
The Centers for Medicare and Medicaid Services has designed something genuinely new. The Long-Term Enhanced ACO Design model, launching January 1, 2027, runs for ten years — the longest performance period CMS has ever established for an ACO program. For Chief Strategy Officers at provider organizations, this is not an incremental policy update. It is a structural decision point that will shape financial performance through 2036.
The central thesis of this report: the organizations that will capture the most value from LEAD are not those that apply fastest — they are those that fix their infrastructure first.
Four findings drive this conclusion.
First, LEAD's ten-year duration fundamentally changes the calculus of infrastructure investment. Under prior models, the payback period for technology and workflow investments rarely fit within a three-to-four-year program window. A decade changes that math entirely. Investments in risk stratification, care coordination workflows, and longitudinal patient data pay back many times over when the performance period extends through 2036.
Second, the application window is narrower than most ACO leaders realize. The Request for Applications is expected to open in March 2026. Organizations that begin infrastructure assessment now have months, not years, to close readiness gaps before paperwork replaces strategy as the dominant conversation.
Third, the ACO market is already generating record results. ACOs saved Medicare $2.4 billion in 2024, a new record for the Medicare Shared Savings Program. LEAD is designed to accelerate that trajectory — but only for organizations with the data infrastructure to perform under full downside risk.
Fourth, the transition from ACO REACH creates a specific urgency. ACO REACH concludes December 31, 2026, after serving 103 ACOs covering approximately 2.5 million Medicare beneficiaries. Those organizations face a direct continuity decision. The ones that treat the transition as a technology reset — rather than a simple re-enrollment — will enter LEAD with a measurable performance advantage.
The audience for this report is the Chief Strategy Officer at a provider organization actively evaluating LEAD participation. The goal is not to argue for or against applying. It is to make the case that the quality of your infrastructure decision, made in the next 90 days, will determine whether LEAD becomes a margin multiplier or a decade-long liability.
The LEAD model does not exist in isolation. It is the product of five structural forces that have been building simultaneously across the regulatory, demographic, economic, technological, and competitive dimensions of American healthcare. Understanding each force is essential for any strategy officer sizing the opportunity.
CMS has spent fifteen years testing ACO models, iterating on benchmarking methodology, and adjusting risk-sharing parameters. LEAD represents the synthesis of that learning. Its ten-year duration signals something important: CMS is no longer treating value-based care as an experiment. The agency is betting on permanence.
The model's design reflects this. LEAD replaces ACO REACH, which itself replaced the Global and Professional Direct Contracting model. Each iteration has moved in the same direction: more sophisticated benchmarking, more explicit infrastructure requirements, deeper integration with post-acute and long-term care settings, and stronger incentives for organizations that take on full downside risk. LEAD's prospective quarterly payment mechanism — the Enhanced Primary Care Contribution — provides upfront cash flow specifically to fund infrastructure investment. CMS is, in effect, paying organizations to build the capabilities the model requires.
The regulatory timeline is unforgiving. The RFA opens in March 2026, with an application deadline of April 1, 2026 for the first performance period. Rolling applications are accepted through 2033, but the financial advantage accrues to early participants. Organizations that enter in 2027 capture the full ten-year window. Those that wait until 2030 or 2031 are entering a mature competitive market with compressed payback periods.
Exhibit 1: LEAD Regulatory Timeline — Key Dates and Decision Points
| Milestone | Date | Strategic Implication |
|---|---|---|
| ACO REACH ends | December 31, 2026 | 103 ACOs must decide on continuity |
| LEAD RFA opens | March 2026 | Infrastructure assessment must begin now |
| LEAD application deadline (first period) | April 1, 2026 | 90-day window from RFA to application |
| LEAD model launches | January 1, 2027 | Performance clock starts |
| Dual-eligible Medicaid partnership planning | March 2026 to December 2027 | Two states selected; expands LEAD scope |
| Dual-eligible Medicaid partnership launches | 2028 and beyond | Significant population expansion for participating ACOs |
| LEAD model concludes | December 31, 2036 | Full 10-year performance window closes |
| ACCESS Model launches | July 2026 | Parallel AI-enabled payment model; complementary to LEAD |
The numbers behind ACO performance have reached a scale that commands board-level attention. MSSP generated $6.4 billion in gross savings in 2024, with $2.5 billion in net savings to Medicare. Seventy-five percent of MSSP ACOs — 476 organizations — earned performance payments totaling $4.1 billion. ACOs in the Level E and Enhanced tracks generated two-thirds of all savings, accounting for $5.4 billion of $6.6 billion in gross savings. Since 2012, ACO programs have produced $35 billion in gross savings and $13.6 billion in net savings to Medicare.
