CMMI’s New Strategic Direction: Trump Administration’s “Make America Healthy Again” Strategy
On May 13th, the Centers for Medicare & Medicaid Services (CMS) Administrator, Dr. Mehmet Oz, and CMS Deputy Administrator and Innovation Center Director, Abe Sutton, hosted a webinar to discuss a new strategic direction for the Center for Medicare and Medicaid Innovation (CMMI). Responding to the Trump Administration’s strategy to “Make America Healthy Again,” Administrator Oz and Director Sutton discussed the three pillars of the CMMI’s new strategic direction: (1) promote evidence-based prevention; (2) empower people to achieve their health goals; and (3) drive choice and competition for people (Strategic Direction).1 This blog will provide an overview of the CMMI and the Strategic Direction outlined during the webinar and materials posted on CMMI’s website.
I. Overview of the CMMI
The CMMI, also known as the “Innovation Center,” was authorized under the Affordable Care Act (ACA) with the goal of designing, implementing, and testing new health payment models to address quality of care and efficient resource management. Although the focus of the CMMI is on Medicare, Medicaid, and CHIP programs, the CMMI also develops interventions that affect patients with commercial insurance, such as multi-payer alignment models.
The ACA funded the CMMI with US$10 billion for years 2011 through 2019 and allocated another US$10 billion to the CMMI each decade thereafter. Notably, this funding is not subject to standard Congressional appropriations procedures. Under the management of CMS, the CMMI has launched over 40 new payment models, including accountable care organizations (ACOs), bundled payment models, and medical home models.
II. New Strategic Direction of CMMI
In their webinar, Administrator Oz and Director Sutton described the three pillars of the CMMI’s Strategic Direction and highlighted the supporting public policy objectives.2 Administrator Oz and Director Sutton stated that the costs that America’s health care systems bear are unsustainable and stressed the need for health care in America to focus on the treatment and prevention of the root causes of diseases as opposed to purely treating symptoms that can lead to poor outcomes for patients.3 To address these challenges, Director Sutton stated that CMS’s Strategic Direction will “leverage innovation and smart public policy” to help people stay healthier longer and also protect federal taxpayers.4
1. Strategic Pillar #1: Promote Evidence-Based Prevention
The first pillar is to “promote evidence-based prevention” by planning to incorporate prevention in all payment model designs.5 Such prevention mechanisms include offering patients incentives for sustained lifestyle changes and lifestyle education and support.6 Additionally, Director Sutton stated that the next phase of the CMMI models will offer patients access to “evidence-based holistic medicine approaches.”7 To drive adoption of such prevention-based activities, Director Sutton also announced that the CMMI will leverage incentives and “utilize waivers to drive preventive care and seek opportunities for patients through community organizations providing evidence-based activities.”
2. Strategic Pillar #2: Empower People to Achieve Their Health Goals
Director Sutton announced that the second pillar is to “empower people to achieve their health goals which starts with giving patients better access to information, tools and support to help them live healthier lives.”8 The CMMI intends to increase patient access to relevant and usable data, so patients can appreciate and understand their health status, set health goals with their providers, avoid out-of-pocket costs, and engage in their care more effectively.9
Director Sutton stated that the CMMI is assessing several tools focused on helping patients make more informed decisions about their care by providing insights into provider cost and performance.10 Moreover, the CMMI intends to “leverage technology and data-sharing, both for the benefit of patients to adopt healthier behaviors and for providers to deliver coordinated care.” Lastly, the CMMI intends to “align financial incentives with flexibilities of health,” which may include the use of waivers to support predictable cost-sharing for certain services, drugs or devices or other performance incentives tied to patient-centered quality measures, including lifestyle.11
3. Strategic Pillar #3: Drive Choice and Competition
The final strategic pillar is to “drive choice and competition.”12 This pillar focuses on testing different models and features that can promote competition in health care markets.13 The CMMI intends to promote models that support a variety of practices and providers, such as those in rural communities and those treating patients with chronic conditions, in order level the playing field for independent practices and providers.14
The CMMI intends to promote choice in care and posed different potential mechanisms it may implement in accordance with this pillar, such as requiring site-neutral payments across settings “to reduce costs and reinvest hospital capacity in outpatient and community-based care through changes to certificate of need requirements” and expanding scopes of practice, virtual care, and at-home care so patients can receive care more flexibly. However, Director Sutton did not have an exact date as to when providers can receive additional information on its new models or changes to existing models.
