The Center for Medicare and Medicaid Innovation (CMMI) was established by the Affordable Care Act (ACA) in 2010 to test alternative payment and care delivery models across Medicare, Medicaid, and the Children’s Health Insurance Program. Sixteen years later, CMMI has tested approximately 70 models, funding this work with both its mandatory ACA appropriation and the Medicare Trust Funds. Despite the scale of activity, the public record on CMMI’s full financial footprint contains gaps, a function of how the Centers for Medicare & Medicaid Services structures its statutory reporting obligations.

To fill in these knowledge gaps, Avalere Health evaluated CMMI’s spending against its mandatory appropriation and the model-specific payments from the Medicare Trust Funds since the agency’s inception. We drew on recent analyses from the Government Accountability Office (GAO), the Congressional Budget Office (CBO), and CMMI’s biennial Reports to Congress (RTCs).

CMMI’s Spending Against its Mandatory ACA Appropriation

CMMI receives $10 billion every decade under ACA Section 3021; this funding is not subject to annual Congressional approval and is intended to cover model operations and administrative costs. A March 2026 GAO report confirmed that CMMI’s cumulative obligations reached $11.4 billion through fiscal year (FY) 2024, meaning the agency drew $1.4 billion against its second $10 billion allotment.

In September 2023, the CBO released a report outlining CMMI’s spending between administrative outlays and the net impact of model participation on Medicare benefit payments, making it the only publicly available source in CMMI’s history to do so. The report estimated that CMMI spent $7.9 billion on employees, model infrastructure, evaluations, and other model operations in its first decade. That spending, combined with a $2.6 billion net reduction in spending on healthcare benefits attributable to model participation, resulted in a first-decade net federal cost of $5.4 billion.

CMMI’s biennial RTCs reported $7.8 billion in spending from FY2010–2024, covering operational payments made to model and participants and the design, implementation, and evaluation of models.

The $3.6 billion gap between GAO’s $11.4 billion in total obligations and the $7.8 billion attributed to specific models reflects administrative costs such as CMMI staff salaries, infrastructure, and operational overhead, all of which are excluded from CMMI’s statutory payment reporting.

Model-specific Payments from the Medicare Trust Funds

Three RTCs (2020, 2022, and 2024) show that across 57 CMMI models FY2010–2024, Medicare Trust Fund payments totaled $20.75 billion. This number reflects shared savings bonuses, performance adjustments, and waiver-based payments that would not have occurred absent model participation. Routine Medicare fee-for-service (FFS) payments for services rendered to model beneficiaries are not included.

The RTCs capture only payments made within each reporting period, and model-specific data that was unavailable at the time of publication is not carried forward to subsequent reports. As a result, 14 of the 57 models included in this analysis, did not report Trust Fund payment data. Additionally, the RTCs do not break down payments by Trust Fund accounts (i.e., Hospital Insurance Trust Fund vs. Supplementary Medical Insurance Trust Fund).

Further, not all CMMI models are captured in the RTCs despite reporting a net increase in Medicare payments. The Medicare Advantage Value-Based Insurance Design Model presents a distinct case: the RTCs reported no direct payments from the Medicare Trust Funds across any reporting period, despite reporting $4.5 billion in ”substantial and unmitigable costs to the Medicare Trust Funds.” The RTCs do not attribute these costs to the Trust Fund because the model was not designed to provide payments to plans beyond those provided under statute for the MA program. CMMI expected that plans would pay for the benefits using the rebates or enrollee premiums.

Conclusion

Public data documents over $20 billion in payments from the Medicare Trust Funds attributable to CMMI models from FY2010–2024, with the annual draw rate accelerating from approximately $590 million per year in CMMI’s first decade to approximately $4.5 billion by FY2023–2024. Gaps in data availability means the public record does not fully capture CMMI’s administrative costs or detail the financial activity of all models in its portfolio.

Greater transparency in CMMI’s statutory reporting, including disclosure of center-wide administrative costs and consistent reporting across model types, would allow policymakers and stakeholders to more fully assess the agency’s impact on Medicare Trust Fund payments and determine whether CMMI is achieving its intended purpose.

To learn more about CMMI payment models and Medicare Trust Fund spending, connect with us.

Methodology

Avalere Health reviewed publicly available sources to evaluate CMMI’s operational spending and model-specific Medicare Trust Fund payments. Key sources included the GAO March 2026 report on CMMI obligations; the CBO September 2023 analysis of CMMI’s budgetary effects; and CMMI’s 2020, 2022, and 2024 biennial RTCs (covering FY2010–2020 cumulatively, FY2021–2022, and FY2023–2024, respectively). Model-specific Trust Fund payment data was obtained from Table 2 of the 2020 and 2022 RTCs and Table 3 of the 2024 RTC, with report payments under Section 1115A of the ACA and payments under Title XVIII or XIX of the Act made on behalf of model beneficiaries. Routine Medicare FFS payments that would have occurred absent model participation are excluded from all figures. Trust Fund payment figures represent payments reported within each RTC’s coverage period and do not include data unavailable at the time of publication.