These are not projections. They are audited results from a program that has been running for over a decade. LEAD, at full scale, will represent more than $10 billion in annual Medicare spending under risk. For strategy officers, the question is not whether value-based care produces financial results. The evidence is settled. The question is whether your organization has the infrastructure to capture its share.
The shared savings rate in MSSP ranges from 40 percent to 75 percent for the 2024 performance year, depending on track. Under LEAD's full downside risk structure, the upside is proportionally significant — but so is the exposure for organizations that underperform. Infrastructure is not a nice-to-have in this environment. It is the mechanism by which risk is managed.
LEAD's explicit focus on high-needs, dual-eligible, and long-term post-acute care populations reflects a demographic reality that strategy officers cannot ignore. The Medicare population is growing in both size and clinical complexity. Dual-eligible beneficiaries — those enrolled in both Medicare and Medicaid — represent a disproportionate share of total cost. LEAD's planned Medicaid partnership, beginning with two states in the 2028-plus timeframe, signals that CMS views dual-eligible management as central to the model's long-term value proposition.
For ACOs, this means that population health infrastructure must be capable of managing across payer lines, not just within Medicare fee-for-service. Data from Medicaid, long-term care facilities, home health agencies, and social services organizations must flow into a single longitudinal record. Organizations that have built this capability will have a structural advantage in LEAD's dual-eligible expansion. Those that have not will face a significant data integration challenge at precisely the moment when the model's financial stakes are highest.
CMS has explicitly identified priority technology use cases for LEAD participants: care navigation, condition management, and population health analytics. The agency's stated intent is to reduce fragmentation and lower barriers to adoption, particularly for provider-led and smaller ACOs that have historically struggled with customization costs and vendor complexity. This is a meaningful signal. CMS is not simply requiring technology adoption — it is actively working to standardize the requirements so that infrastructure investment translates directly into performance.
The technology landscape has matured accordingly. Risk stratification tools that combine clinical, claims, and social determinants of health data are now available at enterprise scale. AI-enabled care gap identification can surface actionable interventions across populations of hundreds of thousands. Automated outreach through phone, SMS, and patient portals can close gaps without proportional increases in care management headcount. The question for strategy officers is not whether these capabilities exist. It is whether your organization has deployed them at the scale LEAD requires.
Exhibit 2: Technology Capability Maturity Model for LEAD Readiness
| Capability Domain | Emerging | Developing | Advanced | LEAD-Ready |
|---|---|---|---|---|
| Data Aggregation | Single EHR source | Multi-EHR, no claims | Clinical + claims integrated | Clinical + claims + SDOH + LTPAC unified |
| Patient Attribution | Manual/claims-only | Semi-automated | Automated with reconciliation | Real-time, multi-payer attribution |
| Risk Stratification | Rule-based, static | Periodic AI scoring | Dynamic AI with clinical signals | Continuous, prospective, SDOH-adjusted |
| Care Gap Identification | HEDIS-only, retrospective | Multi-measure, quarterly | Real-time gap alerts | Automated prioritization across all populations |
| Care Coordination | Phone-based, reactive | Workflow-supported | Protocol-driven with analytics | AI-assisted, proactive, closed-loop |
| LTPAC Integration | None | ADT feeds only | Bi-directional data sharing | Full care coordination with SNF/HH/LTPAC |
| Dual-Eligible Management | Not supported | Medicaid data siloed | Partial integration | Unified Medicare-Medicaid record |
| Financial Modeling | Retrospective only | Annual projections | Scenario modeling | Prospective contract analytics, quarterly |
The ACO market is not static. More than 7,000 community health center service sites participated in MSSP in 2025, an 18 percent increase from the prior year. An additional 1,800 health centers participated in ACO Primary Care Flex and ACO REACH models. The organizations entering LEAD will not be competing only on clinical quality. They will be competing on the speed and precision with which they identify and close care gaps, manage high-risk populations, and demonstrate financial performance against CMS benchmarks.
