The Make America Healthy Again: Enhancing Lifestyle and Evaluating Value‑Based Approaches Through Evidence (“MAHA ELEVATE”) Model is a new federal initiative focused on expanding access to preventive and lifestyle-based care options within Original Medicare.
What You Need to Know:
- Holistic Health Interventions. The MAHA ELEVATE Model aims to reduce the progression of chronic disease by funding evidence-based functional and lifestyle medicine approaches, such as nutritional support and physical activity, which Original Medicare does not currently cover.
- Cooperative Agreement Funding. Unlike traditional fee-for-service or shared savings models, this initiative will be financed through cooperative agreements totaling approximately $100 million, with a Notice of Funding Opportunity (NOFO) expected in early 2026 and a model launch date of September 1, 2026.
- Diverse Participation Opportunities. Eligible applicants include private practices, health systems, and accountable care organizations (ACOs), and the model offers specific pathways for organizations to provide “Food as Medicine” benefits and dementia-related interventions alongside conventional medical care.
Introduction
The prevalence of chronic disease in the United States remains a key focus for the Centers for Medicare & Medicaid Services (CMS). Traditional fee-for-service models are not moving the needle fast enough, and CMS believes that coverage of services and interventions not currently covered by Medicare will help to address the problem.
The MAHA ELEVATE Model is a newly announced initiative from the CMS Innovation Center (CMMI) that aims to transform preventive care and chronic disease management within Original Medicare. As a model focusing on holistic, functional, and lifestyle medicine approaches, MAHA ELEVATE represents an effort to test interventions currently not covered under traditional Medicare and gather evidence on the impact of these interventions on cost, quality, and patient outcomes. Patients will be encouraged to take ownership of their health through lifestyle changes. Novel approaches that include nutrition and physical activity will be utilized to support behavior changes that can improve or slow down disease progression, as well as address chronic conditions that resist treatment by traditional medicine. The model is positioned as a voluntary program that could ultimately provide evidence of effectiveness for services like nutrition, physical activity, and other lifestyle-focused interventions that support conventional medical care. The model will differ from other CMMI initiatives in that it will use a cooperative agreement to finance the alternative services, rather than using contingent shared savings or claims-based reimbursement.
Interested providers should be on the lookout for CMS’s NOFO in early 2026, which we expect will contain application information to participate in the MAHA ELEVATE Model. The model launch date is set as September 1, 2026.
Overview
The MAHA ELEVATE Model will provide approximately $100 million in funding for up to three-year cooperative agreements that propose evidence-based interventions designed to slow or prevent chronic disease in Medicare beneficiaries. These interventions must integrate functional or lifestyle medicine strategies, such as nutritional support, physical activity programs, stress management, and other wellness-focused activities, that are not currently covered by Original Medicare. Cooperative agreements will be awarded to organizations with prior experience integrating holistic measures and that have scientifically documented improvements in health. All proposals must include nutrition or physical activity in their design. Three awards have been reserved for dementia-related intervention proposals. CMS plans to release a NOFO in early 2026 for the first cohort. The second cohort will begin in 2027.
Eligible MAHA ELEVATE applicants will include:
- Private medical practices
- Health systems and ACOs
- Academic organizations
- Functional, lifestyle, preventative, and integrative medicine centers
- Federally Qualified Health Centers and Rural Health Centers
- Community-based organizations
- State or local governments
- Indian Health Service / Tribal Services / Urban Indian Programs
- Senior living communities
This model is part of CMMI’s broader Make America Healthy Again agenda, which emphasizes evidence-based prevention, patient empowerment, and choice in care delivery. This model aligns with a larger shift toward incorporating preventive and health-promoting services with the goal of reducing chronic illness progression and federal spending while improving quality of care.
MAHA ELEVATE Services
“Food as Medicine” Nutritional Counseling
MAHA ELEVATE provides a new platform for organizations providing “Food as Medicine” benefits to enter Original Medicare. However, the model will include firm limits on what funds can be used for. Specifically, while nutrition is a core feature of the model, CMS has expressly listed food itself as an unallowable cost. Even with this limitation, organizations providing Food as Medicine could leverage MAHA ELEVATE to provide the ancillary services supporting food benefits, such as culinary medicine, food security screenings, meal planning, nutrition coaching and education, food delivery, administration and data collection and reporting costs, and coordination with public food benefits (e.g., Supplemental Nutritional Assistance Program and the Special Supplemental Nutrition Program for Women, Infants, and Children).
ACOs and academic medical centers would be natural partners for Food as Medicine companies interested in participating. Similarly, health professionals who regularly provide nutritional counseling could explore using MAHA ELEVATE to overcome long-standing Medicare coverage hurdles. This could include, for example, loosening “incident-to” billing restrictions for nutritional counseling and expanding coverage to include chronic conditions beyond diabetes and chronic kidney disease (e.g., cardiovascular disease, obesity, and malnutrition).
