I'm not an attorney but I'm writing as a full time expert in health policy. I think that if you put together three things - (1) the law that created CMMI, Medicare's Center for Innovation, and (2) legal arguments made in the case against the Trump "Most Favored Nation" drug pricing rule from CMMI, and (3) writings from the "Gorsuch Court" in the current OSHA case, the outlook for CMMI would not be good.
There's a lot of webpages for CMMI at CMS - here. It's authorized to create and run any number of "models." The statute describes no limits on the size or duration of models, but shields them from judicial review at 1515A(d)(2). The statute also allows CMS to waive any law in Medicare or Medicaid for the purpose of carrying out a model at (d)(1).
There's no single answer but one possibility might be the "CMMI Medicare Direct Contracting" system, created by Trump and altered and continued forward by Biden. It's unpopular in some circles - here.
FN1. The statute calls the center, "Center for Medicare and Medicaid Innovation," and you see it abbreviated often as CMMI. However, the statute at 1115A immediately describes the abbreviation as "CMI." You also see "Innovation Center" or "CMS Innovation Center" (which would be CIC, but you never see that choice of abbreviation, since it offers the pronunciation "sick.")
FN2. In the Judge Black ruling, 12/23/2020, the 3 arguments against MFN are recited. The court agrees with Argument 1 - MFN was bad due to its IFN emergency rulemaking. QED.
However, her footnote 9 carefully writes, "The court does not today reach the plaintiffs' arguments concerning the statutory authority of CMS [scope too broad] or the constitutionality of the rule [excess delegation by Congress to CMMI].
See also her footnote 17, "The court reiterates that it is expressing no opinion on the merits of teh plaintiffs' statutory or constitutional challenges to the rule."
FN3. In 2009, law professor Cass Sunstein wrote an article, Is OSHA Constitutional? (Cited inside one of the judicial opinions I read above, the BUSH dissent in appellate court filings on the path to the OSHA SCOTUS case). One could imagine Sunstein revisiting the same themes under the new title, "Is CMMI Constitutional?"
I have some informal personal links and notes on Direct Contracting here.