MAHA ELEVATE Model: Strategic Guide for Healthcare Organizations

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For the first time, CMS is funding lifestyle interventions that traditional Medicare has never covered. In this article, we'll go over what the model funds, who qualifies, and what it takes to compete for one of 30 available awards.

What is MAHA ELEVATE?

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MAHA ELEVATE is a first-of-its-kind initiative to test evidence-based approaches that treat the root causes of health problems before they turn into emergencies. It stands for Make America Healthy Again: Enhancing Lifestyle and Evaluating Value-based Approaches Through Evidence.

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This model commits $100 million over three years to fund up to 30 organizations delivering chronic disease prevention programs for Original Medicare beneficiaries. With 45% of Medicare beneficiaries managing four or more chronic conditions that drive roughly 90% of healthcare spending, this model tackles an urgent crisis through prevention rather than reactive treatment.

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Understanding CMMI MAHA Elevate's Strategic Opportunity

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MAHA ELEVATE represents CMS's paradigm shift from paying for sick care to investing in preventive interventions that address the root causes of chronic disease in Medicare populations.

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First CMMI Innovation Model Focused on Lifestyle Medicine

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MAHA ELEVATE marks the CMS Innovation Center's unprecedented investment in whole-person care addressing root causes rather than symptoms alone, funding evidence-based nutrition, physical activity, stress reduction, and other lifestyle strategies not currently covered by Medicare.

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September 2026 launch with Notice of Funding Opportunity in early 2026

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The Notice of Funding Opportunity will be published in early 2026, creating a narrow application window before the September 1, 2026 program launch, requiring organizations interested in the first cohort to begin preparation immediately given limited time between award notification and go-live.

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Focus on interventions not currently covered by Original Medicare

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MAHA ELEVATE specifically targets services Original Medicare doesn't reimburse for, including comprehensive nutrition counseling programs, structured physical activity interventions, stress management protocols, and social connection initiatives. This creates an evidence-generation opportunity potentially reshaping Medicare benefits for all 65 million beneficiaries.

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Strategic Implications for Healthcare Organizations

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Participating organizations gain more than federal funding by helping shape Medicare's future direction while building competitive advantages in value-based care markets through evidence generation and policy influence.

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Potential pathway to future Medicare coverage for lifestyle interventions

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CMS explicitly intends to use MAHA ELEVATE to generate evidence for potential new Medicare benefits. Interventions proven effective can become candidates for permanent Medicare coverage or inclusion in future value-based models. This gives forward-looking organizations compelling incentive to influence policy affecting all Medicare beneficiaries.

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Evidence generation opportunity for value-based care approaches

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The model rigorously tracks clinical outcomes, utilization, and spending for each intervention, creating a national dataset on lifestyle medicine ROI that participants leverage when negotiating value-based contracts and shared savings arrangements with CMS-validated data.

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Alignment with broader CMMI innovation initiatives

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MAHA ELEVATE fits within CMS's coordinated strategy rewarding prevention alongside the ACCESS model for tech-enabled chronic care management and various ACO programs, creating synergies for organizations participating in multiple CMMI models.

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MAHA Elevate Model Requirements and Funding Structure

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Understanding eligibility criteria, intervention requirements, and funding parameters is essential for organizations evaluating whether MAHA ELEVATE aligns with their capabilities and strategic goals.

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Eligible Organizations and Partnership Models

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CMS has structured eligibility broadly to encourage diverse applicants while emphasizing the importance of partnerships for comprehensive service delivery and data collection capabilities.

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Health systems and hospitals with lifestyle medicine capabilities

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Health systems and hospitals with integrative medicine programs, cardiac rehabilitation, or wellness departments have natural advantages. Academic medical centers and clinics specializing in preventive, functional, or integrative medicine are explicitly encouraged to apply.

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ACOs and Medicare Advantage plans with wellness programs

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Accountable Care Organizations experienced in care coordination represent ideal candidates, with private medical practices including primary care groups able to lead proposals, while Medicare Advantage (MA) plans can collaborate with providers bringing care management experience and data capabilities.

