CMS requests ACOs apply for LEAD model

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CMS issued a request for applications March 31 for its long-term enhanced ACO design model.

The model’s performance period will span one decade — the longest CMS has tested — and run from Jan. 1, 2027, until Dec. 31, 2036. Under LEAD’s risk-sharing options, ACOs can keep up to 100% of savings if spending is below benchmark and be held responsible for 100% if spending exceeds the benchmark. ACOs could also choose to keep up to half the savings and be responsible for up to half the losses.

Building off the model’s December 2025 announcement, the request for applications included more details about what LEAD will evaluate.

Here are five more things to know about the model as ACOs consider applying:

  1. Benchmarks will not be rebased throughout the period, meaning benchmarks will not change based on more recent expenditure history.
  1. The model relies on a three-way blended update factor that combines national and regional growth with prospective accountable care trends. After five years, a regional, ratebook-based benchmark will be phased in, ultimately replacing expenditure-based benchmarks.
  1. The model will experiment with an AI-inferred risk adjustment model in 2028. A full transition to AI-only risk scores for the aged and disabled population will take effect in performance year 2031.
  1. Capitation is mandatory, rather than getting paid per claim. CMS allows this mechanism to be extended to specialists, as well. This is currently only available with Medicare Advantage, not original Medicare.
  1. ACOs would be able to give qualifying patients eligible hemp products through the Substance Access Beneficiary Engagement Incentive.

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