$100 Million to Rethink Medicare: Inside CMS's MAHA ELEVATE Model and How to Position Your Organization

Three days. That's how long organizations have to submit a mandatory Letter of Intent for one of the most unusual grant programs the Centers for Medicare & Medicaid Services has ever launched — and most eligible applicants don't know it exists yet.

The MAHA ELEVATE model (Make America Healthy Again: Enhancing Lifestyle and Evaluating Value-based Approaches Through Evidence) opened applications on March 31 and will distribute approximately $100 million through 3-year cooperative agreements to up to 30 organizations. As Granted News reported, the program targets a category of interventions that Original Medicare has historically refused to cover: functional and lifestyle medicine approaches including nutrition coaching, stress management, sleep optimization, and physical activity programs.

The LOI deadline is April 10, 2026. Full applications are due May 15. If your organization serves Medicare fee-for-service patients and has experience with whole-person care, the next 72 hours matter.

What MAHA ELEVATE Actually Funds

This is not a standard CMS demonstration project testing a new payment model. MAHA ELEVATE is a cooperative agreement — closer to a research grant than a Medicare reimbursement experiment. Funded organizations receive up to $3.3 million over three years to deliver evidence-based interventions that Original Medicare doesn't currently cover, then collect data on whether those interventions improve health outcomes and reduce costs.

Every proposal must include either nutrition or physical activity interventions. Beyond that required floor, applicants can add stress management, sleep health, harmful substance avoidance, social connection programming, and behavioral interventions targeting chronic disease risk factors. The model explicitly permits "Food as Medicine" benefits — culinary medicine, nutrition coaching, meal planning, food security screenings, and coordination with programs like SNAP and WIC — though food itself is an unallowable cost. You can teach someone to cook; you can't buy their groceries.

Three of the 30 awards are reserved specifically for dementia-related proposals, with potential integration alongside CMS's existing GUIDE (Guiding an Improved Dementia Experience) Model. Organizations already participating in GUIDE should pay particular attention — the overlap creates a unique positioning opportunity.

The first cohort launches September 1, 2026. A second cohort begins in 2027, meaning organizations that miss the current cycle may have another window, though CMS has not yet announced the second cohort's timeline.

Who Qualifies — and Who Doesn't

The eligible applicant pool is deliberately broad, which is both an opportunity and a source of confusion. CMS has authorized the following organization types:

Physician practices and health systems form the most obvious applicant category. Multi-specialty practices with existing integrative or lifestyle medicine programs can propose scaling those programs to Medicare FFS patients with federal backing.

Accountable Care Organizations get a particularly interesting deal. For ACOs, MAHA ELEVATE offers a grant-funded pathway to test non-covered services and generate evidence that could shape future Medicare policy — without the financial risk tied to shared savings benchmarks. An ACO can use this funding to build out preventive programming that, if validated, could eventually become reimbursable.

Federally Qualified Health Centers and Rural Health Centers serve disproportionately complex patient populations with limited resources. MAHA ELEVATE's cooperative agreement structure — which provides direct funding rather than requiring organizations to front costs and seek reimbursement — is better suited to FQHCs than most CMS innovation models.

Community-based organizations, state and local governments, and senior living communities are eligible in ways that most CMS programs would not permit. A community nutrition program, a county public health department, or a continuing care retirement community could apply directly.

Indian Health Service, Tribal Services, and Urban Indian Programs are explicitly listed. Given the chronic disease burden in Native communities and the historic difficulty of adapting CMS models to tribal health systems, these slots represent meaningful access.

Academic organizations and functional/lifestyle medicine centers round out the eligible pool. Medical schools with existing lifestyle medicine residency tracks or research programs in nutritional interventions have natural alignment.

Who can't apply as a primary applicant: laboratories, pharmaceutical companies, and organizations without demonstrated experience in evidence-based whole-person interventions. However, labs can partner with funded organizations to provide biomarker testing, functional assessments, and data generation — a significant opportunity for diagnostic companies and clinical research organizations.

