CMS ACCESS MSK · Program Live July 5, 2026 Cohort 1 Closed · Cohort 2 Open Now 10-Year Model · 2026–2036

Your PT practice just became
the MSK quarterback.

CMS ACCESS pays PT practices $100 per patient per year to longitudinally manage chronic MSK — decoupled from visit volume. JointCoach provides the RTM data layer, PROM engine, and physician-attested compliance infrastructure to get your practice enrolled and generating revenue from Day 1.

$180
OAP per patient / yr (total)
$100
PT co-management fee / yr
12 mo
12-month longitudinal care period
94%
PROM compliance on JointCoach platform

Three revenue streams. One patient panel.

ACCESS is not just an OAP check. For PT practices using JointCoach, the full revenue architecture spans pre-ACCESS RTM, the ACCESS co-management fee, and post-ACCESS RTM resumption.

$154
per patient · pre-ACCESS RTM

Phase 1 — RTM On-Ramp

JointCoach RTM (CPT 98985 + 98979) runs 1–3 months pre-enrollment. Establishes digital literacy and collects baseline PROMs. Revenue continues during this phase.

RTM Active
$100
per patient / yr · PT co-management fee

Phase 2 — ACCESS Period

Your practice earns $100/pt/yr as the co-managing clinician. Monthly digital check-ins (~3×/year review, no extra visits required). RTM billing pauses to avoid Substitute Spend penalty.

Core Revenue
$1,260
per patient · post-ACCESS RTM resumption

Phase 3 — RTM Returns

After the 12-month ACCESS period, RTM billing resumes at full rate (~$1,260/yr/pt via CPT 98977 + 98980). Patients remain on JointCoach. Revenue scales with panel size.

RTM Resumes
50
patients enrolled
$5,000 / yr
co-management fee only
100
patients enrolled
$10,000 / yr
co-management fee only
250
patients enrolled
$25,000 / yr
+ post-ACCESS RTM upside

Choose the path that fits your practice.

Every PT practice is different. Practices inside ACO networks follow a different on-ramp than post-discharge orthopedic practices. JointCoach supports both.

1

ACO / PCP Partnership

Primary Care Triage Model
ID

Identify Candidates

Your ACO or PCP partner identifies beneficiaries with chronic MSK via claims analysis or HIE queries. Chronic MSK pain > 3 months required.

Eval

PT Evaluation & Triage

PT performs initial functional evaluation under FFS. Confirms eligibility and biopsychosocial complexity. Low-complexity patients route digital-first.

Digital-First ACCESS Eligible
Co-M

Enroll & Co-Manage

Enroll patients into ACCESS via JointCoach. Monthly digital PROM check-ins. PT remains clinical hub for triage and care decisions throughout the 12-month period.

2

Post-Discharge Model

RTM-to-ACCESS Bridge
FFS

Standard PT Episode

Deliver standard in-person care for the presenting complaint. JointCoach RTM runs in parallel during the FFS episode — building baseline data and digital habits.

RTM Billing Active
Flag

Identify Transition Candidates

Flag patients with chronic MSK near discharge — those likely to remain symptomatic or benefit from longitudinal support. JointCoach surfaces PROM trends to guide triage.

RTM Bridge ACCESS
Enroll

ACCESS Transition

Enroll for 12-month longitudinal support and outcome tracking. RTM pauses during ACCESS to avoid Substitute Spend penalty — resumes at full rate post-program.

Every instrument. Every cadence. Built in.

CMS ACCESS requires audit-ready PROM collection at baseline, quarterly, and end-of-period. JointCoach auto-collects every instrument on schedule — no staff follow-up required.

Category Instrument Indication Success Threshold Collection Schedule
Generic PROMIS Physical Function 6b/CAT All MSK ↑ 2-pt T-score
BQE
PROMIS Pain Interference 6a/CAT All MSK ↑ 2-pt T-score
BQE
Site-Specific KOOS JR Knee ↑ 10 pts
BQE
HOOS JR Hip ↑ 10 pts
BQE
Oswestry (ODI) Back ↓ 8 pts
BQE
Neck Disability Index (NDI) Neck ↓ 8 pts
BQE
QuickDASH Shoulder/Arm ↓ 10 pts
BQE
Pain NRS 0–10 All MSK ≤ 2-pt increase
BQE
Global PGIC All MSK Qualitative anchor
E

B Baseline (Day 0–60)  ·  Q Quarterly (Month 3, 6, 9)  ·  E End-of-Period (Day 425 + PGIC)  ·  Goal: ≥50% of enrolled patients meeting improvement threshold (OAT).