Demand for healthcare executives with value-based care expertise has grown by nearly 25 percent since 2023, with executive salaries rising 10 to 18 percent year-over-year. The talent market is signaling what the financial market already knows: organizations that have built value-based care infrastructure are worth more, attract better leadership, and generate better results. The competitive gap between infrastructure-ready and infrastructure-deficient ACOs will widen over the next decade. LEAD's ten-year window makes that gap permanent for organizations that enter without the right foundation.
The case for infrastructure investment before LEAD application is not primarily about opportunity. It is about consequence. Strategy officers who delay infrastructure decisions until after the RFA opens will face a specific, quantifiable set of problems — and the compounding effect of those problems over ten years is substantial.
The transition from ACO REACH to LEAD is not a simple re-enrollment. LEAD introduces explicit requirements for LTPAC coordination, dual-eligible management, and prospective payment reconciliation that many current ACO participants have not built into their workflows. The 103 ACOs covering approximately 2.5 million Medicare beneficiaries in ACO REACH for 2025 face a direct continuity decision. Those that treat LEAD as an administrative transition — rather than a capability upgrade — will enter the model with infrastructure gaps that compound over time.
The mechanism is straightforward. Under LEAD's full downside risk structure, performance shortfalls in Year One are not isolated events. They establish the baseline against which subsequent years are measured. An ACO that enters LEAD with inadequate risk stratification will misidentify its highest-cost patients. It will underinvest in the interventions that drive savings. It will generate lower-quality data for CMS benchmarking. And it will carry those deficiencies forward through a ten-year performance period with no opportunity to reset the clock.
Exhibit 3: Cost of Infrastructure Delay — Cumulative Impact Over LEAD's 10-Year Window
| Year | Infrastructure-Ready ACO | Infrastructure-Deficient ACO | Cumulative Gap |
|---|---|---|---|
| 2027 (Year 1) | Baseline performance established on accurate risk data | Misattributed population, incomplete risk picture | Benchmark disadvantage established |
| 2028 (Year 2) | LTPAC integration generating care coordination savings | ADT feeds incomplete, SNF referrals unmanaged | Post-acute cost overruns accumulate |
| 2029-2030 | Dual-eligible expansion captured with unified record | Medicaid data siloed, dual-eligible population underserved | Missed savings in highest-cost cohort |
| 2031-2033 | AI-driven care gap closure at scale, quality bonuses compounding | Manual workflows, care gap closure rates stagnant | Quality performance gap widens |
| 2034-2036 | Decade of performance data supports favorable rebenchmarking | Inconsistent data quality limits negotiating position | Exit position significantly disadvantaged |
LEAD operates under full downside risk for most participating organizations. This is not a theoretical exposure. Under MSSP's Enhanced track — the closest structural analog — ACOs in Level E and Enhanced tracks generated two-thirds of all program savings but also bore the greatest financial risk for underperformance. The organizations that performed best shared a common characteristic: they had invested in population health infrastructure before their performance period began, not during it.
The financial headwinds facing health systems in 2025 through 2027 are well-documented. Hospitals will face margin pressure from tariff impacts, subsidy expirations, and federal policy changes, with EBITDA margins expected to decline by 40 to 100 basis points over this period. For organizations already operating under financial stress, entering LEAD without adequate infrastructure is not a neutral decision. It is a decision to take on downside risk without the tools to manage it.
Building population health infrastructure takes time that the LEAD timeline does not accommodate. Risk stratification models require data normalization, training, and validation. Care management workflows require clinical staff training and protocol development. LTPAC integration requires data sharing agreements with dozens of post-acute partners. None of these can be completed in the weeks between RFA opening and application deadline.
The talent market compounds the challenge. Healthcare executive demand has grown by nearly 25 percent since 2023, with salaries rising 10 to 18 percent year-over-year. Organizations that begin infrastructure work now can recruit and onboard the clinical informatics and population health talent they need at current market rates. Those that wait will compete for the same talent in a tighter market, at higher cost, under greater time pressure.