Notably, Director Sutton expressed concerns about the administrative burden experienced by providers attempting to enter into value-based arrangements. In response, the CMMI intends to standardize model design features where appropriate (e.g., quality measures, benchmarking, and attribution) to reduce the administrative burden of participating in advanced alternative payment models and support multi-payer alignment. In doing so, the CMMI will be assessing models across their life cycles to determine indicators of savings to federal taxpayers.
Indeed, as part of the CMMI’s larger effort to protect federal taxpayers, the CMMI has committed that all models have downside financial risk and require providers to assume some of the financial risk. Further, the CMMI has stated it intends to push Medicare and Medicaid beneficiaries to accountable care arrangements with providers who assume global downside financial risk.15
III. Conclusion
The CMMI’s Strategic Direction in response to the Trump Administration’s strategy to “Make America Healthy Again” focuses on providing patients with information and incentives to engage in healthy lifestyles and prevent and/or mitigate disease with increased access to care. The Strategic Direction is not a departure from the statutory goals of the CMMI. Rather, the CMMI will provide a host of new informational, care management, non-clinical, and clinical tools to patients with, or a likelihood of developing, chronic conditions and target efforts to certain provider types historically not included in models. The result of these activities is to encourage patient engagement in healthy lifestyles and prevent and/or mitigate diseases with increased access to care.
Participants in current CMMI models should watch for potential changes to program design and potential expansion of programs to accommodate new Medicare and Medicaid beneficiaries. Existing attribution and participating consent processes utilized in existing models will likely need to be reworked to support efforts to mandate participation of beneficiaries. Further, the Strategic Direction appears to open the door to non-traditional providers, like care management platforms. These organizations should likewise watch for potential model expansions or announcements which may offer an opportunity to demonstrate their value propositions as part of broad reimbursement models.
Foley is here to help you address the short and long-term impacts in the wake of regulatory changes. We have the resources to help you navigate these and other important legal considerations related to business operations and industry-specific issues. Please reach out to the authors, your Foley relationship partner, or to our Health Care Practice Group and Health Care & Life Sciences Sector with any questions.
[1]CMS Innovation Center Strategy to Make America Healthy Again, Ctrs. for Medicare & Medicaid Servs., (April 13, 2025), https://www.cms.gov/newsroom/press-releases/dr-mehmet-oz-shares-vision-cms.
[2] Webinar: CMS Innovation Center’s 2025 Strategy to Make America Healthy Again (Centers for Medicare & Medicaid Services 2025) (webinar recording not yet released) [hereinafter Webinar: CMS Innovation Center’s 2025 Strategy to Make America Healthy Again]
[3]Webinar: CMS Innovation Center’s 2025 Strategy to Make America Healthy Again.
[4]Id.
[5]Id.
[6]Id.
[7]Id.
[8]Id.
[9]CMS Innovation Center Strategy to Make America Healthy Again, Ctrs. for Medicare &Medicaid Servs., (April 13, 2025), https://www.cms.gov/newsroom/press-releases/dr-mehmet-oz-shares-vision-cms.
[10]Webinar: CMS Innovation Center’s 2025 Strategy to Make America Healthy Again.
[11]Webinar: CMS Innovation Center’s 2025 Strategy to Make America Healthy Again.; Strategic Direction, Ctrs. for Medicare & Medicaid Servs., May 13, 2025, https://www.cms.gov/priorities/innovation/about/strategic-direction.
[12]Strategic Direction, Ctrs. for Medicare &Medicaid Servs., May 13, 2025, https://www.cms.gov/priorities/innovation/about/strategic-direction.
[13]Id.
[14]Id.
[15]Id.
