Written by Karen Ostrowski, Director, Health Policy and Regulatory Affairs (Consultant), Civitas
Overview of MAHA ELEVATE
CMS’s MAHA ELEVATE Model, announced through the Center for Medicare and Medicaid Innovation (CMMI), is a state-centered transformation model focused on prevention, chronic disease reduction, and long-term cost sustainability across Medicare and Medicaid. While CMS has not released every operational detail, the framing signals a structural shift in state-led reform: ELEVATE asks states to align incentives across programs and link system performance to measurable population-level outcomes.
Unlike episode-based demonstrations or condition-specific pilots, such as bundled payment initiatives tied to a single procedure or disease category, ELEVATE is designed to operate at a broader system level. States are expected to propose reform strategies that integrate physical health, behavioral health, and prevention efforts, with accountability tied to longer-term quality and cost trajectories. CMS has increasingly signaled concern that short-term utilization management does little to alter chronic disease trends or cost growth. ELEVATE reflects that posture. It implies earlier identification of risk, cross-program data visibility, and sustained measurement over time. Most delivery systems do not operate that infrastructure independently.
Details around funding structure, attribution mechanics, and required reporting are still emerging. The model centers on multi-payer alignment, longitudinal accountability, and state-led governance. CMS has emphasized flexibility in state design paired with outcome guardrails, meaning operational decisions may be locally driven, but performance expectations will not be.
What MAHA ELEVATE Proposes
CMS has allocated approximately $100 million in total funding for the model, structured as multi-year cooperative agreements. The agency anticipates supporting up to roughly 30 awardees across two cohorts. CMS plans to release a Notice of Funding Opportunity (NOFO) in early 2026 for the first cohort, with the voluntary model scheduled to launch on September 1, 2026. A second cohort is anticipated to begin in 2027. Awards support a three-year implementation period, combining upfront infrastructure and planning support with performance-based funding tied to measurable outcomes.
ELEVATE is intended to support, not replace, the care Medicare beneficiaries already receive. The model focuses on prevention-oriented and lifestyle-based interventions that operate alongside traditional clinical services. CMS has emphasized that the goal is to generate new evidence on cost and quality, evaluating whether sustained, upstream interventions can improve health outcomes and ultimately reduce spending in Original Medicare.
The funding structure reinforces the model’s emphasis on longitudinal accountability rather than short-term utilization changes. States may receive initial support to build implementation capacity – including data infrastructure, governance alignment, and performance measurement systems – followed by ongoing payments contingent on achieving agreed-upon quality and cost targets.
ELEVATE encourages alignment across payers, particularly between Medicaid and Medicare. While CMS has not yet released full operational specifications, the model proposes shared accountability for defined population outcomes rather than condition-specific payment adjustments. That likely includes standardized quality measures, cost trend targets, and benchmarks tied to prevention and chronic disease management.
States participating in the model will likely need to articulate:
- target populations and attribution methodologies;
- defined outcome measures and cost benchmarks;
- governance structures to support multi-payer coordination;
- and implementation plans for performance monitoring and reporting.
Why This Matters for Civitas
The MAHA ELEVATE Model assumes states can see across care settings and programs in a consistent, reliable way. CMS has not explicitly referenced data exchange entities or networks such as HIEs, HDUs, or other trusted intermediaries, but the model presumes the existence of:
- longitudinal beneficiary tracking across Medicaid and Medicare;
- timely clinical data from multiple provider types;
- cross-setting behavioral health visibility;
- performance measurement that spans years, not months;
- attribution logic that works across payers;
- and governance structures capable of aligning diverse stakeholders.
Most individual provider organizations cannot accomplish this independently, nor can many state agencies. Where this level of integration exists today, it is typically because shared data infrastructure has already been built.
The model also increases the importance of neutral convening authority. Multi-payer reform introduces regulatory variability, competitive sensitivities, and differing reporting obligations. In markets with established, community-rooted data networks, those tensions are often manageable. In markets without them, states may find that governance becomes the bottleneck rather than payment design. That dynamic is familiar territory for Civitas members, many of whom already serve as neutral conveners in multi-stakeholder environments.
Implications for Members
ELEVATE shifts emphasis from discrete services to sustained, measurable improvement over time. That shift carries both technical and governance-related implications. If states are accountable for prevention outcomes across Medicare and Medicaid, they will need consistent data visibility across settings, programs, and years.
Several implications stand out:
- Attribution and identity matching become central. Cross-program accountability requires reliable beneficiary matching and longitudinal tracking. Members that already support multi-payer identity management will be well positioned.