The organizations that will be positioned to launch successfully in January 2027 are those that begin infrastructure assessment immediately. Those that wait will find themselves managing an infrastructure build and a CMS application simultaneously — a combination that produces neither well.
The ACO market has produced a decade of performance data. The patterns are clear. Organizations that consistently outperform their benchmarks share four strategic behaviors that distinguish them from their peers. Each behavior is available to any ACO that commits to it before the LEAD application window opens.
The single most consequential infrastructure decision an ACO can make is the decision to build a unified longitudinal patient record before its performance period begins. This sounds obvious. In practice, most ACOs operate with clinical data in one system, claims data in another, pharmacy data in a third, and social determinants information either absent or disconnected from clinical workflows.
The consequence is not just operational friction. It is systematic underperformance on the metrics that determine LEAD financial results. Risk stratification models that rely on clinical data alone will miss the patients whose cost trajectory is driven by social factors — housing instability, food insecurity, transportation barriers. Care gap identification that does not incorporate claims data will miss the gaps that occur outside your own network. Attribution models that cannot reconcile multiple data sources will misidentify which patients are actually yours to manage.
Leading organizations have addressed this by building data infrastructure that aggregates clinical, claims, pharmacy, lab, and SDOH data into a single patient record before they begin population health programs. The payoff is measurable. Organizations that have implemented unified data platforms report 40 percent improvements in care gap closure rates. The mechanism is direct: when care managers can see the complete picture of a patient's health status, social circumstances, and utilization history in a single view, they make better decisions faster.
Children's Mercy Hospital illustrates the scale of what unified data infrastructure enables. After building a population health platform capable of aggregating data across 36 clinics, the organization achieved a 79 percent screening rate increase and identified social needs for 16,000 patients — while simultaneously enabling real-time ED visit alerts and intelligent immunization and behavioral screening worklists. The infrastructure investment preceded the clinical results. That sequence is not coincidental.
The shift from retrospective to prospective risk identification is the defining operational change that separates high-performing ACOs from the rest. Retrospective analysis tells you which patients were expensive last year. Prospective stratification tells you which patients are becoming expensive now — before the hospitalization, before the ED visit, before the cost has already been incurred.
This distinction matters enormously under LEAD's full downside risk structure. An ACO that identifies a patient's deteriorating trajectory six months before a preventable hospitalization has time to intervene. An ACO that identifies the same patient after the hospitalization has only the opportunity to manage the discharge. The financial difference between these two scenarios, multiplied across a population of tens of thousands of attributed lives, is the difference between shared savings and shared losses.
CMS's own risk model changes reinforce this imperative. Prospective coding is now required for accurate Risk Adjustment Factor scores — retrospective chart review alone is no longer sufficient. This is not a technology preference. It is a regulatory requirement with direct financial consequences for organizations that have not built prospective coding workflows.
Leading organizations have responded by deploying AI-enabled risk stratification that combines clinical signals, claims data, and SDOH factors to identify rising-risk patients before they cross into high-cost territory. The results are significant. AI risk stratification has produced a 30 percent reduction in high-cost patient identification lag — meaning organizations find their highest-risk patients 30 percent faster than with traditional methods. At population scale, that speed advantage translates directly into intervention time and cost avoidance.
PSW, a population health organization managing 400,000 lives, demonstrates what prospective risk stratification enables at scale. By deploying targeted interventions driven by AI risk identification, PSW achieved a 16.7 percent reduction in skilled nursing facility utilization and a 12 percent reduction in avoidable emergency department visits. These are not marginal improvements. They represent multi-million-dollar ROI from a single operational change in how the organization identifies and prioritizes its highest-risk patients.
Exhibit 4: Risk Stratification Impact — From Identification Lag to Intervention Speed
| Stratification Approach | Identification Lag | Intervention Window | Financial Outcome |
|---|---|---|---|
| Retrospective claims review | 60-90 days after event | Post-event management only | Cost already incurred |
| Periodic AI scoring (quarterly) | 30-45 days before event | Limited intervention window | Partial cost avoidance |
| Continuous AI with clinical signals | 7-14 days before event | Full intervention window | Maximum cost avoidance |
| Prospective AI with SDOH integration | 30-90 days before event | Preventive intervention possible | Highest ROI per patient |
| LEAD-required standard | Prospective, ongoing | Continuous | Full downside risk management |
LEAD's explicit focus on long-term and post-acute care coordination is the model's most operationally demanding requirement — and the one that most current ACO participants are least prepared to meet. The model creates direct incentives for coordinating with skilled nursing facilities, home health agencies, and other LTPAC providers. Organizations that have not built data-sharing relationships and care coordination workflows with their LTPAC partners before LEAD launches will face a significant performance gap in the model's earliest years.
