It’s Happening: The CMS Move that is Shifting the Private Practice Landscape…AGAIN
I’ve Been Saying This for Over a Year
If you’ve followed me on TikTok, been in my world on Facebook, or attended the webinar I hosted specifically about what 2026 would mean for private practice owners, none of this is a surprise. I have been talking about the structural shift happening in behavioral health delivery for over a year. Not to be alarmist. Because the data was already pointing somewhere, and I believe private practice owners deserve to see it clearly before it arrives at their door. This week, it arrived.
What Just Happened at CMS
On April 13, 2026, the Centers for Medicare & Medicaid Services confirmed that over 150 organizations have been provisionally accepted into the ACCESS Model, short for Advancing Chronic Care with Effective, Scalable Solutions. This is a 10-year, voluntary federal payment program launching July 5, 2026.
The organizations approved include mental health apps, digital health startups, wearable device makers, and technology companies backed by some of the largest players in healthcare. They will receive recurring, outcome-based payments from Medicare to manage chronic conditions, and the behavioral health track covers depression and anxiety.
Yes, the two most common diagnoses in your practice.
What the ACCESS Model Actually Does
Traditional Medicare fee-for-service has always paid for specific activities, a session, a code, a defined service. The ACCESS Model changes that model entirely. Participating organizations receive recurring payments tied to measurable health outcomes for their enrolled patients.
Here is what that means in practice:
CMS will publish a public directory of all ACCESS participants, including the conditions they treat and their measured outcomes
Primary care physicians and referring clinicians will be able to send patients directly to listed organizations
Patients can enroll with ACCESS organizations directly, alongside or instead of their traditional providers
The program runs for 10 years, this is not a pilot. This is infrastructure.
Why Private Practice Owners Who Do NOT Take Medicare Are NOT Off the Hook
This is the part of the conversation that tends to get skipped. And it’s the part I feel most passionate about sharing.
CMS is simultaneously running the Innovation in Behavioral Health (IBH) Model, a parallel restructuring of how Medicaid behavioral health is funded and delivered. The IBH Model is explicitly designed to align Medicaid and Medicare payments toward integrated, technology-enabled behavioral health organizations. It launched in Michigan, New York, and South Carolina in January 2025, with more states to follow.
Both programs are pointing in the same direction: away from individual providers billing fee-for-service, aka 1:1, and toward organizations delivering measurable outcomes at scale. It is unclear the exact framework for this, whether it is independently verified as evidence based or if the individual providers will get to choose how they show progress. I’ll be continuing my research on this, and keep you informed as I do, connect with my newsletter here to stay in the loop.
If your entire revenue comes from insurance-reimbursed sessions, Medicare, Medicaid, or commercial, the structural logic of your business is being challenged. Not because your clinical work isn’t valuable. Because the payment architecture around you is being deliberately redesigned. This isn’t particularly unexpected. This system was never built to support weekly sessions for multiple family members to receive care. This move is the natural byproduct of years of decreasing mental health stigma and increasing visibility of the value of mental health care.
The Referral Shift Is the Real Risk
Here is what will happen quietly, and then all at once:
PCPs and referring physicians will see the CMS directory of ACCESS-approved organizations for depression and anxiety management
Some will begin routing Medicare patients there, especially as outcome data becomes public
ACCESS organizations will have marketing budgets, technology infrastructure, and federal backing that most individual private practice owners cannot match
Clients who find care through these systems may not find their way back to private practice
This is not speculation. This is what happens when a new infrastructure-level delivery system is funded and made visible at the federal level.
The part that concerns me the most
As someone who values equitable access, ease of enrollment and good health outcomes, you might think that I’m for this. But as someone who understands how marginalized communities get left behind with a quest toward ‘progress’ that makes the richest among us even wealthier, here’s what is more likely to be the case.
