The CMMI Authority

The entire world of value-based care models rests on one provision: Section 1115A of the Social Security Act. Understanding what it uniquely allows explains why the Innovation Center can do what it does, and why the model landscape looks the way it does.

Where CMMI comes from

Section 1115A was added by Section 3021 of the Affordable Care Act and created the Center for Medicare and Medicaid Innovation. Its stated purpose is to test innovative payment and service delivery models that reduce program spending under Medicare, Medicaid, and CHIP while preserving or enhancing the quality of care. Codified at 42 U.S.C. 1315a, it is the statutory engine behind every model this curriculum has discussed.

What the authority uniquely allows

Two powers make 1115A exceptional:

• Broad testing discretion. The Secretary, through CMMI, can design and test a wide range of payment and delivery models, and can waive certain Medicare and Medicaid requirements as needed to run them. This is why models can depart from standard program rules.
• Expansion without legislation. The feature covered in the evaluation course: if a model meets a rigorous standard, it can be expanded in duration and scope nationally, without a new act of Congress.

Worth remembering: that expansion pathway is what turns CMMI from a research shop into a policy engine. Ordinarily, changing how Medicare pays requires an act of Congress. Section 1115A lets a demonstrated model become national policy through the executive branch alone, provided it clears the certification bar. This is an unusual delegation of power, and it is the reason so much payment reform runs through CMMI rather than through legislation.

The limits

The authority is broad but not unbounded. Models are meant to be budget-responsible and are subject to evaluation. Certain protections and requirements cannot be waived. And crucially, Congress retains its own authority: it can mandate specific alternative payment models by statute, override CMMI, or change 1115A itself. CMMI operates within a space Congress created and can reshape.

Why this frames everything

Every later lesson depends on this authority. How models are born, how they are announced, how they expand or end, all of it is CMMI exercising, or Congress constraining, the power in Section 1115A. Knowing the source of the authority is what lets you follow the action.

Key takeaways

• Section 1115A (42 U.S.C. 1315a), added by ACA Section 3021, created CMMI to test payment and delivery models that cut spending while preserving or enhancing quality.
• It uniquely allows broad model testing and national expansion of successful models without new legislation.
• The authority is bounded: models face evaluation and limits, and Congress can mandate models or change the statute itself.

Sources

• Social Security Act, Section 1115A (opens in a new tab)
• Congressional Research Service, Recent Developments Regarding Payment Models at the CMS Innovation Center (IF13033) (opens in a new tab)