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Community-based organizations and digital health platforms

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CMS welcomes applications from Federally Qualified Health Centers, rural health clinics, senior living communities, and state or local government entities. Digital health companies can partner with healthcare organizations having necessary data infrastructure and Medicare relationships.

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Partnership opportunities for service delivery and data collection

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Most successful proposals will combine strengths of multiple partners such as hospitals partnering with digital health companies and community fitness programs for comprehensive delivery, with CMS permitting multiple distinct proposals from one entity targeting different interventions.

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Intervention Requirements and Evidence Standards

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CMS has established specific design and evidence criteria that all funded interventions must meet to ensure quality, effectiveness, and alignment with lifestyle medicine principles.

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Must include nutrition or physical activity components

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Every MAHA ELEVATE intervention must include either nutrition components, physical activity components, or both as mandatory foundational elements, signaling that changing eating and activity habits proves central to chronic disease prevention in seniors.

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Evidence-based approaches with peer-reviewed literature support

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CMS requires applicants document peer-reviewed literature supporting intervention safety, efficacy, and cost-effectiveness for target populations, with proposals referencing clinical studies demonstrating lifestyle approaches improve relevant health outcomes in older adults and evidence of prior success in applicant's own population highly encouraged.

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Focus on six domains of lifestyle medicine

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CMS outlined six core domains proposals may address including: 

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1. Healthy nutrition
2. Regular physical activity
3. Restorative sleep
4. Stress management
5. Avoidance of harmful substances
6. Social connection

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Programs can incorporate multiple domains though at least one key pillar must be present.

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Three reserved slots for dementia-focused interventions

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Three of the 30 awards are reserved specifically for interventions addressing dementia and cognitive decline in older adults. CMS shows particular interest in lifestyle strategies supporting brain health like memory fitness classes and social engagement programs.

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Funding Structure and Allowable Costs

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Understanding what the federal funding covers and excludes is critical for accurate budgeting, proposal development, and ensuring compliance with cooperative agreement requirements.

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Approximately $3 million per organization over three years

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Funding averages roughly $3 million per organization spread across three years though exact amounts may vary based on proposal scope. CMS released funds in two rounds for 2026 and 2027 cohorts alongside hands-on oversight.

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Service delivery, administration, and data collection costs covered

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Allowable costs include staffing for: 

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• Health coaches
• Dietitians
• Exercise physiologists
• Behavioral therapists
• Patient educational materials
• Program infrastructure
• Administrative expenses
• Data collection efforts

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Food itself specifically excluded as unallowable cost

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While organizations can provide nutrition education and cooking classes, federal funding cannot purchase food or groceries for beneficiaries, requiring organizations to develop creative partnerships with food banks or find alternative funding if meal provision is central to program design.

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Data collection and reporting requirements for outcomes

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CMS requires regular reporting of enrollment numbers, service utilization, clinical outcomes including biometric measures and health status indicators, and cost impacts, with organizations needing to deliver robust data while maintaining HIPAA compliance and patient privacy safeguards.

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Strategic Use Cases for Healthcare Organizations

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Different types of healthcare organizations can leverage MAHA ELEVATE in strategic ways aligned with their existing business models and value-based care objectives.

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ACO Integration and Shared Savings Enhancement

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ACOs represent ideal MAHA ELEVATE participants. This is due to their existing focus on prevention, care coordination, and financial accountability for Medicare populations with aligned incentives for reducing costs through upstream interventions.

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Leveraging existing shared savings for preventive interventions

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In 2024, 476 MSSP ACOs serving 10 million beneficiaries saved Medicare approximately $2.5 billion earning $4.1 billion in performance payments, with MAHA ELEVATE offering federal funding to amplify preventive efforts without tapping earned savings.

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Supporting MSSP and ACO REACH quality measures

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Lifestyle interventions directly support quality measures ACOs already track.

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This includes diabetes control, hypertension management, depression screening, and preventive care completion. Improving these metrics through lifestyle programs simultaneously meets MAHA ELEVATE requirements and enhances ACO performance.

