Your Data Partner for MAHA ELEVATE
CMS's new $100M cooperative agreement model requires beneficiary-level reporting of clinical outcomes, utilization, and costs across a 3-year evaluation. We handle the data infrastructure so your team can focus on the intervention.
MAHA ELEVATE at a Glance
CMS Innovation Center cooperative agreement
What is MAHA ELEVATE?
The Make America Healthy Again: Enhancing Lifestyle and Evaluating Value-based Approaches Through Evidence (MAHA ELEVATE) Model is a CMS Innovation Center cooperative agreement program funding evidence-based, whole-person lifestyle and functional medicine interventions for Original Medicare beneficiaries.
Unlike traditional shared savings or claims-based models, MAHA ELEVATE is structured as a grant — CMS provides up-front funding (~$3.3M average per award) for organizations to deliver lifestyle medicine interventions not currently covered by Original Medicare.
Every proposal must include a nutrition or physical activity component, and may also address sleep, stress management, social connection, or substance avoidance. Three of the 30 awards are reserved for dementia-focused programs.
What sets MAHA ELEVATE apart is its rigorous evaluation requirement: every awardee must implement a randomized design (or valid comparison group) and report beneficiary-level data on clinical outcomes, utilization, and costs to CMS throughout the 3-year performance period.
Cooperative Agreement (Grant)
Up-front funding, not claims-based reimbursement. Funds may cover data collection, reporting, and administrative costs.
Two Cohorts
Cohort 1 launches September 2026. Cohort 2 follows in 2027 — application planning starts now.
RCT-Style Evaluation
Awardees must implement randomized or quasi-experimental designs with rigorous outcome measurement.
Enrollment-Tied Funding
A significant portion of funding is tied to meeting enrollment targets — typically 1,000+ Medicare FFS beneficiaries.
What CMS Expects From Awardees
MAHA ELEVATE doesn't have a fixed measure set the way MIPS or MSSP does — CMS co-designs the data plan with each awardee. But the reporting categories and capabilities required are concrete, and they're exactly where most clinical applicants need a partner.
Beneficiary-Level Clinical Outcomes
Regular reporting of biometrics and health status indicators relevant to the intervention — BMI, A1c, blood pressure, lipid panels, depression screening scores, and other condition-specific measures.
Service Utilization & Process Measures
Encounter-level tracking of intervention delivery, beneficiary engagement, dosing/frequency, and adherence — needed to demonstrate that the intervention was delivered as designed.
Enrollment & Recruitment Reporting
Documented recruitment of Medicare FFS beneficiaries against CMS-set targets. Funding is tied to meeting enrollment thresholds — typically 1,000+ beneficiaries with treatment and comparison groups.
Cost Impact Data
Healthcare utilization and cost tracking alongside clinical outcomes — the core evidence CMS needs to evaluate whether the intervention could justify future Medicare coverage.
HIPAA-Compliant Data Infrastructure
Beneficiary safeguards, secure data transmission, and proper data governance — auditable by CMS throughout the 3-year performance period.
Quarterly CMS Submissions
Ongoing data submission cadence to CMS for model monitoring and evaluation — with validation, error correction, and resubmission support throughout the agreement period.
A Purpose-Built Match for MAHA ELEVATE
AHS already does this work for 50+ MSSP ACOs covering roughly 10% of the MSSP market. The capabilities CMS requires from MAHA ELEVATE awardees are exactly what our Pulse Platform delivers — adapted for the model's specific reporting needs.
A Partner CMS Already Knows
Building data infrastructure from scratch for a 3-year cooperative agreement is risky and expensive. We're already wired into CMS reporting pipelines — your application is stronger when reviewers see an experienced, certified registry partner attached to your proposal.
Established Track Record
50+ MSSP ACOs submit through our Pulse Platform every reporting cycle. 100% CMS submission success across eCQM, MIPS CQM, Medicare CQM, and Promoting Interoperability.
Ready Now
No greenfield build. Our infrastructure, security certifications, and CMS submission pipelines are operational. Your project can stand up data workflows in weeks, not months.
Custom Measure Builds
Because MAHA ELEVATE measures are co-designed with CMS post-award, you need a partner that can build new measures to spec — not just submit standard ones. That's our core competency.
HITRUST e1 + ONC Certified
Three consecutive HITRUST e1 certifications and ONC certified Health IT status (CHPL ID 15.04.04.3260.Puls.01.00.1.260331). CMS reviewers care about security maturity — we have it.
Letter of Support Ready
We're already providing data partnership support to an active MAHA ELEVATE Cohort 1 applicant. We can supply letters of support and partnership documentation for your application package.
Allowable Cost
CMS explicitly allows MAHA ELEVATE funds to cover data collection, reporting, and infrastructure costs. Our services are an eligible budget line item — funded by the grant, not by you.
MAHA ELEVATE Key Dates
Cohort 1 applications closed May 15, 2026. If you're considering MAHA ELEVATE, Cohort 2 is your window — and now is when serious planning starts.
Cohort 1 Application Window (Closed)
Letter of intent due April 10, full application due May 15, 2026. Up to 30 awards across both cohorts.
Cohort 1 Awards Announced
CMS announces initial cohort awardees. Real-world signal of what proposals win and how budgets are structured.
Cohort 1 Performance Period Begins
Awardees begin 3-year cooperative agreement performance. Data collection, intervention delivery, and CMS reporting starts.
Cohort 2 Application Cycle
Separate application cycle with new LOI and submission deadlines. Approximate timing — monitor CMS for official NOFO.
