the geographic service area, or whether each PC applies separately.

Anything that follows assumes the company delivers care and the participant is a professional entity with the company behind it as MSO.

Get the participant TIN and its clinicians enrolled

Standard Medicare enrollment, with two ACCESS-specific points. Follow Enroll in Medicare for the CMS-855B, 855I, and 855R; clinicians reassign to the professional entity, never the MSO. The ACCESS points: the entity must be a participating supplier (file the CMS-460), and the application is not approved until enrollment is complete: CMS says to start “as early as possible,” and a PECOS cycle of 60–120 days is what slips a cohort date.²

Appoint the medical director

An MD or DO, individually Medicare-enrolled, employed by or under contract with the participant, “responsible for oversight of care delivery and model performance.” The RFA allows a contract with a self-employed physician or with “a physician employed by a professional entity or physicians’ group.”¹In an MSO-PC structure the natural candidate is the PC’s physician-owner or a senior employed physician. Give the role a written agreement with defined duties, hours, and fair-market-value compensation, and document the time: this is a non-patient-facing role, and the rules that govern paying for it are in Draft a medical director agreement.

Map licensure to the geographic service area

The application asks which states your organization and clinicians are licensed in, which you intend to be licensed in by your start date, and for a certification that “all clinicians delivering ACCESS services will be licensed and in good standing in each state where they practice.”¹ Medicine is practiced where the patient is; a clinician in Texas treating an aligned beneficiary in Ohio needs an Ohio license. Interstate compacts shorten the path: see Digital health and telehealth.If the professional entity itself must be domestic to a state to practice there, the service area for a single-TIN participant may be narrower than your company’s footprint. Decide this before you certify it.

Prepare the fee-for-service certification

Participants and their financially affiliated entities certify that they will not bill Medicare FFS for aligned beneficiaries’ track conditions during the care period; duplicative spend is clawed back through the Substitute Spend Adjustment.³ Identify every commonly owned TIN (the application asks for them) and make sure your billing system can suppress FFS claims for aligned beneficiaries by track.The remaining application requirements (certified EHR and FHIR outcome submission, the cost-sharing waiver or disclosure, cohort dates) are facts rather than decisions; they are on the ACCESS reference page.

Verify it worked

The participant TIN is the entity that may lawfully furnish physician services in every state in the service area
CMS-855B approved; participating status filed
Every treating clinician enrolled and reassigned to the participant TIN; roster maintained
Medical director appointed under a written FMV agreement, individually Medicare-enrolled
Licensure confirmed or scheduled for every state in the service area
Commonly owned TINs identified; FFS suppression for aligned beneficiaries built
MSA’s clinical carve-out covers the model’s clinical decisions: treatment protocols, outcome targets, and patient volume remain with the PC

Common failure modes

Failure	Consequence
The health technology company itself applies as the participant in a CPOM state	It cannot lawfully employ or take reassignment from the clinicians; enrollment certifies compliance it does not have
Medical director is a nominal stipend recipient with no oversight duties	The role fails the RFA’s “responsible for oversight” requirement and the arrangement looks like the “rent-a-medical-director” pattern boards discipline
Clinicians licensed only in the company’s home state	Certification of multi-state licensure is false; services to out-of-state beneficiaries are unlicensed practice
Affiliated TIN keeps billing FFS for the same condition	Substitute Spend Adjustment reduces the OAP; certification breached
Enrollment started after the application	Approval waits on PECOS; cohort date slips a quarter or more

Sources

CMS Innovation Center, ACCESS Model Request for Applications, v1.1 (Feb. 12, 2026), Participant Eligibility Criteria at 13–14; Medical Director at 22; Appendix A Q11–Q14, Q29–Q32.
CMS, ACCESS Technical FAQs, “How do organizations enroll in Medicare to participate in ACCESS?” (updated Mar. 18, 2026).
CMS, ACCESS Payment Amounts and Performance Targets; RFA at 24–28.

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Banking & Finance

Compliance Tasks

Get a health technology company into Medicare Part B for ACCESS

Prerequisites

Steps

Verify it worked

Common failure modes

Sources

​Prerequisites

​Steps

​Verify it worked

​Common failure modes

​Sources

Prerequisites

Steps

Verify it worked

Common failure modes

Sources