CMS Announces MAHA ELEVATE Model: A New Opportunity to Shape Reimbursement for Lifestyle, Functional, and Whole-Person Care Services
The Centers for Medicare & Medicaid Services (“CMS”) has announced the MAHA ELEVATE Model (Make America Healthy Again: Enhancing Lifestyle and Evaluating Value-Based Approaches Through Evidence), a new initiative designed to evaluate evidence-based interventions for chronic disease management and prevention in Medicare populations.
Set to launch its first cohort in September 2026, MAHA ELEVATE represents a significant shift in how Medicare may pay for evidence-based lifestyle, functional, and whole-person care services that are currently not covered under Medicare. With $100 million in funding available across two award cycles, this model presents an opportunity for organizations delivering preventive, lifestyle-based, or functional medicine interventions to partner directly with CMS, and potentially shape future Medicare coverage and reimbursement.
Overview of the MAHA ELEVATE Model
The MAHA ELEVATE Model aims to evaluate up to 30 evidence-based interventions that promote nutrition, physical activity, lifestyle modification, and whole-person support for Medicare beneficiaries living with chronic conditions. CMS’s goal is to build a U.S. evidence base—spanning cost, outcomes, and patient experience—to inform future Medicare coverage determinations.
Key characteristics of the Model include:
3-year cooperative agreements for each awardee
A focus on whole-person care, including functional or lifestyle medicine
Interventions must not currently be covered by Medicare, must include a nutrition or physical activity component, and must have documented evidence of the intervention’s safety, efficacy, and cost impact
Three awards will be reserved for dementia-focused interventions
Who is Eligible to Apply?
MAHA ELEVATE applications are open to a broad range of entities, including:
Private medical practices
Health systems and accountable care organizations (“ACOs”)
Academic medical centers
Functional, lifestyle, preventive, and integrative medicine centers
Federally Qualified Health Centers (“FQHCs”) and Rural Health Clinics (“RHCs”)
Community-based organizations
State or local governments
Tribal/Urban Indian Health programs
Senior living communities
Applicants may apply individually or through partnerships, and CMS will allow organizations to submit multiple distinct proposals.
What Types of Interventions Will CMS Consider?
Proposals must focus on whole-person care for chronic conditions. These interventions must not already be covered by Medicare, and must have documented scientific evidence of safety, efficacy, and potential cost impact. Interventions may include components such as:
Lifestyle medicine
Functional medicine
Nutrition interventions
Physical activity programs
Stress management
Sleep interventions
Social connection/support services
Harmful substance avoidance programs
Applicants must demonstrate the ability to collect and report clinical outcomes, quality metrics, and cost data, as well as have an infrastructure to store and analyze data consistent with CMS requirements.
Scope of Funding
Awardees can use MAHA ELEVATE funding for whole-person care services not currently covered by Medicare and for program administration, data collection, and recording.
Funding cannot be used to cover food or for services that are currently billable to Medicare.
Why MAHA ELEVATE is a Significant Opportunity for Healthcare Innovators
A pathway to influence future Medicare coverage. CMS is explicitly using MAHA ELEVATE to generate evidence that may justify future coverage of lifestyle and functional medicine interventions for chronic conditions. Programs selected may help set the standard for what Medicare reimburses in the next decade.
Federal funding for lifestyle and functional care. Historically, prevention and lifestyle programs have struggled to find reimbursement pathways. MAHA ELEVATE directly funds service delivery, removing a major commercial barrier.
A validation opportunity for digital and hybrid care models. Digital platforms, behavior change apps, connected fitness tools, AI-driven coaching, and virtual lifestyle medicine programs may be able to demonstrate scalable preventive impact.
Strong alignment with CMS’ broader shift toward value and outcomes. MAHA ELEVATE complements other initiatives, such as CMS’s ACCESS initiative and the FDA’s TEMPO initiative, creating a cohesive national strategy for long-term chronic disease mitigation.
Timeline:
Early 2026: CMS issues the Notice of Funding Opportunity (NOFO)
2026: First cohort begins September 1, 2026
2027: Second cohort launches
Up to 30 total interventions will be funded across both cohorts
How Digital Health Companies and Other Healthcare Innovators Can Prepare
Validate and evidence-base your intervention. Focus on services with strong evidentiary support, such as nutrition programs, physical activity interventions, functional medicine protocols, and community-based programs that are not currently reimbursable by Medicare.
Begin compiling internal outcomes data. CMS will require proof of prior success.
Strengthen data infrastructure and privacy protocols. Accurate, secure, and CMS-aligned data collection is essential.
Map your intervention to chronic conditions with demonstrated need. Ensure the proposal addresses the core focus of the model: Medicare beneficiaries living with chronic conditions.
Build partnerships. Community organizations, digital health vendors, academic partners, and clinical groups may all enhance the strength of your proposal.
How Nixon Law Group Can Help
Nixon Law Group is prepared to support organizations evaluating whether to apply for MAHA ELEVATE, including assessing eligibility and strategic fit, reviewing effectiveness and implementation data, and ensuring HIPAA, privacy, and data governance readiness.
MAHA ELEVATE represents CMS’s direct effort to generate evidence on whole-person, lifestyle, and functional interventions in Medicare populations. Digital health companies with interventions not currently reimbursable by Medicare have an opportunity to present a case for coverage and shape the future or chronic disease care.