- Earlier risk identification depends on broader data feeds. Prevention-oriented measurement assumes timely primary care data, specialist input, behavioral health visibility, and, in some cases, community-based information. Fragmented data will directly affect performance benchmarks.
- Measurement integrity will have financial consequences. If outcome thresholds are tied to funding, incomplete lab feeds, missing medication histories, or inconsistent reporting will not just create analytics gaps — they may affect payment.
- Multi-payer alignment increases governance complexity. Medicare Advantage participation, Medicaid managed care variability, and commercial plan engagement will shape how feasible cross-program reporting becomes. In many regions, Civitas members are the only entities already aggregating across these boundaries.
- Infrastructure unevenness will impact adoption speed. States with mature HIE, HDU, or APCD ecosystems may be able to operationalize ELEVATE more quickly. In other markets, implementation timelines may hinge on new investment in shared exchange capacity.
ELEVATE builds on infrastructure many regions already have. In places where that foundation is thin, pressure points will surface quickly and states may need to rely more heavily on shared data networks.
Opportunities for Civitas
ELEVATE creates several openings for engagement. As noted, CMS has not yet finalized the specific data validation standards, reporting pathways, or infrastructure expectations embedded in the model. That leaves room for informed guidance based on member experience. Civitas can help shape CMS’s approach to attribution integrity, cross-program reporting, and longitudinal data validation before requirements are finalized.
The model also strengthens the economic argument for shared infrastructure. If state revenue or provider performance is tied to measurable prevention outcomes, data completeness and quality become directly linkedto financial results. That alignment makes the value of shared infrastructure easier to demonstrate.
Another area to watch is cross-model alignment. States participating in other CMMI initiatives may seek to layer ELEVATE on top of existing transformation efforts. Civitas is positioned to help reduce duplicative reporting requirements and encourage harmonized data strategies rather than fragmented ones.
Finally, ELEVATE may draw stronger Medicaid agency engagement in shared infrastructure conversations. If states are accountable for longitudinal outcomes, they may need to rely more heavily on entities that already manage cross-sector exchange.
Challenges and Risks
ELEVATE’s structure creates opportunity, but several variables could affect how smoothly it unfolds. Much of the operational detail is still forthcoming, and the prevention and multi-payer structure will play out differently across states. A few areas to watch closely:
- Measurement methodology. CMS has not fully detailed how prevention gains will be defined or benchmarked. If outcome thresholds are aggressive — or risk adjustment does not adequately account for patient complexity — certain regions, particularly rural or high-burden communities, could face disadvantages.
- Attribution mechanics. Cross-program accountability depends on clear beneficiary attribution rules. Medicare Advantage penetration and Medicaid managed care variability could complicate alignment if methodologies are not transparent and consistent.
- Commercial payer participation. Multi-payer alignment is conceptually appealing, but commercial engagement is not guaranteed. Uneven participation could create parallel reporting structures rather than true alignment.
- Infrastructure unevenness. States with mature HIE, HDU, or APCD ecosystems may be able to operationalize ELEVATE more quickly. In other regions, gaps in exchange capacity, identity matching, or data completeness may slow implementation.
- Governance and consent variability. Differences in state privacy laws, consent requirements, and data-sharing authorities across Medicare and Medicaid programs may introduce friction if not addressed early.
None of these challenges are new to Civitas members. ELEVATE ties performance and funding more directly to measurable outcomes, which may make these long-standing issues more visible and more consequential during implementation.
Considerations for Engagement
ELEVATE’s prevention focus and multi-year structure align with Civitas’s broader emphasis on sustained accountability and durable data governance. Unlike short-term pilots, the model tests whether longitudinal measurement and cross-program alignment can impact Medicare spending over time. That framing intersects directly with the infrastructure and governance questions Civitas members navigate every day.
As the model develops, Civitas will support members and partners by:
- monitoring the NOFO and subsequent guidance for attribution, measurement, and reporting requirements;
- identifying where existing member infrastructure aligns with ELEVATE’s prevention and accountability goals;
- convening targeted discussions on cross-program data alignment, particularly where Medicare and Medicaid measurement intersect;
- engaging CMS on practical considerations around data validation, risk adjustment, and governance assumptions embedded in the model;
- and tracking how ELEVATE interacts with state Medicaid transformation efforts.
ELEVATE will evolve as CMS releases additional detail. Early engagement will help ensure that infrastructure realities are part of that conversation rather than an afterthought.