PCPs, who are overworked and already under pressure, will be less likely to defer the $100 referral bonus and send clients to the office around the corner than they will the tech based apps who promise change. The office, who had to let the part time receptionist go, and instead returns calls in between clients has a hard time keeping up with admin. So, the doctor chooses to refer the 62-year-old African American man with Diabetes, who is experiencing an increase in his recurrent depression symptoms to Headway instead.
He doesn’t understand the QR code, but gets his grandson to help by scanning it and helping with the text registration. He is pretty good with texting, so when he gets a message from who he thinks is a therapist, but is actually a chat bot, he starts chatting and schedules his first appointment.
But it does not go well, and he grows frustrated when he tries to use the iPad that his grandson set up for him over the weekend, because of the lagging internet speed in his low income community, and instead of having his session, he gets a text saying that he needs to reschedule for another time.
The next time he gets it scheduled, he uses the library’s internet, but he doesn’t really connect well with the therapist who has a caseload of 100 clients and doesn’t really understand his needs. He gives up and decides to just tell the doctor he’s ‘fine’ at his next checkup, even though he’s not.
Here’s what no one is saying: Marginalized communities are often not served best by these programs and unless the 150 providers who have been selected are willing to provide access to the technology needed in places where federally provided phone and discounted internet access have been slashed, the people most in need may have the highest hurdles. I would bet the first apple watch is free, but will they provide a wifi enabled cell phone? A laptop?
But think about the deeper issues too.
How will the community mental health centers, who largely provide care to Medicaid and Medicare patients, maintain operations while having their grant budgets gutted and also likely their largest payor, CMS, now paying the billionaire-owned Headway? Where will the graduate school place the interns, more industrious than most, who figured out how to pay for school without the loans? Will they be able to find practicum or internship placements, if the hospitals are overcrowded with the only the highest acuity of patients and there are few private practices to fill in the gap? Because what private practice owner can stay afloat if the private insurers decide to follow CMS guidelines?
What Actually Protects a Private Practice Owner
I was accused of inciting anxiety when I shared this info in a Facebook group. That was surprising, but only mildly.
As someone who understands marketing and has at least some grasp on the way to use the algorithm to my advantage, I do have to occasionally be jarring, but providing the truth, with context, is not being an alarmist. I believe that many of the therapists who are in their own practice, who will be wondering why inquiries are down to a trickle 2 years from now, would prefer this preview of what’s to come while they still have time to do something about it, so here’s my take.
The practice owners who will navigate this shift with the most confidence are the ones who have already done one thing: built revenue that does not depend entirely on any single payer system.
That means:
Coaching programs, consulting, and group offerings that operate outside the insurance billing system
Direct-pay or hybrid models that give you pricing sovereignty,
Digital products and programs that scale without adding clinical hours
A clear client relationship and brand that third-party technology platforms cannot replicate
This is not about abandoning insurance or Medicare patients. It is about refusing to let one payment system hold the entire weight of your business.
What I’m Doing About This Right Now
Many of you know that in addition to being a Fractional Director of Operations for a group practice in Indiana, I have been helping private practice owners build exactly this kind of structural protection, diversified, scalable revenue beyond the clinical session. It is the foundation of everything I built helping us cross the 20,000 session mark while generating millions in revenue, and everything I now teach to my individual coaching clients and Leverage Lab practice owners. I’m also currently exploring helping a few practice owners create their own membership model, similar to a Direct primary care approach.
If you are a private practice owner who has been thinking about what comes next, how to add revenue that isn’t tied to your billable hours, how to stop being at the mercy of insurance reimbursement rates, how to build something that actually belongs to you, I want to talk to you.
I’m running the Own Your Practice Challenge April 21–23, specifically for practice owners who are ready to get serious about exiting or reducing their dependence on third-party insurance, and/or the platforms, without losing income in the process.
JOIN THE OWN YOUR PRACTICE CHALLENGE
The ground is shifting. The question is whether you’re building on something solid enough to move with it. And remember, when you get my support, I show you how to build so that you don’t have to choose between peace and profit, you get to have both.