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Provider Network and Care Management Integration

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Healthcare providers can integrate lifestyle medicine into care management for high-risk Medicare patients, creating comprehensive care models that improve outcomes while reducing costs through behavioral interventions.

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Expanding primary care capabilities with lifestyle medicine

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Lifestyle Medical, a primary care practice centered on lifestyle medicine, reports 30-40% lower healthcare costs per patient compared to typical Medicare patients, with these dramatic savings coming from fewer emergency visits, hospitalizations, and expensive procedures demonstrating the financial potential.

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Care coordination for high-risk Medicare beneficiaries

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Primary care networks can target patients managing four or more chronic conditions. For these members, care plans can expand to include nutritional counseling, stress reduction workshops, and group exercise. Addressing behavioral factors alongside medical management improves chronic disease control. It also reduces the risk of costly complications downstream.

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Integration with existing chronic care management programs

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MAHA ELEVATE provides resources to enhance existing Chronic Care Management programs with lifestyle interventions. Care managers can refer appropriate beneficiaries to MAHA ELEVATE services directly. Telephonic support and care coordination continue alongside those referrals. The result is a more comprehensive support structure for high-risk members.

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Application Strategy and Competitive Positioning

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Developing a competitive MAHA ELEVATE application requires careful assessment of organizational capabilities, evidence-based intervention design, and detailed implementation planning.

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Organizational Readiness Assessment

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Conducting honest capability assessments helps organizations determine whether to pursue MAHA ELEVATE and identify areas requiring strengthening before application submission.

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Existing lifestyle medicine or wellness program capabilities

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Organizations should inventory existing programs including diabetes education classes, nutrition counseling, stress management workshops, or senior exercise programs, with organizations having board-certified lifestyle medicine practitioners, health coaches, or behavioral health specialists on staff possessing implementation advantages.

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Data collection and reporting infrastructure requirements

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MAHA ELEVATE demands detailed participant tracking and timely CMS reporting This requires organizations to have experience with data analytics, IT systems capturing outcomes through EHRs or patient registries, and assigned personnel responsible for data management or Health IT partnerships with capable entities such as Invene.

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Partnership development for comprehensive service delivery

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Organizations should identify where they need collaborators for comprehensive lifestyle intervention delivery, with physician groups lacking exercise training expertise potentially partnering with fitness centers and organizations with clinical staff but limited community reach considering senior centers or YMCAs.

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Intervention Design and Evidence Documentation

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Developing evidence-based interventions with clear target populations and measurable outcomes forms the foundation of competitive applications that demonstrate both scientific rigor and practical feasibility.

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Target chronic condition selection and population identification

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Successful proposals focus on specific high-burden issues like reducing cardiovascular risk in Medicare patients with hypertension and obesity, using organizational data to identify unmet needs or coverage gaps while tailoring interventions to well-characterized patient cohorts.

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Evidence base development and literature review requirements

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Organizations must build compelling cases by conducting literature reviews and citing peer-reviewed research for each program component, including data from past implementations demonstrating proof of concept with measurable outcomes alongside external evidence.

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Outcome measurement and evaluation framework design

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Define success through 3-5 primary outcomes relating to both quality and cost. This includes hemoglobin A1c changes, depression score improvements, hospitalization rates, and total cost of care per beneficiary, with clear collection methods outlined for each measure.

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Implementation Planning and Resource Requirements

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Detailed implementation planning demonstrates organizational capacity to execute the model successfully within the three-year timeframe while meeting all federal requirements.

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Three-year program design and milestone development

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Break the three-year period into phases with realistic timelines and clear milestones. 

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• Year 1 - Focus on recruitment and program refinement
• Year 2 - Focus on scaling and optimization
• Year 3 - Focus on sustainability planning while working backwards from September 1, 2026 start date

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Staffing and infrastructure investment planning

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Project resource requirements should include personnel, equipment, supplies, and IT. Identify full-time equivalents needed for each role and duration. But also account for recruitment time if hiring lifestyle coaches or data analysts and consideration of infrastructure investments.