Two rules that can cut your revenue in half.

MSOs, PE-backed groups, and practices with complex ownership structures: the affiliation and substitute spend rules are the most consequential part of ACCESS. Read them before you structure any partnership.

Affiliation Rule · Critical

The "5% Trap"

If a parent organization owns ≥5% equity in the ACCESS Participant, ALL other entities under that parent become "Affiliates" — and are excluded from FFS billing for enrolled patients.

For large PT groups or MSO-backed practices: if your management company or PE sponsor owns ≥5% of the ACCESS entity you create, your entire PT practice loses FFS billing capability for those patients. Structure carefully.

Strategy A

Total Pivot

Complete transition to ACCESS for that patient population. Embrace FFS exclusion as a feature, not a bug.

Strategy B

Arm's Length

Structure partnership via service contracts, not equity. Keep cross-ownership below 5% to maintain FFS billing for non-enrolled patients.

Revenue Risk · Severe

Substitute Spend Threshold (SST)

If more than 10% of enrolled patients' FFS spend is on services also billed by Affiliates, the SST penalty fires. Maximum penalty: 25% floor on your reconciliation payout — worse than the clinical outcome penalty.

JointCoach's RTM billing intentionally pauses during the 12-month ACCESS period to keep your SST below 10%. This is not an accident — it's the sequencing that protects your reconciliation payment. Pre- and post-ACCESS RTM remains fully billable.

JointCoach's built-in protection
The RTM → ACCESS → RTM sequence is compliant by architecture. Phase 1 RTM (~$154/pt) builds digital habits and baseline PROMs. Phase 2 ACCESS ($100/pt/yr co-management, RTM paused). Phase 3 RTM resumes post-Day 425. SolvingHealth's WORM audit chain provides the documentation trail for OIG review from transaction #1.

One platform with surgeon integration. The others don't have it.

Hinge Health and Sword are B2B employer plays. RevelAI and Limber are PT tools. Neither captures downstream surgical revenue or closes the surgeon ↔ patient ↔ PT loop. JointCoach does.

Tier 1 Giants

Hinge Health & Sword

B2B employer focus — non-Medicare
No local surgeon integration
Cannot capture surgical revenue
Not built for CMS ACCESS MSK
Tier 2 Movers

RevelAI & Limber

Pure PT infrastructure tools
No physician attestation layer
Cannot capture downstream surgical revenue
No surgeon referral network
The Orthopedic Platform

JointCoach + SurgeonValue

Orthopedic surgeon-led — only one
Physician-attested AI governance
Surgeon → PT → Patient closed loop
WORM audit chain for OIG defense
ACCESS + RTM + FHIR R4 native

Enrolled and billing in three phases.

JointCoach guides your practice through every step — from Cohort 2 application through first patient onboarded and first PROM collected.

1
Weeks 1–4 · Foundation

Assess & Contract

Submit Cohort 2 CMS ACCESS application with JointCoach support
Map your PT partner network and patient panel
Confirm affiliation structure (5% rule review)
Sign co-management agreement and set PROM thresholds
2
Weeks 5–8 · Integration

Technology & Training

Embed SolvingHealth harness.js for physician attestation
Connect JointCoach RTM → SurgeonValue data feed
Train clinical staff on PROM collection cadence
Configure MediaPipe ROM capture for patient-facing app
3
Weeks 9–12 · Pilot Launch

First 100 Patients

Onboard first 100 patients via RTM pre-ACCESS on-ramp (~$154/pt)
Validate baseline PROM collection (Day 0–60 window)
Confirm SurgeonValue referral pathway active
Prep for Cohort 2 ACCESS enrollment start

Cohort 2 is open now.

Program goes live July 5, 2026. Cohort 2 accepts quarterly rolling admissions. Tell us about your practice and we'll walk through whether JointCoach is the right fit — and what your enrollment and revenue timeline looks like.

April 1, 2026 — Closed
Cohort 1 Application Deadline
July 5, 2026
Program Live · Cohort 2 Open
Through April 2033
Quarterly Rolling Cohorts
June 2036
Model Conclusion

Tell us about your practice

We respond within one business day. No obligation — we'll tell you if we're not the right fit.