Mental Health, Depression, and Medicare
How ACCESS, MAHA ELEVATE, and Star Ratings Are Reshaping the Policy Landscape
Three policy mechanisms moved on mental health simultaneously at the end of 2025 and into 2026. The ACCESS model named depression and anxiety as two of its four initial clinical tracks. MAHA ELEVATE listed stress management and social connection among its six intervention domains. The CY 2027 proposed rule introduced a depression screening and follow-up measure to the Star Ratings program for the first time. None of these individually constitutes a mental health coverage expansion, and none resolves the provider supply or network adequacy problems documented in the rest of this series. What they do, taken together, is establish mental health as a quality and cost accountability domain for Medicare for the first time in a coherent and cross-cutting way.
Depression and Anxiety as ACCESS Conditions#
The ACCESS model, announced December 1, 2025 and launching July 5, 2026, tests outcome-aligned payments for technology-supported care in Original Medicare across four clinical tracks. The behavioral health track covers depression and anxiety. Participating organizations are measured on improvement in symptoms using validated patient-reported outcome measures: the Patient Health Questionnaire-9 for depression and the Generalized Anxiety Disorder-7 scale for anxiety, with the WHO Disability Assessment Schedule 2.0 submitted for overall function.
The structural design of ACCESS matters for mental health care specifically. Traditional Medicare pays for discrete services, including psychiatric evaluations, individual psychotherapy, and medication management visits, all of which require a licensed provider billing an established CPT code. What it does not pay for is the continuous, technology-enabled engagement that behavioral health evidence increasingly supports: asynchronous check-ins, symptom tracking between sessions, digital cognitive behavioral therapy, app-based mood monitoring that informs clinical decisions, or the care manager touchpoints that collaborative care models depend on. ACCESS creates a payment category for organizations that use these tools and achieve measurable symptom improvement, compensated through recurring outcome-aligned payments tied to the share of patients meeting defined thresholds.
This is directly relevant to the digital mental health sector, which has operated largely outside Medicare reimbursement structures since its emergence. Digital therapeutics companies with documented outcomes in depression and anxiety, including platforms offering FDA-supervised or enforcement-discretion tools, can now structure participation in ACCESS around their existing clinical evidence. CMS has stated that ACCESS participants must meet FDA requirements or fall under enforcement discretion, with up to 40 manufacturers able to request enforcement discretion status under the FDA TEMPO pilot alongside ACCESS, submitting real-world data that can support future marketing authorization.
The behavioral health track also accommodates collaborative care models and integrated primary care practices. A primary care organization already using behavioral health integration billing codes and PHQ-9 tracking can enroll in the behavioral health track, supplement its care management infrastructure with eligible technology tools, and receive outcome-aligned payments on top of existing fee-for-service billing. A rural health clinic with no on-site psychiatrist but a care manager and a behavioral health telehealth vendor is a plausible ACCESS participant, if the organizational structure and outcome documentation support it. CMS will maintain a vendor directory to help participating organizations identify technology tools. Applications opened January 12, 2026, with an initial deadline of April 1, 2026 for the July cohort, and rolling applications extending through 2033 for subsequent cohorts.
What ACCESS does not do is extend to Medicare Advantage. MA plans are not eligible to participate. Plans may offer similar services through supplemental benefits and their own care management programs, but the outcome-aligned payment structure being tested in Original Medicare does not create a parallel mechanism in MA.
MAHA ELEVATE and Mental Health#
MAHA ELEVATE, announced December 11, 2025 and launching September 1, 2026, takes a different approach. Where ACCESS tests outcome-aligned payments for provider organizations, MAHA ELEVATE funds cooperative agreements for organizations proposing evidence-based lifestyle and functional medicine interventions not currently covered by Original Medicare. CMS will fund up to 30 agreements, each receiving approximately $3 million over a three-year performance period, with a total budget of approximately $100 million. Three awards have been reserved for dementia-related proposals.
The six domains MAHA ELEVATE targets are nutrition, physical activity, sleep, stress management, harmful substance avoidance, and social connection. All proposals must include nutrition or physical activity in their design; the other domains are not individually required but are part of the evidentiary framing the model draws on. For mental health, stress management and social connection are the most directly relevant, though the sleep and physical activity domains both have substantial evidence linking them to depression and anxiety outcomes.
MAHA ELEVATE is explicitly framed as evidence generation, not coverage. CMS has stated it will evaluate cost and quality data from funded interventions to inform future decisions about whether to include them in Original Medicare. No awardee should expect that winning a cooperative agreement creates a path to coverage within the three-year performance period. The model is building a Medicare-specific evidence base for interventions that have been well-studied in other populations but whose cost and quality effects at scale in Original Medicare have not been documented in a form CMS can use for rulemaking.
