By Jay Chowdappa, MD, co-founder and CEO, Zynix AI · Updated November 3, 2026
Key takeaways
As of November 3, 2026, the CMS LEAD (Long-term Enhanced ACO Design) Model’s first application window is closed and no new one is announced. LEAD replaces ACO REACH on January 1, 2027 and runs through 2036. CMS is finalizing 2027 participants by mid-December; ACOs that execute gap closure, discharge follow-up and care management at scale gain most.
- LEAD offers a Global Risk Option with up to 100% of savings and losses and a Professional Risk Option with up to 50%, and it does not rebase benchmarks during the model.
- On September 21, 2026, CMS named 79 ACOs in the optional, no-risk Implementation Period (September 15 to December 31, 2026), said well over 100 ACOs are preparing for 2027, and expects more application windows for later cohorts.
- LEAD keeps five ACO REACH quality measures, including all-condition readmissions and timely follow-up after acute exacerbations, and phases in two eCQMs later in the model.
- The ACOs best placed for a 10-year model turn care gap and discharge data into completed outreach, visits and follow-up without adding staff at the same rate.
Where LEAD stands (as of November 3, 2026): The first application window closed at 11:59 PM ET on May 17, 2026. On September 21, 2026, CMS named 79 ACOs taking part in LEAD’s optional, no-risk Implementation Period (September 15 to December 31, 2026) and said it is working with well over 100 ACOs preparing for performance year 2027, which ACOs have until mid-December to finalize. CMS will tell ACOs in December 2026 which alignment minimum applies to them and whether they meet it. ACO REACH ends with its 2026 performance year, and LEAD performance year 2027 starts January 1, 2027. CMS’s LEAD FAQ, last updated October 30, 2026, still says CMS anticipates additional application opportunities for later cohorts but gives no dates, so no ACO can apply today. The 47 days in this post’s web address refer to the first window, from the March 31 RFA to the May 17 deadline.
LEAD timeline at a glance
LEAD is a 10-year model, and most of its milestones are still ahead. This is where each one stood on November 3, 2026.
| Date | Milestone | Status on November 3, 2026 |
|---|---|---|
| March 31, 2026 | CMS releases the LEAD Request for Applications (revised April 15, 2026) | Done |
| March 2026 to December 2027 | Medicare-Medicaid integration planning phase, in which CMS selects two states | Under way |
| May 17, 2026 | First application window closes at 11:59 PM ET | Closed; no new window announced |
| September 15 to December 31, 2026 | Optional, no-risk Implementation Period | Under way; 79 ACOs named on September 21 |
| December 2026 | CMS tells ACOs their alignment minimum; ACOs finalize 2027 participation by mid-December | Coming up |
| December 31, 2026 | ACO REACH ends after performance year 2026 | Coming up |
| January 1, 2027 | LEAD performance year 2027 begins; the CARA specialist initiative starts with data sharing | Coming up |
| 2028 | CARA episode accountability begins | Planned |
| By 2029 | Part D premium buy-down available | Planned |
| December 31, 2036 | LEAD performance period ends | Planned |
What Happened — and Why the Clock Is Still Running
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 closed May 17, 2026, 47 days later.
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 did not apply in this window either step back to MSSP — a lower-upside risk arrangement — or sit out value-based care entirely until a later LEAD application window opens. Neither is a good option for organizations that have been building toward full-risk performance.
Every ACO participating in ACO REACH in performance year 2026 had to make this decision before the May 17 deadline.
LEAD vs. ACO REACH: What Actually Changed
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.
A 10-Year Performance Horizon
LEAD runs from January 2027 through December 2036. 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.
Two Risk Tracks With Real Teeth
LEAD offers two participation tracks:
- Global Track: up to 100% shared savings and shared losses. This is the full-risk path for ACOs with mature cost management programs and proven quality performance.
- Professional Track: up to 50% shared savings and losses. ACOs that choose it stay in it for at least four performance years before they can move to Global, and a newly entering ACO that starts in Global can switch to Professional if it is not ready for full risk.
Both tracks are scored on the same quality measure set: five claims and survey measures carried over from ACO REACH, including all-condition readmissions, timely follow-up after acute exacerbations of chronic conditions and the CAHPS survey, plus two eCQMs (controlling high blood pressure and diabetes glycemic status) that start as optional and become required later in the model. These are the same levers that determine whether you generate savings or owe CMS money at reconciliation.
New Financial Structures and Beneficiary Tools
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.
Medicare-Medicaid Integration Planning
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 Infrastructure Problem Most ACOs Aren't Talking About
The LEAD application asked applicants to demonstrate that they can execute — not just that they understand value-based care conceptually. CMS scores applications in five domains (organizational readiness, revenue sources and payment arrangements, beneficiary and caregiver experience, data and health information, and preventive care), and in practice they come down to questions like these:
- Care gap identification and closure: Can you systematically find patients who missed AWVs, screenings, or follow-up care, and actually reach them before the measurement period closes?
- Post-discharge follow-up: Can you prevent readmissions through timely discharge alerts and structured outreach — not a care manager checking a spreadsheet three days after discharge?
- Quality performance at scale: Can you generate HEDIS-level documentation consistently across your entire attributed population, not just during measurement season?
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.
The pattern has been consistent: 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.
