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March/April 2026    Volume 7 Issue 2
Health Law Connections

CMMI and the Next Generation of Alternative Payment Models

This Feature Article is brought to you by AHLA's Regulation, Accreditation, and Payment Practice Group.
  • March 01, 2026
  • Scott Strickland , Hall Render Killian Heath & Lyman PC
  • Raminta Kizyte , Hall Render Killian Heath & Lyman PC
Doctor at desk

The Center for Medicare and Medicaid Innovation (CMMI) occupies a unique place in federal health law and policy. Established under the Affordable Care Act in 2010, CMMI is authorized to design, implement, and test new or revised health care payment models that lower health care spending for Medicare, Medicaid, and the Children’s Health Insurance Program while maintaining or enhancing the quality of care furnished under these programs. One of CMMI’s key features is its statutory authority to test innovative payment and care delivery models without going through the traditional notice-and-comment rulemaking process, which can be time consuming. This flexibility enables CMMI to launch, modify, and terminate models more quickly, allowing for more timely and responsive reforms in Medicare, Medicaid, and the Children’s Health Insurance Program. This agility has made CMMI a leader in driving health care transformation through rapid testing and iteration of new ideas. Over the past 15 years, CMMI has tested a wide range of alternative payment models, including accountable care organization programs, bundled payment initiatives, and population health pilots.

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