Will insurance pay for outcomes, not sessions? What Headway's changes signal

industry trends insurance private practice Oct 19, 2026

Headway's changes are not just a fee increase or policy changes. They signal an infrastructure shift toward standardized outcome data and payment based on outcomes, not visits.

It's bigger than Headway

I'm sure you've heard colleagues' frustrations about Headway's recent announcement stating they are charging a $9.99 fee for each client acquired through their marketplace (per session for the duration of treatment). It's easy to understand the uproar even if you are not a clinician on Headway.

And then there was the news of the new provider agreement they were asking Headway clinicians to sign, which launched the next wave of frustration directed toward the platform. Rightfully so.

But there is one piece in all of the announcements that I haven't seen anyone talk about yet, which signals a dramatic shift in where our industry is headed.

And that's the requirement for a baseline PHQ-9 or GAD-7 for adult talk-therapy clients.

It may seem like a small requirement, but it's signaling an infrastructure shift that will impact how therapy will be delivered in the future because it aligns with Medicare's introduction of the ACCESS Model, which began July 5, 2026.

In this post, I'll break down why it's important for all clinicians to understand the implications of the ACCESS Model including what the model is, how it works, the pledges commercial insurers have made to align with it, and how it will impact therapists in private practice.

What is the ACCESS Model?

ACCESS stands for Advancing Chronic Care with Effective, Scalable Solutions. It is a 10-year program introduced by the Centers for Medicare & Medicaid Services (CMS). The model tests outcome-aligned payment for technology-enabled chronic-care management in Original Medicare.

Participation in the ACCESS Model reimburses organizations for outcomes and technology-based solutions rather than the number of visits, for many chronic health conditions, including depression and anxiety.

Here's a breakdown of ACCESS requirements:

Assessments to identify eligibility
Care plans that are transmitted to Medicare
Periodic and annual assessments transmitted to Medicare
Technology-enabled solutions
Payment based on annual outcomes, not session visits

And if you are thinking, "I don't take Medicare, so it doesn't apply to me," please stick with me because many of the largest commercial insurers have pledged to align with this model by January 1, 2028, which will impact all private practice therapists, insurance-based or private pay.

Now let's take a step back because I want you to see what this looks like in real life.

The ACCESS Model in real life

I've been researching the model since before it launched in July 2026. But it wasn't until my 90-year-old aunt asked me to look at a letter she received from her PCP that I started to get a sense of how it was being implemented.

The letter she received was from her primary care office and they were introducing a company that could help her manage a chronic health condition. It said she'd be eligible for some technology-enabled solutions and potential follow-ups from a nurse.

I offered to research it for her and here's what I found. (I'm going to provide you with an example that is not related to my aunt's condition to preserve her privacy.)

The PCP identifies a patient with a chronic health condition that qualifies for the ACCESS program. My example will be a patient with high blood pressure.

Assessment: The PCP completes the assessment and determines the patient meets the criteria for the chronic health condition of high blood pressure. They set a goal of decreasing blood pressure within a year.
Technology-enabled solution: They refer the patient to another company that provides them with a blood pressure cuff to test blood pressure at regular intervals. These readings are transmitted to the company that issued the cuff and the PCP. If they see a concerning pattern, they reach out to the patient to intervene through contact with a nurse.
Outcome-based payment: At the end of one year, CMS will look at the blood pressure readings from the first visit and the one-year reading and if there is a decrease, the company that issued the cuff and monitored the blood pressure will be paid by CMS based on results. (Note: The participating organizations are generally paid 50% of the fee up front and then the balance based on outcome obtained.)

Now let's bring it back to our industry.

Why Headway's PHQ-9 and GAD-7 requirement matters

CMS lists depression and anxiety as qualifying chronic health conditions in the ACCESS Behavioral Health track.

In this track, CMS requires the use of assessment tools to determine whether a client meets criteria for the program. Those tools are the PHQ-9 (Patient Health Questionnaire-9) for depression and the GAD-7 (Generalized Anxiety Disorder-7) for anxiety. ACCESS participants must share care plans and updates at key clinical moments and report outcome data through CMS-compatible systems.

Beginning October 12, 2026, Headway is asking talk therapists to have adult clients complete a baseline assessment at the start of care, where clinically appropriate. PHQ-9 and GAD-7 are the accepted baseline options assessing for depression and anxiety. Headway also asks for at least one completed follow-up assessment per client each year.

Headway's new baseline-and-follow-up workflow creates the assessment infrastructure that ACCESS-style payment models depend on. (Note: Currently Headway is not listed as a participating organization in the ACCESS Model.)

In July I wrote about SimplePractice inviting a select group of therapists into Evernorth's network (What the SimplePractice and Evernorth partnership means for therapists). One of the expectations: clinicians "practice measurement-based care by reviewing outcome measures your clients complete during treatment."

Two companies. Same infrastructure.

What is a technology-enabled solution in therapy?

ACCESS is focused on outcome-based reimbursements through the use of technology-enabled solutions to complement traditional care. What is a technology-enabled solution? I don't think we've seen it deployed yet in behavioral health, but I would hypothesize that the future will include apps or AI chatbots trained in evidence-based therapies such as Cognitive Behavioral Therapy.