Plan Your Cohort 2 Application
Identify your intervention, line up clinical and academic partners, secure a data partner, and start documenting your existing program outcomes. Strong applications take 6–12 months to assemble well.
MAHA ELEVATE: Frequently Asked Questions
Common questions from organizations considering a MAHA ELEVATE application, sourced directly from the CMS NOFO and FAQ documents.
What is the MAHA ELEVATE Model?
MAHA ELEVATE (Make America Healthy Again: Enhancing Lifestyle and Evaluating Value-based Approaches Through Evidence) is a CMS Innovation Center cooperative agreement program providing approximately $100 million in funding for up to 30 organizations across two cohorts.
Each award averages $3.3 million over a 3-year performance period to deliver evidence-based lifestyle and functional medicine interventions to Original Medicare beneficiaries. The model tests whether whole-person care approaches not currently covered by Medicare can improve health outcomes and reduce costs.
Who is eligible to apply for MAHA ELEVATE?
Eligible applicants include private practices, health systems, accountable care organizations (ACOs), academic organizations, community-based groups, senior living communities, and state and local governments.
Applicants must demonstrate experience delivering the proposed interventions, provide evidence the interventions are safe and effective for the target population (supported by peer-reviewed literature), and show the ability to collect and report data accurately and in a timely manner with appropriate beneficiary safeguards.
What data does CMS require MAHA ELEVATE awardees to report?
CMS requires regular beneficiary-level reporting across four main categories:
Clinical outcomes — biometrics and health status indicators relevant to the intervention (BMI, A1c, blood pressure, lipids, depression screening scores, etc.). Service utilization and process measures — encounter-level tracking of intervention delivery and beneficiary engagement. Enrollment numbers — recruitment against CMS-set targets, with a significant portion of funding tied to meeting these targets. Cost impact data — healthcare utilization and cost tracking alongside clinical outcomes.
Awardees must also implement a randomized study design or include a valid comparison group. The specific measure set is co-designed with CMS after award, not fixed in the NOFO.
Can MAHA ELEVATE funds be used to pay for data partner services?
Yes. CMS explicitly allows MAHA ELEVATE cooperative agreement funds to cover administrative costs, data collection and reporting, and infrastructure as appropriate. Data partner services like those provided by ACO Health Solutions are an allowable budget line item.
Funds cannot be used to provide services already covered by Original Medicare (those should be paid through normal Medicare billing), or to cover the direct cost of food (though nutrition education and counseling are allowable).
Do I need a CMS Qualified Registry to apply for MAHA ELEVATE?
A Qualified Registry is not strictly required, but CMS evaluates applicants on data collection capability. Partnering with a CMS Qualified Registry significantly strengthens applications because it demonstrates immediate readiness to meet CMS reporting requirements without building data infrastructure from scratch.
ACO Health Solutions is both a CMS Qualified Registry and a Clinical Data Registry, with HITRUST e1 certified infrastructure and an established track record of beneficiary-level CMS reporting for 50+ MSSP ACOs.
When is the MAHA ELEVATE Cohort 2 application due?
CMS has not yet released the official Cohort 2 Notice of Funding Opportunity (NOFO). Based on the announced timeline, Cohort 2 applications are expected in 2027, with a separate Letter of Intent and full application cycle.
Organizations considering Cohort 2 should begin planning now. Competitive applications typically require 6 to 12 months of preparation, including documenting prior program outcomes, lining up clinical and data partners, and developing the evaluation design.
What makes a competitive MAHA ELEVATE application?
Competitive applications demonstrate prior experience delivering the proposed intervention, scientific evidence supporting efficacy in the target population, a rigorous evaluation design with randomization or valid comparison group, recruitment capacity for typically 1,000+ Medicare FFS beneficiaries, and proven data collection infrastructure with HIPAA-compliant safeguards.
Every proposal must include a nutrition or physical activity component. Three of the 30 awards are reserved for programs focused on dementia and cognitive decline.
How long is the MAHA ELEVATE performance period?
MAHA ELEVATE cooperative agreements have a 3-year performance period. Cohort 1 begins September 1, 2026. Cohort 2 is expected to begin in 2027.
Awardees deliver interventions, collect data, and submit reports to CMS throughout the entire 3-year period. The model is designed so successful interventions could inform future Medicare coverage decisions, similar to the pathway established by the Diabetes Prevention Program.
What is the difference between MAHA ELEVATE and the ACCESS Model?
MAHA ELEVATE is a cooperative agreement (grant) that funds evidence-generation for whole-person lifestyle and functional medicine interventions through rigorous evaluation. The ACCESS Model is an outcome-aligned payment program that reimburses providers for technology-enabled chronic care services.
ACCESS uses claims-based payments tied to outcomes; MAHA ELEVATE uses up-front cooperative agreement funding tied to enrollment and reporting milestones. The two models can complement each other for organizations serving Medicare FFS populations with chronic disease.
What clinical conditions can MAHA ELEVATE interventions address?
Awardees may target one or more chronic conditions with evidence-based functional or lifestyle medicine interventions. Common focus areas include diabetes, hypertension, heart failure, obesity, chronic kidney disease, musculoskeletal pain, and behavioral health conditions like depression and anxiety.
All proposals must include a nutrition or physical activity component. Other allowable focus areas include stress management, sleep, avoidance of harmful substances, and social connection. Three awards are reserved for programs focused on dementia and cognitive decline.
Considering MAHA ELEVATE?
Whether you're scoping a Cohort 2 application or already drafting your proposal, we can help you think through the data requirements, scope the partnership, and provide a letter of support. No commitment required for an initial conversation.