What MAHA means for the CMS Innovation Center, APMs

3 pillars of the CMS Innovation Center

On May 13, 2025, CMS launched a new strategy for the Innovation Center centered on three pillars: promoting evidence-based prevention, empowering people to achieve their health goals and driving choice and competition.

Under the first pillar, the Innovation Center promised that "prevention will be part of every model" that the center tests.

"We will utilize the most effective ways for providers to offer patients services -- such as exercise and nutritional support -- that promote healthier lifestyles and slow disease progression, as well as provide easier access to evidence-based, complementary and alternative medicine," Sutton explained in the announcement.

For the second pillar, the Innovation Center aims to increase beneficiary access to data and tools for disease management and healthy living, including virtual care and digital health. To empower healthcare consumers, the Innovation Center also plans to publish data about providers and services, including cost and quality performance.

Finally, the Innovation Center aims to drive choice and competition in healthcare by fostering participation in APMs, particularly among independent and rural providers.

Sutton also emphasized that Innovation Center APMs need to demonstrate cost savings and improved outcomes per statutory requirements.

Impact on alternative payment model design

The MAHA approach to Innovation Center strategy will have a significant impact on APM design and payment structure.

Sutton said on the Innovation Center's website that models will "promote access to and use of evidence-based preventive services known to improve outcomes for people and reduce costs to the health system."

In particular, he pointed to "successful elements of previous primary care models, specialty models, and Accountable Care Organization (ACO) models." He also highlighted the use of community-based services in APMs to achieve preventive care.

Future models will also feature waivers to incentivize preventive care and support "predictable cost-sharing" for some services, drugs and devices, according to the Innovation Center's website.

The website also said future models aim to increase access to evidence-based "alternative medicine," data (e.g., cost and quality data), mHealth applications, shared decision-making tools and health education materials.

Under the MAHA approach, the Innovation Center also seeks to standardize APM design features, including quality measurement techniques. Healthcare providers have cited quality measurement as a significant source of administrative burden, particularly since each APM has its own set of quality measures and modes of reporting.

The Innovation Center also plans to standardize benchmarking and attribution models.

Shifting value-based reimbursement to risk

In addition to an overhaul of APM design, the Innovation Center also expressed its intentions to overhaul value-based reimbursement in its models. The Innovation Center will focus on downside risk within APMs "shift financial risk from taxpayers."

According to Sutton, the Innovation Center will require all APMs to involve downside risk and for a higher proportion of Medicare and Medicaid beneficiaries to be in global downside risk arrangements.

He said that providers will also need to bear some financial risk rather than burden conveners like Medicare and third-party payers with all the financial risk.

President Trump has favored a more risk-based approach to APMs. During his first term, the president made changes to the Medicare Shared Savings Program, a permanent APM program through Medicare, to ramp up downside financial risk adoption among ACOs. The changes, known as Pathways to Success, required most participating ACOs to assume downside risk within two years.

Additionally, Sutton shared that the future Innovation Center models will expand the use of advanced shared savings and prospective payments -- particularly for independent practices. The Innovation Center is also considering collecting losses over longer periods for independent providers.

Sutton also hinted that the Innovation Center could make site-neutral payments part of the APMs in its portfolio. This may reduce the reimbursement rates hospitals receive for outpatient services that can be delivered safely in physician practices. The Innovation Center does plan to "reinvest hospital capacity in outpatient and community-based care through changes to certificate of need requirements," he explained.

The future of alternative payment models under MAHA

MAHA is seeping into every facet of healthcare administration in the U.S. as the Trump administration seeks reform. The healthcare approach will especially significantly impact the Innovation Center, its portfolio of APMs and the future of value-based care.

Already, the Innovation Center announced it will end four APMs early, by December 31, 2025. The models are:

• Maryland Total Cost of Care, which was expected to end in 2026.
• Primary Care First, expected to end in 2026.
• End-Stage Renal Disease Treatment Choices, expected to end in 2027.
• Making Care Primary, expected to end in 2034.

In the announcement, the Innovation Center said it was also considering reducing the size of the Integrated Care for Kids model. In addition, it will no longer pursue two announced models: Medicare $2 Drug List and Accelerating Clinical Evidence.

CMS did not provide specific reasons for cutting these particular Innovation Center models. Although, it was reported that the realignment of the Innovation Center portfolio would save nearly $750 million.

The Innovation Center is open to making additional model changes, according to the termination announcement. As the new MAHA-aligned strategy indicates, those could mean more risk-based reimbursement, standardized quality measurement and additional waivers to promote provider and beneficiary engagement.

Jacqueline LaPointe is a graduate of Brandeis University and King's College London. She has been writing about healthcare finance and revenue cycle management since 2016.