What High-Performing ACOs Do Differently
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 a large share 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 follow-up matters most in the first days after a patient leaves the hospital, and Medicare's transitional care management (TCM) rules expect an interactive contact within 2 business days of discharge. An outreach program that triggers on day four or five is operating outside that window. Timely 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: it deployed AI voice agents for AWV scheduling and post-discharge outreach across its provider network, rather than building a proportionally larger care management team. The Palm Beach ACO customer story describes how the program runs.
The same principle applies 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.
The LEAD Readiness Checklist: What to Do Before January 1, 2027
If your organization was accepted into LEAD, or is preparing for a later application window, here is where to focus before performance year 2027 begins:
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 current visibility into claims, clinical events, and quality measure status — not a data warehouse that refreshes quarterly. If your current data infrastructure doesn't support continuous care gap identification, that gap needs to be on your roadmap now.
5. Track CMS guidance as the model takes shape. CMS has said it anticipates additional application opportunities for later cohorts and will announce their timelines through future RFAs or program guidance. That guidance will directly inform strategy for ACOs that did not apply in the first window — particularly around the Medicare-Medicaid integration planning phase, which runs through December 2027.
Where your ACO stands, and what to do before January 1
The right next step depends on where your organization sits today.
| If your ACO is… | Then, before January 1, 2027 |
|---|---|
| Finalizing LEAD participation for 2027, in or outside the Implementation Period | Confirm participation before the mid-December deadline, check the December alignment notice, and have discharge follow-up and wellness visit outreach running on day one. |
| In ACO REACH and not continuing into LEAD for 2027 | REACH ends December 31, 2026. Settle your next arrangement now, keep follow-up and quality work running through the transition, and watch CMS communications for a later LEAD window. |
| An MSSP ACO or new entrant interested in a later cohort | No window is open. Build the record LEAD rewards, with readmission, follow-up and preventive care baselines by practice, so a future application shows results rather than plans. |
The Execution Layer Is the Competitive Advantage
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, prepare documentation, flag escalations to the care team, and feed structured data back into quality and cost tracking — at scale, without requiring a new FTE for every block of 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 first application deadline was May 17. The model starts January 1, 2027. The time left to build the infrastructure that determines your year-one performance is the eight weeks left in 2026.
Frequently asked questions
What is the CMS LEAD Model, and when does it start?
LEAD, the Long-term Enhanced ACO Design Model, is CMS's successor to ACO REACH, which ends December 31, 2026. Its first performance year begins January 1, 2027, and it runs through December 31, 2036 without rebasing benchmarks. It adds CMS-administered episode arrangements with specialists, starting with data sharing in 2027 and episode accountability in 2028, plus a Medicare-Medicaid integration planning phase and a Part D premium buy-down by 2029.
Which ACOs are participating in the LEAD Model?
On September 21, 2026, CMS published the names of 79 ACOs taking part in the optional Implementation Period, which runs from September 15 to December 31, 2026. CMS said it is working with well over 100 ACOs preparing for performance year 2027, that ACOs have until mid-December to finalize participation, and that the list is not exhaustive, because the Implementation Period was optional.
Can an ACO still apply to the LEAD Model?
Not today. The first window closed at 11:59 PM ET on May 17, 2026, and as of November 3, 2026 CMS had not announced a new one. CMS anticipates additional application opportunities for later cohorts and will announce timelines through future RFAs or program guidance. Meanwhile, the ACO programs LEAD rewards, such as TCM, wellness visits and gap closure, can be built now.
What is the difference between LEAD's Global and Professional risk options?
In the Global Risk Option, an ACO can receive up to 100% of savings and is liable for up to 100% of losses against its benchmark. In the Professional Risk Option, the share is up to 50% each way, and an ACO stays in it for at least four performance years before it may move to Global. Professional ACOs must use primary care capitation; Global ACOs choose either that or capitation for all Part A and B services.
What happens to ACO REACH when LEAD starts?
ACO REACH ends after its fourth performance year, on December 31, 2026; CMS lists 74 ACOs in REACH for 2026. LEAD is its successor from January 1, 2027. REACH ACOs that finalize LEAD participation by mid-December move into performance year 2027. Others need another arrangement, such as the Medicare Shared Savings Program, or must wait for a later LEAD cohort, for which CMS has not yet set dates.
Related reading
- The CMS LEAD Model: Why Your ACO's Data Infrastructure Will Decide If You Win
- ACO LEAD Model: Why 2027 Will Reward ACOs That Can Execute Between Visits
- TCM Billing: CPT 99495 vs 99496 Requirements, Timelines and Documentation
Source notes
CMS: Long-term Enhanced ACO Design (LEAD) Model, Request for Applications (revised April 15, 2026). https://www.cms.gov/priorities/innovation/files/lead-rfa.pdf
CMS: LEAD Model frequently asked questions. https://www.cms.gov/priorities/innovation/lead-model-frequently-asked-questions
CMS: LEAD Model Implementation Period participant list (September 21, 2026). https://www.cms.gov/priorities/innovation/files/lead-imp-participant-list.pdf
CMS: ACO REACH Model. https://www.cms.gov/priorities/innovation/innovation-models/aco-reach
CMS Medicare Learning Network: Transitional Care Management Services (MLN908628). https://www.cms.gov/files/document/mln908628-transitional-care-management-services.pdf
About the author
Jay Chowdappa, MD is co-founder and CEO of Zynix AI. He is a physician, and ACOs led by him generated $300M+ in shared savings before he started Zynix AI to help care teams follow through on what their data already shows.