This edition covers:
Since May of 2025, The U.S. Department of Health and Human Services (HHS) and Centers for Medicare and Medicaid Services (CMS) have been on a regulatory sprint, issuing multiple requests to solicit public information on top of normally scheduled rule-making. One example is CMS' May request for information on a health tech ecosystem. Another is HHS' request for Information on deregulation. The White House has also weighed in, including a statement on creating a patient-centric ecosystem.
As an organization that strives to be a thoughtful representative of the digital health sector in the healthcare ecosystem, Omada participated in this sprint by providing actionable recommendations for how CMS and HHS can take advantage of digital health to effectively bend the curve of chronic disease. Here are the top five, which are reflected in the Center for Medicare & Medicaid Innovation ACCESS Model announced December 1, 2025.
First, CMS should embrace the ability of America’s seniors to get care outside of physician offices and hospital complexes. Hundreds of thousands, if not millions, of adults ages 18 to 64 regularly get care through virtual programs, but to date, these programs have largely gone unrecognized by CMS. However, for the first time in the Physician Fee Schedule (PFS), effective January 2026, CMS proposed to allow any modality of CDC Fully Recognized Diabetes Prevention Programs (DPP) to apply to serve the Medicare population.
Historically, video-based telehealth has been permitted for select services, and a few online components offered by in-person programs have been used to fill in gaps of in-person services since the pandemic; however, no 100% virtual programs have been allowed to serve the Medicare population until now. While that’s a step in the right direction, the Medicare Diabetes Prevention Program (MDPP) will be one of the only, if not the only, CMS benefit that is authorized to be offered 100% virtually.