The financial logic is straightforward. Post-acute care represents a disproportionate share of total Medicare spending for high-acuity populations. Patients discharged to skilled nursing facilities without active care coordination from their ACO are at elevated risk for readmission, prolonged stays, and unnecessary utilization. ACOs that can track their patients through the post-acute episode — receiving real-time ADT notifications, coordinating care plans with SNF clinical teams, and managing transitions back to the community — consistently outperform those that lose visibility at the hospital discharge.
The infrastructure requirements for LTPAC integration are specific. ACOs need bi-directional data sharing agreements with their primary SNF and home health partners. They need ADT notification workflows that trigger care manager outreach within hours of a post-acute admission, not days. They need care plan documentation that travels with the patient across settings. And they need performance analytics that measure outcomes at the SNF level, so that ACOs can direct referrals to partners that produce better results.
Organizations that have built these capabilities report meaningful reductions in readmission rates. Across Atlas-managed populations, readmission rates have declined by 15.8 percent — a result that reflects the combined effect of better risk identification, more effective care coordination, and tighter LTPAC integration. For LEAD participants managing high-needs populations with significant post-acute utilization, this level of readmission reduction represents substantial financial performance improvement.
LEAD's full downside risk structure requires ACOs to understand their financial exposure with precision before they enter the model. This is not a task for a spreadsheet. It requires actuarial-grade financial modeling that incorporates historical spending patterns, population risk profiles, benchmark projections, and scenario analysis for different performance outcomes.
Organizations that have modeled their LEAD economics before applying will make better decisions about which patient populations to prioritize, which infrastructure investments to make first, and what level of performance is required to generate shared savings rather than shared losses. Those that enter the model without this analysis are effectively committing to a decade of financial risk without understanding the magnitude of that commitment.
The financial modeling challenge is compounded by LEAD's novel benchmarking methodology. Unlike MSSP, which uses historical spending with trend adjustments, LEAD is designed to support longer-term planning with benchmarks that do not require annual rebasing. This is a significant advantage for organizations that enter with strong performance data — and a significant risk for organizations that enter with incomplete or inaccurate historical data. The quality of your data today will determine the quality of your benchmark tomorrow.
Leading organizations are addressing this by deploying actuarial intelligence tools that combine comprehensive national Medicare and Medicaid claims datasets with financial modeling capabilities. The goal is not to predict the future with certainty. It is to understand the range of financial outcomes under different performance scenarios — and to make infrastructure investment decisions that shift the probability distribution toward the favorable end of that range.
The infrastructure required for LEAD success is not a single technology purchase. It is a coordinated set of capabilities that must be built, integrated, and validated before the performance period begins. The following framework organizes that work into three phases, each with specific deliverables and a clear connection to LEAD performance requirements.
Exhibit 5: LEAD Infrastructure Readiness Framework — Three-Phase Approach
| Phase | Timeline | Focus | Key Deliverables | LEAD Performance Connection |
|---|---|---|---|---|
| Phase 1: Foundation | Now through RFA opening (March 2026) | Data unification and population assessment | Unified patient record, attribution validation, baseline risk stratification | Accurate benchmark establishment, population identification |
| Phase 2: Capability Build | RFA opening through LEAD launch (January 2027) | Workflow deployment and LTPAC integration | Care management protocols, ADT workflows, SNF data sharing, dual-eligible identification | Year 1 performance, post-acute cost management |
| Phase 3: Optimization | Year 1 through Year 3 of LEAD (2027-2029) | AI-driven performance improvement | Prospective risk stratification at scale, automated care gap closure, financial modeling refinement | Compounding savings, quality bonus capture, benchmark positioning |
The foundation phase has one non-negotiable requirement: every patient attributed to your ACO must be visible in a single longitudinal record that combines clinical, claims, and SDOH data. This is the prerequisite for every other capability in the framework. Without it, risk stratification is incomplete, care gap identification is unreliable, and financial modeling is built on partial information.