For the mental health policy landscape, this matters because the interventions most likely to reduce depression and anxiety burden in older adults, sustained physical activity, social engagement, sleep hygiene, and stress reduction practices, are precisely the ones that do not fit the fee-for-service billing structure. The evidence connecting these lifestyle domains to mental health outcomes in the general adult literature is substantial. MAHA ELEVATE is CMS asking whether that evidence translates to Medicare beneficiaries at scale, and what it costs. The National Association of ACOs noted in a public response that many ACOs already provide such interventions using shared savings dollars, and expressed interest in the MAHA ELEVATE pathway as a way to build the evidence base that could shape future Medicare policy.
The potential convergence with the ACCESS behavioral health track is worth noting. An organization that uses a technology-enabled stress management or behavioral activation program targeting depression, documents outcomes with PHQ-9, and can demonstrate improvement could in principle pursue both ACCESS participation and MAHA ELEVATE funding. ACCESS would pay for the outcome-aligned care management. MAHA ELEVATE would fund the evidence generation and costs of non-covered lifestyle services. CMS has not explicitly designed these models to interlock, but they share overlapping target populations and complementary funding logics.
The Star Ratings Depression Screening Measure#
The CY 2027 proposed rule, released November 25, 2025, proposed adding a Part C depression screening and follow-up measure to the Star Ratings program. CMS proposed to display the measure on the 2026 Stars display page using 2024 measurement year data, and then incorporate it as a scored measure in the 2029 Star Ratings, based on the 2027 measurement year. The measure tracks two separate rates: the percentage of eligible MA plan members screened for clinical depression, and among those who screened positive, the percentage who received follow-up care within 30 days. CMS will average the two rates to determine the Star Rating for the measure.
This addition fills a documented gap. Star Ratings in 2025 and 2026 have no specific behavioral health measures. The existing Maintaining Mental Health measure, which uses HOS survey data to assess member-reported emotional well-being and carries a weight of one in 2026 rising to three beginning with 2027 Star Ratings, captures outcomes at the plan level but does not require plans to implement specific screening processes. The proposed depression screening measure directly incentivizes plans to build systematic PHQ-based screening into their primary care networks and to ensure that positive screens connect to timely follow-up.
The financial stakes are substantial. Quality bonus payments for four-star and above MA plans totaled at least $12.7 billion in 2025. Under the proposed 2027 structure, CMS is also removing 12 measures while adding only the depression screening measure, meaning each remaining measure carries greater weight in the overall rating. Clinical measures are expected to constitute approximately 65 percent of the overall score under the new structure, up from roughly 50 percent in 2025 and 2026. In an environment where 89 percent of contracts in Milliman’s scenario modeling would see their Stars scores decline under the proposed changes, a new clinical behavioral health measure entering with zero-gap performance would represent a meaningful competitive differentiation opportunity for plans that move first.
The ACO intersection matters here as well. MA plans contracting with ACO networks that already embed PHQ-9 screening and behavioral health follow-up pathways in primary care workflows can import compliance with the new Stars measure from their provider partners. ACOs participating in MSSP or ACO REACH programs that have built integrated behavioral health infrastructure are positioned as credentialing assets for MA plan contracting relationships in markets where Stars performance is under pressure.
The Combined Signal#
Three different policy mechanisms, ACCESS payments, MAHA ELEVATE funding, and Stars behavioral health measurement, all converge on mental health in the 2025-2026 timeframe. They operate in different parts of the Medicare landscape: ACCESS targets Original Medicare fee-for-service, MAHA ELEVATE funds a small set of organizations to generate evidence, and Stars drives MA plan behavior through quality incentives. They do not collectively solve the provider supply problem, the ghost network problem, or the cost-sharing burden on beneficiaries with depression. What they do is establish behavioral health performance as a dimension of Medicare accountability in ways that generate data, create financial incentives, and open payment pathways that did not previously exist.
For behavioral health providers and digital mental health companies, the practical question is whether and how to organize around these mechanisms. ACCESS is the most direct opportunity: enrollment opens now, the behavioral health track launches July 2026, and organizations that can document PHQ-9 or GAD-7 improvement at the population level have a plausible path to recurring monthly payments from Original Medicare. For MA plans, the 2027 Stars structure creates urgency to build depression screening infrastructure in primary care networks before the 2027 measurement year. For ACOs, both dimensions create reasons to formalize behavioral health integration programs that have in many cases been running on shared savings dollars without quality measurement infrastructure to support them.
Whether any of these translates to access improvement for beneficiaries in counties where no behavioral health providers participate in Medicare is the question none of these models is designed to answer.
Related Reading#
MCR-01_04 ACCESS: Digital Health’s New Medicare Beachhead MCR-02_05 CY 2027 Proposed Rule: Star Ratings, C-SNP RFI, and the HEI Reversal