CMS Proposes 'RAPID' Pathway to Cut Medicare Coverage Time for Breakthrough Devices From 5 Years to 60 Days
A new joint initiative between the FDA and CMS aims to eliminate the years-long waiting period for Medicare to cover life-saving medical devices by aligning regulatory reviews.
- Federal Regulators
- Focus on eliminating duplicative trials and aligning evidence expectations early to improve government efficiency.
- Device Innovators
- Welcome the faster coverage timeline but face a higher upfront burden to prove substantial clinical improvement.
- Patient Advocates
- View the policy as a life-saving measure that eliminates the devastating waiting period for breakthrough treatments.
How we got here
Jan 2021
CMS finalizes the MCIT rule to provide automatic Medicare coverage for breakthrough devices, which is later repealed by the incoming administration.
Aug 2024
CMS introduces the TCET pathway as a transitional coverage model, but caps it at roughly five devices per year.
Apr 2026
The FDA and CMS jointly announce the RAPID pathway to synchronize evidence requirements and speed up coverage.
Aug 2026
CMS publishes the proposed procedural notice for RAPID, opening a 60-day public comment period.
Why it matters
For older adults facing severe or life-threatening conditions, this policy change means life-saving medical devices could be available through Medicare in two months rather than five years, eliminating a devastating waiting period.
For millions of older Americans, the hardest part of a devastating diagnosis isn't learning that no treatment exists—it's learning that a life-changing treatment does exist, but Medicare will not pay for it yet.[5]
Historically, when the FDA approves a breakthrough medical device—like a novel heart valve, a neurostimulator, or a new diagnostic implant—patients face a bureaucratic "valley of death." It can take up to five years for Medicare to agree to cover the cost, leaving the most vulnerable patients waiting for access to technology that is already sitting on hospital shelves.[5]
That waiting period is about to collapse. The Centers for Medicare & Medicaid Services (CMS) and the FDA have jointly proposed the RAPID (Regulatory Alignment for Predictable and Immediate Device) coverage pathway, a structural overhaul of how medical innovation reaches the bedside.[1][2]
Under the new framework, Medicare coverage for eligible breakthrough devices could begin as soon as 60 days after FDA market authorization, transforming a multi-year ordeal into a matter of weeks.[2][3]

The traditional delay stems from a fundamental disconnect between two massive federal agencies. The FDA evaluates whether a device is safe and effective for the general public. CMS, however, evaluates whether a device is "reasonable and necessary" specifically for the Medicare population, which often skews older and has more complex health needs.[5]
Because the two agencies historically worked sequentially, a manufacturer might spend years running a clinical trial to satisfy the FDA, only to find out after approval that CMS wanted different data. This often forced companies to run entirely new, duplicative trials just to secure reimbursement, stalling patient access indefinitely.[2][5]
RAPID changes the sequence. CMS will now join the FDA and the device manufacturer during the initial trial design phase, known as the Investigational Device Exemption (IDE) stage.[1][3]
CMS will now join the FDA and the device manufacturer during the initial trial design phase, known as the Investigational Device Exemption (IDE) stage.
By aligning their evidence expectations before the first patient is even enrolled, the agencies ensure the trial generates the exact clinical outcomes both regulators need simultaneously. The manufacturer runs one trial, and both agencies get their answers.[2][3]
The result is a synchronized finish line. When the FDA grants market authorization, CMS will issue a proposed National Coverage Determination (NCD) on the exact same day.[2][3]

Following a mandatory 30-day public comment period, a final coverage decision is targeted within 60 days for Class II devices and 90 days for Class III devices. The procedural notice for the pathway is currently undergoing its own 60-day public comment period.[1][3]
Not every device qualifies for this fast track. RAPID is strictly reserved for FDA-designated Breakthrough Devices that address an unmet medical need specifically in the Medicare population. Class II devices must also be participating in the FDA's Total Product Life Cycle Advisory Program (TAP).[2]
There is also a regulatory trade-off. While CMS is speeding up the coverage timeline, it is simultaneously repealing an older shortcut known as the New Technology Add-On Payment (NTAP) alternative pathway for breakthrough devices.[4][5]