The Strategic Calculus: Why This Model Matters Beyond $100 Million

The dollar amount is modest by CMS standards — $100 million distributed across 30 organizations over three years is meaningful but not transformative funding. The strategic value lies elsewhere.

MAHA ELEVATE is a policy trial balloon. CMS is explicitly testing whether lifestyle and functional medicine interventions can produce measurable improvements in Medicare outcomes. If the answer is yes — if nutrition coaching reduces hospitalizations, if stress management lowers cardiovascular event rates, if sleep optimization decreases fall risk in dementia patients — the findings become the evidence base for expanding Original Medicare coverage to include these services permanently.

Organizations selected for MAHA ELEVATE won't just receive $3.3 million. They'll generate the clinical evidence that determines whether an entire category of healthcare services becomes reimbursable under Medicare. The organizations that produce the strongest outcomes data will have first-mover advantage in delivering those services at scale once coverage expands.

This dynamic explains why the eligible applicant list is so broad. CMS wants diverse delivery models — academic medical centers, community health centers, tribal programs, senior living facilities — to test whether whole-person care works across different populations and settings. The most compelling applications will propose interventions that are both evidence-based and replicable in contexts beyond the applicant's specific organization.

How the Political Landscape Shapes This Opportunity

MAHA ELEVATE carries the administration's "Make America Healthy Again" branding, which signals both opportunity and risk. The program aligns with HHS Secretary Kennedy's stated priorities around chronic disease prevention and reducing pharmaceutical dependence. That political backing provides near-term protection — this model is unlikely to face the funding freezes or programmatic terminations that have disrupted other federal health programs.

The risk is duration. Cooperative agreements run three years, but political priorities shift faster. Organizations should structure their proposals to generate publishable outcomes data within 18 to 24 months — not just at the three-year mark — to ensure results exist regardless of future political shifts.

The dementia-focused awards are particularly well-positioned. Alzheimer's and dementia care has bipartisan support, and the GUIDE Model integration creates institutional continuity that transcends any single administration's priorities.

What a Competitive Application Looks Like

CMS hasn't published detailed scoring rubrics, but the model's structure reveals what evaluators will prioritize.

Evidence base matters more than ambition. Proposals must demonstrate "scientifically documented improvements in health" from the proposed interventions. Organizations with published clinical data on their specific nutrition, physical activity, or lifestyle medicine programs have a structural advantage. If you've been running a diabetes prevention program that produced measurable A1C reductions, say so with data.

Data infrastructure is non-negotiable. MAHA ELEVATE requires participants to collect and report data on health outcomes, cost impacts, and quality measures. Organizations without existing electronic health record integration, patient tracking systems, and outcomes measurement capacity will struggle. CMS is looking for organizations that can generate evidence, not just deliver services.

Medicare FFS population access is the threshold requirement. Your organization must serve Original Medicare beneficiaries — not Medicare Advantage, not Medicaid. Organizations whose patient populations skew toward commercial insurance or MA plans may find it difficult to recruit sufficient FFS participants.

Operational separation from other CMS programs. If you're already participating in GUIDE, ACO REACH, or another CMS innovation model, your MAHA ELEVATE proposal must demonstrate financial and operational separation. This doesn't preclude participation — it requires clear organizational boundaries.

The April 10 Decision

The mandatory LOI deadline creates an artificial urgency that serves CMS's purposes — it narrows the applicant pool to organizations already aware of the opportunity and capable of rapid response. But the LOI itself is not the application. It's a signal of intent that reserves your place in the May 15 full application review.

Organizations that submit an LOI can still decide not to submit a full application. Organizations that don't submit an LOI by April 10 are excluded entirely.

For eligible organizations, the calculus is straightforward: submit the LOI now, assess competitiveness over the next five weeks, and make the full application decision with more information. The cost of submitting an LOI is hours; the cost of missing the deadline is permanent exclusion from a program that could reshape how Medicare covers preventive care — and Granted can help you identify whether your organization's profile matches what CMS is looking for before you commit to the full application.