Dementia Services and Integration with the CMS GUIDE MODEL
As previously noted, three participation awards will be reserved for proposals with interventions that address dementia.
“Participating Organizations” and “Partner Organizations” under CMS’s Guiding an Improved Dementia Experience (GUIDE) Model may be well positioned to also be participants in the MAHA ELEVATE Model, as they may be able to use the MAHA ELEVATE funding in two different ways to support their attributed populations. First, GUIDE MODEL Participating Organizations may be able to create new partnerships with providers offering functional or lifestyle medicine services that do not fit squarely within Medicare billable services or one of the nine GUIDE Care Delivery Services but that serve to prevent or slow the progression of neurological decline. Second, GUIDE MODEL Participating Organizations may use MAHA ELEVATE funding as a secondary funding stream to pay for functional or lifestyle medicine services already offered by an existing Partner Organization but not reimbursable by the GUIDE Model. In each scenario, the GUIDE Model Participating Organization can likely benefit from the additional data collection and reporting required under the MAHA ELEVATE Model to further inform its care planning and care coordination for its GUIDE Model-attributed beneficiaries.
Alternatively, senior living communities that otherwise can only play a limited role in the GUIDE Model may have an opportunity to be the main funding recipient under the MAHA ELEVATE Model. Original Medicare generally does not cover the costs (room, board, and personal care) of senior living communities, so the MAHA ELEVATE Model may be a particularly relevant opportunity for those senior living communities that have a high Original Medicare census or a dedicated memory floor. Participating organizations will need to ensure that services funded under MAHA ELEVATE are operationally and financially distinct from services reimbursed under the GUIDE Model to avoid duplication or impermissible overlap.
Accountable Care Organizations
Participating in MAHA ELEVATE offers ACOs a chance to formally design, implement, and rigorously evaluate preventive and whole-person care interventions, especially those interventions that ACOs may already provide but are not reimbursable under traditional Medicare. Unlike the Medicare Shared Savings Program or ACO REACH (Realizing Equity, Access, and Community Health), MAHA ELEVATE does not rely on claims-based benchmarking or shared savings, but instead offers ACOs a grant-funded pathway to test non-covered services and generate evidence that could shape future Medicare policy. ACOs could submit proposals to test evidence-based functional and lifestyle medicine interventions (e.g., nutrition counseling, physical activity programming, stress reduction, sleep health, social support, and other behavioral interventions) that target chronic disease risk factors such as poor diet, inactivity, obesity, hypertension, and diabetes. ACOs often fund these services using shared savings rather than through Medicare fee-for-service reimbursement. By participating, ACOs not only secure cooperative agreement funding to cover the costs of delivering and evaluating these non-covered services over three years but also contribute to building the evidence that could lead CMS to expand future Medicare coverage to include such preventive and lifestyle-oriented services, shifting payment policy toward holistic, upstream care while potentially reducing costly downstream utilization.
Laboratories
Although clinical laboratories are unlikely to be eligible as applicants, they could play a meaningful role in the MAHA ELEVATE Model in partnering with eligible applicant organizations, including health systems, provider groups, ACOs, or community-based entities, to contribute expertise in biomarker testing, functional assessments, and data generation that support evidence-based lifestyle and preventive interventions. By contributing robust clinical and laboratory data, a lab partner can help to demonstrate the biological plausibility and measurable outcomes of proposed interventions, strengthen the evidence package required by CMS, and position itself at the forefront of research defining how advanced diagnostics can enhance preventive care and inform future Medicare coverage of holistic health services. To do this, labs would likely need to collaborate with a funded applicant on data collection, quality and cost outcomes reporting, and execution of the intervention protocol.
Key Takeaways
The MAHA ELEVATE Model represents CMS’s shift towards incorporating more preventive, lifestyle, and functional care within Original Medicare. By funding evidence-based lifestyle and functional medicine interventions that have traditionally been outside traditional Medicare coverage, the model is designed to build a framework for evaluating impacts on cost, quality, and health outcomes associated with holistic approaches to chronic disease prevention and wellness promotion.
Organizations interested in participating should begin:
- assessing their existing lifestyle or functional medicine programs,
- identifying potential partners, and
- evaluating their capacity to meet CMS’s expected evidence, reporting, and compliance requirements ahead of the anticipated NOFO in early 2026.
Successful pilots may ultimately serve as the foundation for future Medicare coverage decisions or new CMMI models that expand access to preventive and integrative care services.
This initiative reflects a broader repositioning of CMS’s strategy toward proactive, patient-centered care and aligns with CMS’s goals to promote evidence-based prevention, empower beneficiaries to achieve their health goals, and drive choice and competition within the health system. The outcomes of MAHA ELEVATE may provide a new template of how Medicare can incorporate non-traditional care initiatives that improve health and reduce long-term costs.
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