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HIPAA compliance and beneficiary safeguard protocols

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Proposals should detail informed consent processes for participants receiving services outside standard Medicare coverage. Privacy protections must include secure, encrypted data systems and de-identified reporting. Patient safety measures for home visits and group activities should also be clearly described.

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Regulatory Compliance and CMS Alignment

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Meeting regulatory requirements and aligning with CMS objectives is essential for successful participation and maintaining good standing throughout the three-year cooperative agreement period.

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Original Medicare Integration and Beneficiary Rights

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Participation in MAHA ELEVATE must be seamless for patients without replacing or restricting Medicare benefits, with beneficiaries continuing to see any Medicare provider and receive any covered service as usual while model services are added voluntarily at no cost and opting in or out cannot affect normal Medicare coverage.

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Data Collection and Reporting Requirements for CMS

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CMS expects extensive data for monitoring and evaluation including patient demographics, service utilization logs, clinical outcome measures at specified intervals, and cost data. This requires organizations to set up systems from day one capturing all relevant metrics in structured formats with assigned project managers responsible for periodic reporting.

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Evidence Generation for Future Coverage Determinations

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MAHA ELEVATE's core purpose involves generating evidence informing Medicare coverage decisions. This requires organizations to structure evaluations answering key CMS questions about health outcome improvements, total cost of care impacts, and effectiveness across subgroups while calculating per-member per-year cost savings.

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Strategic Decision Framework for MAHA Elevate Participation

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Making informed decisions about MAHA ELEVATE participation requires thorough capability assessments, competitive analysis, and detailed timeline planning to ensure organizational readiness.

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Organizational Capability Assessment and Gap Analysis

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Thorough capability assessments inform strategic decisions about pursuing MAHA ELEVATE and guide application development by identifying strengths to leverage and gaps to address.

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Current wellness and lifestyle medicine program evaluation

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Assemble stakeholders reviewing current programs, with robust programs producing outcomes providing head starts for proposals while organizations lacking programs should identify gaps and assess whether they can realistically fill them through hiring or partnerships before September 2026 launch.

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Data analytics and reporting infrastructure review

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Examine data analytics infrastructure critically to determine if current systems can track clinical and cost outcomes, with organizations lacking central data warehouses or analytics teams needing to address gaps by bringing in partner organizations or investing in new systems.

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Partnership development opportunities and requirements

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Identify natural partners in your market including health systems, community organizations, universities, digital health companies, and payer organizations. Partnerships strengthen applications since few organizations possess all necessary capabilities independently.

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Competitive Analysis and Market Positioning

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Understanding the competitive landscape and developing clear differentiation strategies increases the likelihood of securing limited funding slots among numerous qualified applicants nationwide.

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Expected applicant pool and competitive landscape

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CMS will select only 30 awardees from potentially many applicants nationally including large academic medical centers, integrated delivery systems with wellness divisions, specialized lifestyle medicine clinics, and tech-enabled primary care startups, requiring clear identification of distinctive organizational strengths.

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Differentiation strategies for successful applications

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Differentiation might stem from target populations, delivery models, partnership structures, or evidence bases, with organizations needing to emphasize unique capabilities demonstrating both rigor and real-world feasibility while highlighting existing outcomes alongside team expertise.

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Long-term strategic value beyond three-year funding period

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Articulate long-term strategic value for both CMS and your organization since CMS favors applications with clear sustainability and scaling plans, demonstrating how programs could integrate into regular ACO operations after funding ends or contract with MA plans.

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Implementation Timeline and Resource Planning

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Detailed timeline and resource planning ensures organizations can realistically execute proposed interventions while meeting all CMS requirements within the compressed implementation timeframe.

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Notice of Funding Opportunity preparation and application development

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When the Notice of Funding Opportunity (NOFO) drops in early 2026, organizations having completed homework will have major advantages, with successful applicants building teams, developing partnerships, and drafting key sections now to refine once NOFO provides specific requirements rather than starting from scratch.

