WISeR, ASM, and ACCESS Updates
Below are recent announcements and news stories about Medicare payment models.
FOIA Document Release Exposes Issues with WISeR Rollout
The Wasteful and Inappropriate Service Reduction (WISeR) is a Medicare model launched in six states on January 1, 2026, that tests artificial intelligence (AI) and other technology-enabled prior authorization for select outpatient services under traditional, fee-for-service Medicare. Documents released through a Freedom of Information Act (FOIA) lawsuit filed by the Electronic Frontier Foundation (EFF) have revealed numerous problems with the model's rollout.
In a blog post, EFF states that “WISeR has resulted in widespread delays and denials of care, operational chaos, and reports of patient harm.” Specifically, EFF identified several concerns with the program, including delayed responses to prior authorization requests (one status report cites a prior authorization request that went unanswered for 83 days), records confirming that WISeR’s payment methodology creates a financial incentive to deny care, WISeR vendors potentially denying claims at unusually high rates, and feedback from medical providers emphasizing that WISeR delays have harmed patients. WISeR was launched just six months after the model was announced. The released document shows that despite warnings from providers and a vendor about insufficient preparation time, the Centers for Medicare & Medicaid Services (CMS) chose not to delay the launch.
Another concern is that although the current model focuses on 13 services, the documentation indicates it could be expanded to include more intensive services, such as cancer treatment and cardiac catheterization, in future years. Concerns about the model have been raised since its announcement. Even Democratic members of Congress and the Government Accountability Office (GAO) have weighed in on the model, yet CMS has remained very supportive of the program, framing it as a tool against waste, fraud, and abuse.
New Documents Raise Concerns with Administration and Republicans
The recent release of the documents may have shifted the Administration's thinking and that of Republicans in Congress. During his nomination hearing last week for Deputy Secretary of HHS, Chris Klomp acknowledged that the model would not be expanded unless it was working properly. During a hearing last week, Politico reported that Republican Rep. Mike Kelly of Pennsylvania expressed support for an amendment (which failed) to increase transparency in CMS oversight of third-party vendors – such as those used in the WISeR model.
Additional reports on the findings from FOIA documents are available HERE, HERE, and HERE.
ASM Participant List Posted
The Ambulatory Surgical Model (ASM) is a mandatory payment model focused on heart failure and low back pain, scheduled to begin on January 1, 2027. The Center for Medicare and Medicaid Innovation (CMMI) published the list of mandatory ASM participants for 2027. According to CMS, there are 2.2k heart failure participants and 3.3k low back pain participants. The dataset includes information on clinicians required to participate in ASM, including their names, National Provider Identifiers (NPI), organization name, cohort, the ASM performance years for which they must meet ASM requirements, and additional descriptors.
The model aims to improve care for Medicare beneficiaries with chronic conditions, but critics say it could reduce access or harm care for these patients. The model has been criticized for its mandatory participation requirements, errors in the types of specialists included on the mandatory participation list, the level of financial risk, which in later years would exceed current Merit-based Incentive Payment System (MIPS) penalties, and the lack of upfront support for participants compared with past CMMI models.
Expansion of CMS ACCESS Model
Under the voluntary Advancing Chronic Care with Effective Scalable Solutions (ACCESS) Model, organizations receive modest payments to use digital health tools to help manage prevalent chronic conditions among patients with traditional Medicare coverage. Instead of paying for individual services, CMS ties payments directly to measurable improvements in patient health.
Last week, CMS announced an expansion of the model; ACCESS will now offer care options to beneficiaries with heart failure, chronic obstructive pulmonary disease, substance use disorders, and nicotine dependence. CMS said the new condition tracks will begin in spring 2027. The voluntary model currently provides options to manage common chronic conditions such as high blood pressure, diabetes, chronic pain, and depression. The model reflects the agency’s priorities of addressing chronic care and expanding digital health use. CMS estimates that three out of four Medicare beneficiaries qualify for at least one ACCESS track. While limited to Traditional Medicare, Medicare Advantage, Medicaid, and private health insurance plans have pledged to adopt an outcomes-based payment structure aligned to ACCESS, supported by CMS implementation resources.
For more information and questions, please contact:
Sheila Madhani
Madhani Healthcare Consulting
Email: smadhani@madhani-health.com
Tel: (202) 679-2977