April 1, 2026
On March 31, 2026, CMS released the official Request for Applications (RFA) for the Long-term Enhanced ACO Design (LEAD) Model — the 10-year program that will replace ACO REACH when it ends on December 31, 2026. The application window closes May 17, 2026. That is 47 days.
If your organization is currently in ACO REACH, or if you have been evaluating a move into full-risk value-based care, this is not a watch-and-wait moment. The transition timeline is tight: REACH closes December 31, 2026; LEAD performance year 1 begins January 1, 2027. ACOs that don't apply now either step back to MSSP — a lower-upside risk arrangement — or sit out value-based care entirely for a year. Neither is a good option for organizations that have been building toward full-risk performance.
Seventy-four ACOs are currently enrolled in ACO REACH. All of them are making this decision right now.
LEAD is not REACH with a new name. There are meaningful structural differences that change how you need to operate — and what you need to demonstrate in your application.
LEAD runs from January 2027 through December 2036 — the longest CMS innovation model ever tested. This is deliberate. CMS wants organizations to make infrastructure investments that 3- and 5-year programs never justified. A decade-long commitment changes the ROI math on care management staffing, data platforms, and AI-driven execution tooling. If you are going to build it, the window to start is now.
LEAD offers two participation tracks:
Both tracks require robust performance on quality measures — HEDIS metrics, AWV completion rates, care gap closure — the same levers that determine whether you generate savings or owe CMS money at reconciliation.
LEAD introduces beneficiary incentive payments, rural add-on payments, and episode-based risk arrangements with specialists. By 2029, CMS plans to offer beneficiary drug premium buy-downs. These are meaningful program features — but they also require more sophisticated care coordination infrastructure to deploy at scale. An organization that can't execute consistent outreach today is not positioned to operationalize beneficiary incentive programs in year three.
A formal Medicare-Medicaid integration planning phase runs from March 2026 through December 2027. For ACOs serving dual-eligible populations — increasingly a high-cost, high-priority segment — this is significant. Dual-eligible beneficiaries require longitudinal, proactive care management. Point-in-time interventions don't move the needle on total cost of care for this population.
The LEAD application asks you to demonstrate that you can execute — not just that you understand value-based care conceptually. CMS will evaluate your organization on:
These are execution problems, not strategy problems. Most ACOs have the strategy. The gap is in who actually makes the call, who documents the encounter, and whether the workflow closes the loop before the patient falls through.
NAACOS has been consistent on this point: the organizations that underperformed in ACO REACH did so not because they lacked risk contracts or good intentions, but because their care management capacity didn't scale with their attributed population. LEAD's 10-year structure will reward organizations that solve this problem early and punish those that defer it.
The ACOs generating consistent shared savings share a few operational patterns that separate them from the field:
They close AWV gaps proactively, not reactively. Annual Wellness Visits are the highest-leverage touchpoint in a Medicare population — they unlock HCC coding opportunities, flag care gaps, and anchor the care plan for the year. ACOs that wait for patients to self-schedule AWVs consistently leave 30–40% of their attributed population uncaptured. The organizations that win in LEAD will have automated outreach workflows running year-round, not a sprint in Q4.
They act on discharge data in hours, not days. Post-discharge readmission risk peaks in the 72 hours after a patient leaves the hospital. An outreach program that triggers on day four or five is operating outside the intervention window. Real-time ADT feeds connected to automated follow-up workflows are table stakes for serious LEAD participants.
They scale without proportional headcount growth. The organizations winning in value-based care have figured out how to extend each care manager's reach, not just hire more care managers. At the population sizes that LEAD targets — and over a 10-year performance arc — headcount-driven scale is not a viable model.
PBACO operationalized this directly: by deploying AI voice agents for AWV scheduling and post-discharge outreach, they closed care gaps and reduced readmissions without the cost structure of a proportionally larger care management team. The improvement showed in both quality scores and shared savings reconciliation.
HCN demonstrated the same principle at the program level — scaling care management capacity across a significantly larger attributed population without adding headcount at the same rate. In a 10-year model where performance expectations increase over time, that operational leverage is a structural advantage.
If your organization is evaluating a LEAD application, here is where to focus between now and the deadline:
1. Audit your current performance data. What is your AWV completion rate? Where are your HEDIS gaps by measure? What was your readmission rate for PY 2025? You need clean, defensible answers to these questions before you apply — and more importantly, before year one of LEAD starts and those gaps cost you at reconciliation.
2. Model your attributed population under LEAD's financial methodology. LEAD uses updated benchmarking structures, includes rural add-on payments, and has different risk adjustment mechanics than REACH. If you are currently in ACO REACH, your finance team needs to re-model shared savings potential under the new structure before committing to the Global vs. Professional track decision.
3. Assess your care management infrastructure for scale. LEAD is a 10-year model with increasing performance expectations. Ask honestly: can your current team manage a 20% attributed population increase in year three without quality scores degrading? If the answer is no, that is a technology investment decision — and the time to make it is before year one, not after your first reconciliation shows a shortfall.
4. Get your data infrastructure in order. LEAD requires continuous performance monitoring, not annual reporting. ACOs need real-time visibility into claims, clinical events, and quality measure status — not a data warehouse that refreshes quarterly. If your current data infrastructure doesn't support real-time care gap identification, that gap needs to be on your roadmap now.
5. Send representation to the NAACOS Spring Conference (April 22–24, Baltimore). LEAD will dominate the agenda. CMS officials will be present. The intelligence from those sessions will directly inform application strategy — particularly around the Medicare-Medicaid integration planning phase, which starts this year.
The ACOs that win in LEAD will be the ones that close the gap between strategy and execution — between knowing a patient has a care gap and actually closing it; between receiving a discharge notification and reaching the patient within 24 hours; between generating a care plan and having it actively managed through to completion.
That execution layer is not a dashboard. It is not a report. It is AI agents that make calls, document encounters, flag escalations, and feed structured data back into quality and cost tracking — at scale, without requiring a new FTE for every 200 patients added to the attributed population.
The LEAD Model's 10-year horizon is CMS signaling that it expects organizations to build this infrastructure. The organizations that apply thoughtfully — with a clear picture of their current execution gaps and a concrete plan to close them before year one — will enter LEAD with a structural advantage that compounds over a decade.
The application deadline is May 17. The model starts January 1, 2027. The window to build the infrastructure that determines your year-one performance is right now.