CMS’s MAHA ELEVATE Model: Integrating Entire‑Individual Care into Original Medicare | Epstein Becker & Inexperienced

The Make America Healthy Again: Enhancing Lifestyle and Evaluating Value‑Based Approaches Through Evidence (“MAHA ELEVATE”) Model is a brand new federal initiative centered on increasing entry to preventive and lifestyle-based care choices inside Original Medicare.

What You Need to Know:

• Holistic Health Interventions. The MAHA ELEVATE Model goals to cut back the development of power illness by funding evidence-based useful and life-style medication approaches, resembling dietary assist and bodily exercise, which Original Medicare doesn’t at the moment cowl.

• Cooperative Agreement Funding. Unlike conventional fee-for-service or shared financial savings fashions, this initiative can be financed by way of cooperative agreements totaling roughly $100 million, with a Notice of Funding Opportunity (NOFO) anticipated in early 2026 and a mannequin launch date of September 1, 2026.

• Diverse Participation Opportunities. Eligible candidates embrace non-public practices, well being techniques, and accountable care organizations (ACOs), and the mannequin presents particular pathways for organizations to supply “Food as Medicine” advantages and dementia-related interventions alongside typical medical care.

Introduction

The prevalence of power illness within the United States stays a key focus for the Centers for Medicare & Medicaid Services (CMS). Traditional fee-for-service fashions usually are not transferring the needle quick sufficient, and CMS believes that protection of companies and interventions not at the moment lined by Medicare will assist to deal with the issue.

The MAHA ELEVATE Model is a newly introduced initiative from the CMS Innovation Center (CMMI) that goals to rework preventive care and power illness administration inside Original Medicare. As a mannequin specializing in holistic, useful, and life-style medication approaches, MAHA ELEVATE represents an effort to check interventions at the moment not lined underneath conventional Medicare and collect proof on the impression of those interventions on price, high quality, and affected person outcomes. Patients can be inspired to take possession of their well being by way of life-style adjustments. Novel approaches that embrace diet and bodily exercise can be utilized to assist conduct adjustments that may enhance or decelerate illness development, in addition to tackle power situations that resist remedy by conventional medication. The mannequin is positioned as a voluntary program that might in the end present proof of effectiveness for companies like diet, bodily exercise, and different lifestyle-focused interventions that assist typical medical care. The mannequin will differ from different CMMI initiatives in that it’ll use a cooperative settlement to finance the choice companies, quite than utilizing contingent shared financial savings or claims-based reimbursement.

Interested suppliers needs to be looking out for CMS’s NOFO in early 2026, which we count on will include utility info to take part within the MAHA ELEVATE Model. The mannequin launch date is ready as September 1, 2026.

Overview

The MAHA ELEVATE Model will present roughly $100 million in funding for as much as three-year cooperative agreements that suggest evidence-based interventions designed to sluggish or forestall power illness in Medicare beneficiaries. These interventions should combine useful or life-style medication methods, resembling dietary assist, bodily exercise applications, stress administration, and different wellness-focused actions, that aren’t at the moment lined by Original Medicare. Cooperative agreements can be awarded to organizations with prior expertise integrating holistic measures and which have scientifically documented enhancements in well being. All proposals should embrace diet or bodily exercise of their design. Three awards have been reserved for dementia-related intervention proposals. CMS plans to launch a NOFO in early 2026 for the primary cohort. The second cohort will start in 2027.

Eligible MAHA ELEVATE candidates will embrace:

• Private medical practices
• Health techniques and ACOs
• Academic organizations
• Functional, life-style, preventative, and integrative medication facilities
• Federally Qualified Health Centers and Rural Health Centers
• Community-based organizations
• State or native governments
• Indian Health Service / Tribal Services / Urban Indian Programs
• Senior residing communities

This mannequin is a part of CMMI’s broader Make America Healthy Again agenda, which emphasizes evidence-based prevention, affected person empowerment, and selection in care supply. This mannequin aligns with a bigger shift towards incorporating preventive and health-promoting companies with the purpose of lowering power sickness development and federal spending whereas enhancing high quality of care.

MAHA ELEVATE Services

“Food as Medicine” Nutritional Counseling

MAHA ELEVATE supplies a brand new platform for organizations offering “Food as Medicine” advantages to enter Original Medicare. However, the mannequin will embrace agency limits on what funds can be utilized for. Specifically, whereas diet is a core function of the mannequin, CMS has expressly listed meals itself as an unallowable price. Even with this limitation, organizations offering Food as Medicine may leverage MAHA ELEVATE to supply the ancillary companies supporting meals advantages, resembling culinary medication, meals safety screenings, meal planning, diet teaching and training, meals supply, administration and information assortment and reporting prices, and coordination with public meals advantages (e.g., Supplemental Nutritional Assistance Program and the Special Supplemental Nutrition Program for Women, Infants, and Children).

ACOs and tutorial medical facilities can be pure companions for Food as Medicine corporations fascinated with taking part. Similarly, well being professionals who usually present dietary counseling may discover utilizing MAHA ELEVATE to beat long-standing Medicare protection hurdles. This may embrace, for instance, loosening “incident-to” billing restrictions for dietary counseling and increasing protection to incorporate power situations past diabetes and power kidney illness (e.g., heart problems, weight problems, and malnutrition). 