Manufacturers will now have to definitively prove their device offers a "substantial clinical improvement" over existing treatments to qualify for those add-on payments. The upfront bar for clinical evidence is higher, but the reward is immediate, predictable national access.[4][5]
Questions remain about execution. Both agencies are taking on significant new collaborative workloads, and it is unclear if current staffing levels can support a high volume of RAPID candidates without slowing down the review of standard medical devices.[5]
For patients, however, the bureaucratic mechanics matter less than the outcome. When a breakthrough device is the only thing standing between decline and recovery, cutting the wait time from years to months is nothing short of life-saving.[5]
What to know
- The RAPID pathway aims to cut Medicare coverage wait times for breakthrough devices from up to five years to just 60 days.
- CMS will now join the FDA during the initial clinical trial design phase to align evidence requirements.
- A proposed Medicare coverage determination will be issued on the exact same day a device receives FDA market authorization.
- The pathway is limited to FDA-designated Breakthrough Devices that address unmet needs in the Medicare population.
- Concurrently, CMS is repealing an older shortcut, requiring manufacturers to prove substantial clinical improvement for add-on payments.
Where opinion splits
Federal Regulators
Focus on eliminating duplicative trials and aligning evidence expectations early to improve government efficiency.
For the FDA and CMS, the RAPID pathway represents a shift from sequential bureaucracy to parallel collaboration. By getting involved during the Investigational Device Exemption (IDE) phase, regulators can ensure that a single clinical trial answers both the FDA's questions about general safety and CMS's questions about efficacy for older adults. This prevents the historical problem where a manufacturer finishes a multi-year trial only to be told by CMS that the data is insufficient for reimbursement.
Device Innovators
Welcome the faster coverage timeline but face a higher upfront burden to prove substantial clinical improvement.
Medical device manufacturers have long lobbied for faster Medicare coverage, arguing that the 'valley of death' between FDA approval and CMS reimbursement stifles investment in life-saving technology. While RAPID solves the timeline issue, it comes with a catch: CMS is simultaneously repealing the New Technology Add-On Payment (NTAP) alternative pathway. Innovators will now have to design more rigorous upfront trials to definitively prove their device is substantially better than existing treatments.
Patient Advocates
View the policy as a life-saving measure that eliminates the devastating waiting period for breakthrough treatments.
For patient advocacy groups, the bureaucratic mechanics of how CMS and the FDA share data are secondary to the real-world outcome: time. When a patient is diagnosed with a severe or irreversibly debilitating condition, a five-year wait for Medicare to cover a newly approved device is often a death sentence. By shrinking that window to 60 days, advocates argue that the RAPID pathway will directly save lives and reduce disparities in access to cutting-edge care.
Key terms
- Breakthrough Device Designation
- An FDA status given to novel medical devices that provide more effective treatment for life-threatening or irreversibly debilitating conditions.
- National Coverage Determination (NCD)
- A nationwide policy by CMS that dictates whether Medicare will pay for a specific medical item or service.
- Investigational Device Exemption (IDE)
- An FDA approval that allows an experimental medical device to be used in a clinical study to collect safety and effectiveness data.
- RAPID Pathway
- The new joint FDA-CMS program designed to cut the time between a device's approval and its Medicare coverage down to 60 days.
Unanswered questions
- Whether CMS and the FDA have the internal staffing capacity to handle the intensive early-engagement requirements of the RAPID pathway without slowing down other device reviews.
- How quickly commercial health insurers will follow Medicare's lead in adopting immediate coverage for these breakthrough devices.
Reader questions
Will this apply to all new medical devices?
No. The RAPID pathway is strictly limited to FDA-designated Breakthrough Devices that address an unmet medical need specifically for the Medicare population.
Does this mean devices will be approved with less evidence?
Actually, the opposite. Manufacturers must now meet both FDA and CMS evidence requirements simultaneously during their initial trials, raising the upfront bar for clinical data.
When does the RAPID pathway take effect?
The pathway is currently undergoing a 60-day public comment period following its procedural notice, with implementation expected shortly after the final notice is published.
Sources
[1]STAT NewsDevice Innovators
STAT+: A RAPID proposal for breakthrough coverage, and nurses push back on AI
Read on STAT News →[2]U.S. Food and Drug AdministrationFederal Regulators
CMS and FDA Announce RAPID Coverage Pathway to Accelerate Patient Access to Life-Changing Medical Devices
Read on U.S. Food and Drug Administration →[3]Centers for Medicare & Medicaid ServicesFederal Regulators
CMS and FDA Announce RAPID Coverage Pathway to Accelerate Patient Access to Life-Changing Medical Devices
Read on Centers for Medicare & Medicaid Services →[4]Federal RegisterFederal Regulators
Medicare Program; Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals
Read on Federal Register →[5]Factlen Editorial TeamPatient Advocates
Synthesis by Factlen editorial team
Read on Factlen Editorial Team →
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