The practical work of this phase includes establishing data sharing agreements with all payer partners, deploying EHR connectors that normalize clinical data across your network, integrating claims feeds for attributed Medicare beneficiaries, and adding SDOH screening data to the patient record. For organizations with multiple EHR systems — common in health systems that have grown through acquisition — this requires a data aggregation layer that can reconcile patient records across systems without requiring EHR replacement.
The category requirement here is a healthcare-specific data platform with pre-built connectors for major EHR systems, payer data feeds, and SDOH sources. Generic data warehousing tools are not adequate for this purpose. The data normalization requirements for clinical data — reconciling medication lists, problem lists, and lab values across different EHR coding conventions — require healthcare-specific data quality rules at scale. Innovaccer's platform, for reference, applies more than 6,000 data quality rules across 400-plus pre-built EHR and data connectors, supporting more than 54 million unified patient records. That scale of data quality infrastructure is what the foundation phase requires.
The capability build phase translates unified data into operational workflows. This is where the infrastructure investment becomes visible to clinical staff. Care managers need worklists that surface the right patients at the right time, with the right context for intervention. Physicians need alerts that are specific enough to act on, not generic enough to ignore. Post-acute partners need data sharing arrangements that give them visibility into the ACO's care plans for their shared patients.
The LTPAC integration work deserves specific attention because it is the most time-consuming element of this phase. Establishing bi-directional data sharing with SNF and home health partners requires individual data sharing agreements, interface development, and workflow training on both sides of the relationship. Organizations that begin this work after the RFA opens will not complete it before LEAD launches. The lead time is measured in months, not weeks.
The care management workflow component requires equal attention. LEAD's focus on high-needs and homebound populations means that care management protocols must be designed for patients with complex, multi-morbid conditions and significant social risk factors. Protocols built for a simpler MSSP population will not be adequate. Organizations need to assess their current care management capacity, identify the gaps between current protocols and LEAD population requirements, and build or acquire the workflow tools to close those gaps before January 2027.
The optimization phase begins at LEAD launch and continues through the first three years of the performance period. This is where organizations that have built the right foundation begin to separate from those that have not. AI-driven risk stratification, automated care gap closure, and prospective financial modeling compound over time. Each year of performance data improves the accuracy of risk models, the precision of care gap identification, and the reliability of financial projections.
The category requirement for this phase is an AI-enabled population health platform that can operate at the scale of LEAD's attributed population — potentially tens of thousands of Medicare beneficiaries — with the clinical specificity required for high-needs and dual-eligible patients. The platform must support HEDIS, MSSP, and ACO measure libraries out of the box, because building custom measure specifications from scratch is a significant time and resource investment that most organizations cannot afford during an active performance period.
The financial modeling component of this phase is equally important. LEAD's ten-year duration means that organizations need ongoing visibility into their trajectory against CMS benchmarks, not just end-of-year reconciliation. Quarterly financial modeling that incorporates actual performance data, updated risk profiles, and scenario analysis for the remainder of the performance period gives strategy officers the information they need to make mid-course corrections before they become financial problems.
The LEAD model is, at its core, a strategic positioning decision. The ten-year performance window means that the infrastructure choices made in the next 90 days will shape your organization's competitive position through 2036. Your immediate priority is a gap assessment: where does your current population health infrastructure stand against the LEAD readiness framework, and what is the realistic timeline to close the gaps before January 2027?
The strategic question is not whether to apply for LEAD. It is whether to apply in the first cohort, with the infrastructure required to perform, or to wait for a later cohort while competitors establish their benchmark positions. The financial advantage of early entry — a full ten-year performance window, favorable benchmark establishment, and compounding quality performance — is significant. The risk of early entry without adequate infrastructure is equally significant. Your 90-day priority is to get honest about which side of that equation your organization currently sits on.
The clinical implications of LEAD center on two populations that your current workflows may not adequately serve: high-needs patients with complex multi-morbid conditions, and dual-eligible beneficiaries whose care spans Medicare and Medicaid. LEAD's explicit focus on these populations means that clinical protocols, care management capacity, and LTPAC coordination workflows must be designed for complexity, not average acuity.