Dementia Services and Integration with the CMS GUIDE MODEL

As beforehand famous, three participation awards can be reserved for proposals with interventions that tackle dementia.

“Participating Organizations” and “Partner Organizations” underneath CMS’s Guiding an Improved Dementia Experience (GUIDE) Model could also be effectively positioned to even be individuals within the MAHA ELEVATE Model, as they are able to use the MAHA ELEVATE funding in two alternative ways to assist their attributed populations. First, GUIDE MODEL Participating Organizations could possibly create new partnerships with suppliers providing useful or life-style medication companies that don’t match squarely inside Medicare billable companies or one of many 9 GUIDE Care Delivery Services however that serve to forestall or sluggish the development of neurological decline. Second, GUIDE MODEL Participating Organizations might use MAHA ELEVATE funding as a secondary funding stream to pay for useful or life-style medication companies already supplied by an current Partner Organization however not reimbursable by the GUIDE Model. In every state of affairs, the GUIDE Model Participating Organization can probably profit from the extra information assortment and reporting required underneath the MAHA ELEVATE Model to additional inform its care planning and care coordination for its GUIDE Model-attributed beneficiaries.

Alternatively, senior residing communities that in any other case can solely play a restricted function within the GUIDE Model might have a chance to be the primary funding recipient underneath the MAHA ELEVATE Model. Original Medicare typically doesn’t cowl the prices (room, board, and private care) of senior residing communities, so the MAHA ELEVATE Model could also be a very related alternative for these senior residing communities which have a excessive Original Medicare census or a devoted reminiscence flooring. Participating organizations might want to make sure that companies funded underneath MAHA ELEVATE are operationally and financially distinct from companies reimbursed underneath the GUIDE Model to keep away from duplication or impermissible overlap.

Accountable Care Organizations

Participating in MAHA ELEVATE presents ACOs an opportunity to formally design, implement, and rigorously consider preventive and whole-person care interventions, particularly these interventions that ACOs might already present however usually are not reimbursable underneath conventional Medicare. Unlike the Medicare Shared Savings Program or ACO REACH (Realizing Equity, Access, and Community Health), MAHA ELEVATE doesn’t depend on claims-based benchmarking or shared financial savings, however as a substitute presents ACOs a grant-funded pathway to check non-covered companies and generate proof that might form future Medicare coverage. ACOs may submit proposals to check evidence-based useful and life-style medication interventions (e.g., diet counseling, bodily exercise programming, stress discount, sleep well being, social assist, and different behavioral interventions) that concentrate on power illness threat elements resembling poor weight-reduction plan, inactivity, weight problems, hypertension, and diabetes. ACOs usually fund these companies utilizing shared financial savings quite than by way of Medicare fee-for-service reimbursement. By taking part, ACOs not solely safe cooperative settlement funding to cowl the prices of delivering and evaluating these non-covered companies over three years but in addition contribute to constructing the proof that might lead CMS to broaden future Medicare protection to incorporate such preventive and lifestyle-oriented companies, shifting cost coverage towards holistic, upstream care whereas doubtlessly lowering expensive downstream utilization.

Laboratories

Although scientific laboratories are unlikely to be eligible as candidates, they may play a significant function within the MAHA ELEVATE Model in partnering with eligible applicant organizations, together with well being techniques, supplier teams, ACOs, or community-based entities, to contribute experience in biomarker testing, useful assessments, and information technology that assist evidence-based life-style and preventive interventions. By contributing sturdy scientific and laboratory information, a lab associate might help to exhibit the organic plausibility and measurable outcomes of proposed interventions, strengthen the proof package deal required by CMS, and place itself on the forefront of analysis defining how superior diagnostics can improve preventive care and inform future Medicare protection of holistic well being companies. To do that, labs would probably must collaborate with a funded applicant on information assortment, high quality and price outcomes reporting, and execution of the intervention protocol.

Key Takeaways

The MAHA ELEVATE Model represents CMS’s shift in direction of incorporating extra preventive, life-style, and useful care inside Original Medicare. By funding evidence-based life-style and useful medication interventions which have historically been exterior conventional Medicare protection, the mannequin is designed to construct a framework for evaluating impacts on price, high quality, and well being outcomes related to holistic approaches to power illness prevention and wellness promotion.

Organizations fascinated with taking part ought to start:

• assessing their current life-style or useful medication applications,
• figuring out potential companions, and
• evaluating their capability to satisfy CMS’s anticipated proof, reporting, and compliance necessities forward of the anticipated NOFO in early 2026.

Successful pilots might in the end function the inspiration for future Medicare protection choices or new CMMI fashions that broaden entry to preventive and integrative care companies.

This initiative displays a broader repositioning of CMS’s technique towards proactive, patient-centered care and aligns with CMS’s targets to advertise evidence-based prevention, empower beneficiaries to realize their well being targets, and drive selection and competitors throughout the well being system. The outcomes of MAHA ELEVATE might present a brand new template of how Medicare can incorporate non-traditional care initiatives that enhance well being and scale back long-term prices.

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