Medicare payment policy is increasingly being implemented and tested via new payment models from the Centers for Medicare & Medicaid Services’ (CMS) Center for Medicare and Medicaid Innovation (CMMI), and we expect this to continue in 2026. In 2025, CMMI announced an unprecedented number of health care payment and delivery models and appears to be using its broad authority to implement payment policies that align with the "Make America Healthy Again" agenda. In the last six months of 2025, CMMI announced ten new voluntary or mandatory models; comparatively, in previous years, CMMI released approximately four models on average per year.

In addition to releasing a significant number of models, CMMI also is using the models differently compared to previous years. Although all CMMI models must demonstrate that they are expected to result in cost savings while improving or maintaining quality of care, the models released in previous years have typically focused on niche issues in health care (e.g., models aimed at oncology care or joint replacement surgery). In contrast, several of the new models are targeted at fundamental health care programs and hot-button issues. In all of these models, CMS relies on its broad authority under Section 1115A of the Social Security Act (SSA) to implement sweeping payment policies without being hindered by SSA requirements that would otherwise apply if the policies were implemented outside of the context of CMMI.

Several of the new models announced focus on drug pricing, including the Medicare Part B Global Benchmark for Efficient Drug Pricing (GLOBE) (mandatory), Medicare Part D Guarding U.S. Medicare Against Rising Drug Costs (GUARD) (mandatory), and Generating Cost Reductions For U.S. Medicaid (GENEROUS) Models (voluntary). GLOBE and GUARD are mandatory, meaning model participation is required, and CMS typically uses notice-and-comment rulemaking to establish the model. CMMI also announced in 2025 the Wasteful and Inappropriate Service Reduction (WISeR) Model (voluntary), which utilizes AI to review prior authorization requests for select products and geographic areas under Medicare fee-for-service. Other models announced include the Better Approaches to Lifestyle And Nutrition for Comprehensive hEalth Model (BALANCE) Model (voluntary), aimed at expanding access to evidence-based lifestyle interventions and select GLP-1 medications; and the Advancing Chronic Care with Effective, Scalable Solutions (ACCESS) Model (voluntary) and the Ambulatory Specialty Model (ASM) (mandatory), both targeted towards improving care for chronic conditions.

The models released by CMMI pose both challenges and opportunities for stakeholders. We are closely monitoring the announcement and implementation of the models, observing how they continue to evolve and develop following their initial announcement.