Here's what I think this could look like in the future:

The assessment is the PHQ-9 and GAD-7 and the client is determined eligible for ACCESS based on the score.
A technology-enabled solution is offered such as an AI chatbot trained in an evidence-based therapy.
The client would be required to use the chatbot and complete ongoing assessments.
If the client's scores do not improve, they may be referred to a real-life therapist (I'm speculating here).
The company would transmit the results of the assessments to CMS.
The company would receive payment if the client's scores decreased over the year.

I think it's clear that companies like Headway are building the platform infrastructure that makes outcome-based arrangements operationally possible.

I'm not the only one reading it this way. In his Substack, Robert Longyear calls the behavioral health track a test of whether "software, not clinicians, can manage chronic disease at scale." In his read, the clinician's role is occasional oversight, done asynchronously. Not weekly sessions.

The economics point the same way. The model was built for scale.

Can independent therapists participate in the ACCESS Model?

Independent therapists are not allowed to participate in ACCESS individually and here's why:

Participants must be Medicare Part B enrolled organizations with a physician clinical director, and they must have reporting systems in place that can communicate with CMS's own systems.

Participants must offer FDA-compliant digital tools. Most solo and small group practices don't have an app to offer, and building one isn't realistic.

But here's the most important thing: the reimbursement is low. Here's the math for the Behavioral Health track for Medicare reimbursements:

Medicare pays $180 per client for the first year and $90 per client after year one. The model only works at high volume.

And that's why the platforms are building the infrastructure now. And here's how:

Attract many therapists to their platforms, offering higher pay rates and easy credentialing
Increase the number of clients on the platform (more therapists, more clients)
Require ACCESS assessment instruments for all new clients
Develop the technology to offer clients who meet ACCESS requirements
Transition clients to the technology-based solution
Continue regular assessments
Possible individual sessions as needed
Collect fees at scale

The model wasn't built for solo practices.

How does the ACCESS Model affect therapists who don't take Medicare?

Even if you don't take Medicare, CMS is encouraging commercial insurers to align with the ACCESS Model, meaning they would structure care so providers get paid for measurable outcomes and technology-supported care rather than only fee-for-service volume. CMS calls this the ACCESS Payer Pledge.

Under the pledge, payers commit to offering payment arrangements aligned with ACCESS's core principles by January 1, 2028. That means they are expected to build payment arrangements that reward outcome attainment, care coordination, and technology-enabled care delivery.

Payers that have signed the pledge include:

Arkansas Blue Cross and Blue Shield
Blue Shield of California
Blue Cross and Blue Shield of Minnesota
Blue Cross Blue Shield of North Dakota
BlueCross BlueShield of Tennessee
CareFirst BlueCross BlueShield
Centene
Cigna
CVS Health (Aetna)
Devoted Health
GuideWell
Horizon Blue Cross Blue Shield of NJ
Humana
UnitedHealthcare
Baylor Scott & White Health Plan
TriWest Healthcare Alliance
Blue Cross & Blue Shield of Rhode Island

For behavioral health, a commercial insurer could align with the ACCESS program by:

Requiring measurement-based care in network participation agreements.
Requiring providers to utilize platforms that can track and report PHQ-9/GAD-7-style outcome data.
Paying platforms for care coordination and digital engagement where those services support measurable improvement, rather than paying for individual therapy visits.

What this means for the industry

This is a preview of where insurance-based private practice is heading.

Medicare and the largest commercial insurers have committed to paying for measurable outcomes and technology-supported care. The platforms are building to meet them.

Next time you see a post from a platform or an EHR that talks about requiring assessments or aligning with outcome-based reimbursement models, you'll know it's another sign pointing in that direction.

If you've read my other blog posts (or watched my videos) you know that I've been talking about where the industry is headed.

I've hypothesized that insurance companies will move away from independent insurance contracts toward platform-based credentialing. If you hear of insurance panels saying they are not accepting new providers, that would lend more credibility to my argument.

I now believe that they are moving providers toward platform-based credentialing so in the future (2028) they will have the infrastructure required to participate in and financially benefit from the ACCESS program.

And I believe this means for clients who meet certain criteria, the first option will be for them to enroll in a technology-based solution like an app or a chatbot to address symptoms and be referred to a provider when progress has not been made.

And just a thought...with announcements from Headway and the Evernorth partnership with SimplePractice...the platforms are collecting your clients' data starting now. Your clients must fill out PHQ-9s and GAD-7s prior to the start of treatment and at regular intervals. I think it's a plausible assumption that they will be using the data to compare against outcomes from their technology-based solutions as they are testing them. And if the app or chatbot performs better, then it will be further reason for insurance companies to deny individual sessions.

Closing

So where does that leave us as trauma therapists in private practice?

It's clear it will be harder to have a successful, independent insurance-based private practice. So therapists will either have to stay on the platforms, move to private pay or leave the field.

And honestly, it's why my focus has been on helping trauma therapists understand the business side of their practice. I believe successful therapists in the near future will be good therapists who are also good at business.

I encourage you to read the articles I've linked below for further understanding of the industry and where it's headed. I will continue to provide my perspective as things evolve.

Prefer to watch? Here's the video version on YouTube.

Want my take as the industry keeps changing? Join my email list.

For further reading:

ACCESS Model

ACCESS Payer Pledge

Holland & Knight: CMMI launches voluntary payment model for qualifying chronic conditions