See how LEAD compares to ACO REACH

Unlike other Medicare ACO models, LEAD eliminates benchmark rebasing over its 10‑year duration, preserving incentives for ACOs to generate savings year after year. LEAD offers two voluntary risk tracks, Global and Professional, consistent with ACO REACH. Organizations entering the Professional track must remain there for four years before becoming eligible to switch to the Global track. Benchmarking will initially rely on historical experience with regional or prior savings adjustments, resembling the Medicare Shared Savings Program (MSSP). CMMI has indicated that the model will transition to a rate‑book‑based benchmark in the latter half of its duration. CMMI expects costs to begin converging across higher and lower spending ACOs over time, and therefore, will transition to the use of standardized, rate-book based benchmarks.

LEAD enhances ACO REACH by integrating high‑needs beneficiaries across all ACOs, strengthening risk adjustment and benchmarking, supporting Medicaid coordination, and improving payment accuracy for complex‑care providers. Under LEAD, participants are defined at the Taxpayer Identification Number (TIN) level, aligning closer to the Medicare Shared Savings Program (MSSP) and replacing ACO REACH’s TIN and National Provider Identifier (NPI) structure. Beneficiaries may be aligned through claims‑based or voluntary alignment, with ACOs choosing between prospective alignment or a new hybrid option that allows monthly voluntary alignment additions and a mid‑year opportunity to add participant TINs. High‑needs beneficiaries are treated as a distinct cohort within all ACOs alongside aged/disabled (AD) and end‑stage renal disease (ESRD) populations, with LEAD continuing to apply prospective risk adjustment for AD and ESRD and concurrent risk adjustment for the high‑needs cohort.

LEAD continues to offer total cost of care (TCC) and primary care capitation (PCC) and introduces a new non‑primary care capitation (NPCC) option for organizations electing PCC. NPCC will not be reconciled against fee‑for‑service billing, offering greater payment stability. The model also introduces CMS‑Administered Risk Arrangements (CARA), an optional platform designed by CMMI to support episode‑based downstream risk arrangements between ACOs and contracted specialists.

LEAD will initially include seven quality measures, five carried over from ACO REACH and two electronic clinical quality measures (eCQMs) phased in over time. There’s also a reduced 3% quality withhold (compared to 5% in ACO REACH in PY2026) that ACOs may earn back based on performance in those five measures. Participants must implement a prevention and quality plan (PQP) tailored to their population. The LEAD model will also retain the high performers pool (HPP) that awards a bonus to high-performing ACOs providing exceptional quality of care. The model also expands beneficiary engagement and prevention supports, including future Medicare Part D premium buydowns, expanded medical nutrition therapy, chronic disease prevention rewards, and new beneficiary engagement incentives. Additionally, CMS plans to test Medicaid integration through partnerships with two states focused on care coordination for dually eligible beneficiaries.

While CMS has outlined LEAD’s core structure, several critical details remain unresolved and are expected to be clarified in the forthcoming Request for Applications (RFA), anticipated in March.