The newly announced Long-term Enhanced ACO Design (LEAD) Model, details of which were released in the Request for Applications (RFA) on March 31, 2026, represents CMS’ commitment to design a more stable and inclusive framework to expand participation and advance accountability for cost and quality. For organizations considering ACO participation for Performance Year (PY) 2027, it is critical to understand the key success factors that differentiate LEAD from MSSP and ACO REACH.
Organizations have until May 17, 2026 to respond to the RFA, so it is critical to chart out an ACO strategy today. ACO REACH participants in PY-2026 are eligible to submit an abbreviated application. In addition, organizations interested in future cohorts will have an opportunity to submit a standardized Letter of Interest (LOI), which CMS expects to release no later than April 20, 2026.
In One Sentence Each
- MSSP – The broad, flexible entry point into value‑based care for original FFS Medicare.
- ACO REACH – The full‑risk, equity‑focused model for advanced organizations.
- LEAD – CMS’s next‑generation, capitation‑driven, specialist‑integrated, high‑needs‑focused ACO model.
Below is a table summarizing the key differences between the models:
| LEAD | MSSP | ACO REACH | |
| Model Purpose and Overview | CMS’s next generation, 10-year primary care centric model with capitation, specialist integration, and high needs focus
Professional and Global Risk Options No AHEAD overlap allowed (except primary care AHEAD in certain circumstances) |
Foundational Medicare ACO program; broad entry point into value-based care
Basic (Levels A-E) to Enhanced track, each with greater downside risk AHEAD overlap allowed |
Advanced, full risk model focused on health equity, capitation, and care redesign
Professional and Global Risk Options |
| Model Length | 10-years (2027-2036) | Permanent | Time-limited (PY-2026 is final participation year) |
| Risk-Sharing Options | No AHEAD overlap allowed (except primary care AHEAD in certain circumstances) | Upside-only → partial → full (Track A → ENHANCED) | Professional (partial) or Global (full) |
| Payment Model | |||
| Core Payment | Capitation-first (PCC, TCC, NPCC) | FFS + shared savings/losses | Capitation (PCC/TCC) + risk |
| Upfront Payments | Advanced Payment Option (APO)
Administrative add-on (Higher-spending ACOs) |
Advanced Infrastructure Payment (AIP) | Optional advanced payments |
| Specialist Alignment Options | CARA episodes (CMS‑run specialist risk) | None | Optional downstream arrangements |
| Cash Flow | Prospective monthly payments | Retrospective | Prospective |
| Benchmarking | |||
| Method | Historical – incorporates new methodology with stability protections | Historical + regional blend | Historical + regional + risk |
| Rebasing | No rebasing for duration of ACO participation in the model | Every new agreement period (5 years) | Not rebased over four-year model term |
| Growth Rate (Trending) | More favorable, creates “wedge” for savings
ACPT guardrail |
National/regional | Model-specific |
| High Needs Risk Adjustment | Integrated throughout | Minimal | Present – separate for “High Needs” ACOs |
| Regional Penalty | Reduced | Significant | Minimal |
| Discounts | Present (Global risk only)
Retention incentive (2%) |
Not present | Present |
| Beneficiary Alignment | |||
| Method | Prospective and hybrid
Hybrid alignment: two opportunities – before start of PY and mid-year – to add Participant TINs for claims-based alignment |
Prospective or retrospective
No mid-year additions for prospective alignment |
Prospective only
Annual basis; no mid-year additions |
| Voluntary Alignment | Very strong; key strategy (monthly if Hybrid) | Allowed | Strong (quarterly) |
| TIN Alignment | No TIN shuffling across LEAD ACOs affiliated with same convener within 3 PYs | Whole TIN approach | TIN + NPI split allowed |
| High Needs Flexibility | Integrated across entire model | None | Separate High Needs track |
| Thresholds |
Alignment buffer offered if within 10% below alignment minimums |
5,000 attributed lives minimum for participation | 5,000 attributed lives for New Entrant ACOs; 1,250 for High Needs ACOs |
| Specialist Alignment | CARA episodes: CMS‑administered specialist risk, including new falls‑prevention episode (Global track only) | Minimal; no structured risk model | Optional downstream arrangements |
| High Needs Beneficiaries | High‑Needs policies integrated across the entire model (alignment, risk, benchmark, care delivery) | Limited focus | Dedicated High Needs track |
| Care Delivery Requirements | |||
| 24/7 Access | Required | Encouraged | Required |
| Home‑Based Care | Required for High‑Needs | Optional | Required for High‑Needs |
| Advanced Care Planning | Required | Encouraged | Required |
| Healthy Living Strategy | Core program pillar offering Benefit Enhancements and Beneficiary Engagement Incentives, among other initiatives (Tech Enabler Initiative and Prevention and Quality Plan requirement) | None | None |
| Waivers |
|
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| Quality | Claims-based and CAHPS, 3% withhold
Phases in two (2) new quality measures on top of ACO REACH core measures (eCQMs) – optional for PYs 1 and 2, pay for reporting for PYs 3 and 4, pay for performance in PY5-10 |
Claims-based, CAHPS and clinical measures
Larger scale reporting (eCQM/MIPS) |
Claims-based, CAHPS and clinical measures, 5% withhold in PY-2026
Five (5) core quality measures |
| Administrative Complexity | Very high; capitation, CARA, High-Needs care, prevention, data integration | Moderate; accessible to most groups | High; requires advanced capabilities |
| Model Overlaps | CMS prohibits simultaneous participation between LEAD and MSSP at the TIN level. | Current ACO Reach participants will have an abridged application for LEAD | |
| Application Timeline | May 17, 2026 deadline for PY 2027 applicants | June 9, 2026 – June 23, 2026 for Phase I Submission for PY-2027 applicants | Model sunsetting end of PY-2026 |
How COPE Health Solutions Can Help
Organizations should assess where they fall along the value-based care maturity spectrum and choose the model that fits best. Given LEAD’s requirement to take some level of downside risk upon entry, participation in the program will require thoughtful preparation across several areas. Organizations should evaluate:
- Financial readiness, including the ability to manage downside risk from the get-go and model performance under new benchmarking methodologies
- Operational capabilities, such as care coordination, population health management, and high-needs patient engagement
- Data and technology infrastructure, including readiness for evolving quality reporting requirements
- Governance and compliance structures, aligned with CMS expectations for ACO oversight and accountability
COPE Health Solutions supports clients across the full lifecycle of ACO participation, including:
- Strategic advisory to decide best fit model for your organization and at key decision deadlines throughout 2026
- Financial assessments and scenario modeling to evaluate performance under various tracks and capitation/quality decisions in each model
- Network development, funds flow and provider recruitment/relations, including specialist integration, to establish strong ACO governance and provider alignment
- Care model design, build and/or configuration to service a High Needs population, including home-based primary care
- Quality/HCC gap closure to meet model goals of true prevention
- Data integration and real-time analytics
- Business and operational readiness evaluations aligned with CMS application criteria
- Implementation and ongoing ACO operations and compliance support to maximize performance
With the LEAD application window already underway, organizations should act now to assess their readiness and define their path forward; those interested in a PY 2027 start with LEAD should begin readiness assessments and applications immediately. COPE Health Solutions is ready to support your journey into the next generation of accountable care.
Contact info@copehealthsolutions.com to schedule a briefing to get started.