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Program launch readiness for September 2026 start date

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Between award notification and September 2026, organizations must hire staff, finalize contracts, set up data systems, develop intervention materials, and recruit initial participants, with this tight timeline making advance planning essential and requiring identification of potential long lead-time items now.

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Success metrics and performance measurement framework

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Define short-term and long-term success clearly with ambitious but achievable targets, planning activities achieving and measuring those outcomes while allowing mid-course corrections through quarterly progress reviews to keep teams focused on delivering measurable results.

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Getting Started with MAHA Elevate Application Preparation

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Organizations serious about competing for MAHA ELEVATE funding should begin preparation activities immediately to maximize competitive positioning when the NOFO releases in early 2026.

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NOFO Preparation and Application Strategy Development

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Monitor CMS communications closely by subscribing to MAHA ELEVATE email updates, with organizations needing to study the NOFO thoroughly once published to create compliance checklists. This ensures proposals address every requirement while developing application project plans with internal deadlines well ahead of CMS deadlines.

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Partnership Development for Comprehensive Service Delivery

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Formalize partnerships strengthening MAHA ELEVATE initiatives through Memoranda of Understanding outlining each party's roles and contributions, with clear partnership agreements demonstrating all key components are covered by capable entities while setting expectations that avoid later confusion.

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Evidence Base Development and Literature Review Planning

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Plan thorough literature reviews gathering pertinent research supporting intervention components, delegating sub-topics to team members researching nutrition interventions, physical activity programs, and stress reduction in chronic disease while creating organized repositories noting key findings and prioritizing U.S.-based recent data.

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Final Takeaways

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Organizations most likely to succeed possess existing wellness capabilities, robust data infrastructure, and strategic partnerships enabling comprehensive service delivery. Beyond three-year funding, MAHA Elevate participants position themselves as innovation leaders in value-based care. This helps prove that investing in health rather than just treating disease can work at scale while potentially securing long-term reimbursement for lifestyle medicine services.

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Frequently Asked Questions

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How can Invene help organizations meet MAHA Elevate's data requirements?

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Many organizations have the clinical capabilities to deliver lifestyle interventions but lack the data infrastructure CMS requires. Invene helps healthcare organizations build the technical foundation needed to participate, including EHR integration, claims data pipelines, patient-reported outcome collection systems, and analytics platforms that generate CMS-compliant reports. For organizations pursuing MAHA Elevate, Invene can assess current data gaps and build scalable infrastructure that supports both program delivery and long-term sustainability.

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What types of organizations are eligible to apply for MAHA Elevate funding?

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Health systems, hospitals, ACOs, private medical practices, Federally Qualified Health Centers, rural health clinics, community-based organizations, senior living communities, and state or local government entities can all apply. Most successful applicants will involve partnerships between clinical organizations serving Medicare beneficiaries and entities delivering lifestyle medicine interventions while meeting rigorous data collection requirements.

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Can MAHA Elevate funding be used to purchase food for nutrition interventions?

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No, food purchases are specifically excluded as allowable costs. Organizations can provide nutrition education, cooking classes, and meal planning support, but federal funding cannot buy groceries or prepared meals for beneficiaries. Organizations must develop creative partnerships with food banks or community organizations, or seek supplemental funding if meal provision is central to intervention design.

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How does MAHA Elevate differ from Medicare Advantage supplemental benefits?

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MAHA Elevate targets Original Medicare beneficiaries specifically and focuses on interventions not currently covered by traditional Medicare. Evidence generated through MAHA Elevate could eventually inform both Original Medicare coverage decisions and expanded MA supplemental benefit options for all plans.

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What happens to programs after the three-year funding period ends?

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Organizations need sustainability planning from the beginning. Successful interventions might transition to other funding sources like ACO shared savings, MA supplemental benefits, or future Medicare coverage if CMS makes positive coverage determinations based on MAHA Elevate evidence.

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What data infrastructure is required to participate in MAHA Elevate?

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Participants must track clinical outcomes, healthcare utilization, costs, and beneficiary satisfaction across intervention periods. This typically requires electronic health record integration, claims data access, patient-reported outcome collection systems, and data analytics capabilities generating required CMS reports.

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