Your 90-day priority is a clinical workflow assessment: can your care management team identify, reach, and effectively manage the highest-risk patients in your attributed population? Do your protocols address the social risk factors that drive utilization for dual-eligible patients? Do you have the LTPAC relationships and data sharing arrangements to coordinate care across the post-acute episode? The answers to these questions will determine whether your clinical infrastructure is ready for LEAD's performance requirements.
LEAD's data requirements are the most technically demanding in the history of CMS ACO programs. A unified longitudinal patient record that combines clinical, claims, SDOH, and LTPAC data is not optional — it is the foundation on which every other LEAD capability is built. Your 90-day priority is a data infrastructure assessment: how many of your attributed patients have complete records that combine all four data types, and what is the gap between that number and your total attributed population?
The technology investment required to close this gap is significant but well-defined. Healthcare-specific data platforms with pre-built EHR connectors, payer data integration, and SDOH data sources can accelerate the data unification timeline substantially compared to custom-built solutions. The make-versus-buy decision for this infrastructure should be made before the RFA opens, not after.
LEAD's full downside risk structure requires financial modeling that most ACO finance teams have not built. The ten-year performance period means that financial exposure is not a single-year calculation — it is a decade-long commitment that must be modeled under multiple performance scenarios. Your 90-day priority is a financial risk assessment: what is your organization's downside exposure under LEAD if performance falls short of benchmark, and what infrastructure investments are required to bring that exposure within acceptable bounds?
The Enhanced Primary Care Contribution — LEAD's upfront cash flow mechanism — provides capital specifically for infrastructure investment. Understanding how to deploy that capital effectively requires knowing, before you apply, exactly which infrastructure gaps need to be closed and what each investment will cost. Organizations that have done this analysis before applying will make better use of EPCC funding than those that receive it without a plan.
Exhibit 6: 90-Day Action Plan by Stakeholder Role
| Role | Priority Assessment | Key Decision | Resource Requirement |
|---|---|---|---|
| Chief Strategy Officer | LEAD readiness gap analysis vs. framework | Apply in first cohort vs. later cohort | External advisory support, peer benchmarking |
| Chief Medical Officer | Clinical workflow and care management capacity assessment | Protocol redesign for high-needs and dual-eligible populations | Clinical informatics, care management leadership |
| Chief Information Officer | Data infrastructure completeness assessment | Build vs. buy for unified patient record platform | Technology evaluation, vendor selection |
| Chief Financial Officer | Downside risk modeling under LEAD scenarios | Infrastructure investment prioritization | Actuarial modeling, financial analytics |
| VP Value-Based Care | LTPAC partnership and data sharing assessment | SNF/HH data sharing agreement prioritization | Partnership development, interface build |
The LEAD model is the most consequential value-based care decision most ACO leaders will face in this decade. Its ten-year performance window is genuinely unprecedented in CMS program history — and that duration is precisely what makes the infrastructure decision so important. A three-year model forgives infrastructure gaps that a ten-year model compounds into permanent competitive disadvantages.
The central argument of this report is simple: the organizations that will capture the most value from LEAD are those that treat the period between now and the March 2026 RFA opening as an infrastructure sprint, not an administrative waiting period. The gap assessment, the data unification work, the LTPAC integration, the financial modeling — none of this can be done in the weeks between RFA opening and application deadline. It must be done now.
The evidence from a decade of ACO program performance is consistent. Organizations that invest in population health infrastructure before their performance period begins outperform those that build infrastructure during an active performance period. The mechanism is not complicated: better data produces better risk identification, which produces better interventions, which produces better financial results. LEAD's ten-year window means that this compounding effect operates at a scale no prior CMS model has ever tested.
For strategy officers evaluating LEAD participation, the forward-looking question is not whether value-based care will be central to your organization's financial future. The ACO program's record of $35 billion in gross savings since 2012 has settled that question. The question is whether your organization will be positioned to capture its share of the next decade's value — or whether it will spend ten years managing the consequences of an infrastructure decision made under time pressure in early 2026.
The window to make that decision well is open now. It will not stay open long.
1. Centers for Medicare and Medicaid Services. "Long-Term Enhanced ACO Design (LEAD) Model." CMS Innovation Center. Program parameters confirmed for January 1, 2027 launch through December 31, 2036.
2. Centers for Medicare and Medicaid Services. "Medicare Shared Savings Program 2024 Performance Year Results." CMS.gov. ACOs saved Medicare $2.4 billion in 2024; $6.4 billion gross savings; $2.5 billion net savings; 476 ACOs earned performance payments totaling $4.1 billion.
3. Centers for Medicare and Medicaid Services. "ACO REACH Model Participation Data 2025." 103 ACOs covering approximately 2.5 million Medicare beneficiaries enrolled for 2025 performance year.
4. Centers for Medicare and Medicaid Services. "Medicare Shared Savings Program Historical Results." Cumulative gross savings of $35 billion and net savings of $13.6 billion since 2012.
5. Centers for Medicare and Medicaid Services. "ACO REACH Model Conclusion." Program concludes December 31, 2026 after running from 2023 through 2026.
6. Centers for Medicare and Medicaid Services. "ACCESS Model Announcement." December 2025. Model launches July 2026 as a 10-year voluntary, outcome-aligned payment model for AI-enabled solutions.
7. Centers for Medicare and Medicaid Services. "LEAD Model Application Timeline." Request for Applications expected March 2026; application deadline April 1, 2026 for first performance period; rolling applications accepted through 2033.
8. Centers for Medicare and Medicaid Services. "LEAD Model Dual-Eligible Medicaid Partnership." Planning phase March 2026 through December 2027; two states selected for initial partnership; program expansion 2028 and beyond.
9. Centers for Medicare and Medicaid Services. "MSSP Shared Savings Rate Structure 2024." Shared savings rates range from 40 percent to 75 percent depending on track for 2024 performance year.
10. Centers for Medicare and Medicaid Services. "Community Health Center MSSP Participation 2025." More than 7,000 CHC service sites participated in MSSP in 2025, an 18 percent increase from the prior year; 1,800 additional health centers in ACO Primary Care Flex and ACO REACH models.
11. Innovaccer. "Atlas Population Health Platform." Key outcomes: 15.8 percent readmission reduction across Atlas-managed populations; $11 billion-plus at-risk revenue actively managed on Atlas platform. Published 2025-2026.
12. Innovaccer. "PSW Customer Story." 16.7 percent reduction in SNF utilization; 12 percent reduction in avoidable ED visits across 400,000 lives managed on Atlas platform.
13. Innovaccer. "Children's Mercy Customer Story." 36 clinics onboarded in one year; 79 percent screening rate increase; 16,000 patients with identified social needs.
14. Innovaccer. "Population Health and Risk Theme Metrics." 40 percent improvement in care gap closure rates with unified data; 30 percent reduction in high-cost patient identification lag with AI risk stratification. Verified internal metrics.
15. Innovaccer. "KLAS Award 2026." Number 1 Data Analytics Platform for Providers and Payers; Best in KLAS 2026 for Population Health Management.
16. Addison Group, Definitive Healthcare, and IMS People. "Healthcare Executive Demand Report." Healthcare executive demand has grown by nearly 25 percent since 2023; executive salaries rising 10 to 18 percent year-over-year. [NEEDS VERIFICATION — cited from research context as attributed to these sources.]
17. Hospital financial analysis. "EBITDA Margin Projections 2025-2027." Hospitals expected to face 40 to 100 basis point EBITDA margin reduction from tariff impacts, subsidy expirations, and federal policy changes. [NEEDS VERIFICATION — cited from research context as directional.]
18. NAACOS and Innovaccer. "Value-Based Care Survey 2025." 64 percent of healthcare leaders expect revenue gains from value-based care in 2025.
Innovaccer is the Agentic Cloud for Healthcare, unifying data and deploying AI agents across clinical, operational, and financial workflows. The Atlas population health platform manages more than $11 billion in at-risk revenue and supports HEDIS, MSSP, and ACO measure libraries out of the box. Innovaccer holds the number one KLAS ranking for Data Analytics for both providers and payers in 2026, and its unified patient records touch 1 in 6 Americans. To assess your organization's LEAD readiness, schedule a consultation at innovaccer.com/request-a-demo-in.