NAACOS Welcomes New Details on LEAD Model and is Encouraged by CMS Actions to Address Fraud
Statement from Emily Brower, president and chief executive officer, the National Association of ACOs
WASHINGTON (March 31, 2026) – The National Association of ACOs (NAACOS) applauds the Centers for Medicare and Medicaid Services (CMS) for bringing novel innovation into the LEAD (Long-term Enhanced ACO Design) Model. New details, released today as part of the model’s Request for Applications, demonstrate CMS’ commitment to advancing care transformation and value-based care.
Specifically, features such as flexible cash flow payments, nesting bundled payments within the ACO, beneficiary engagement incentives, improved approaches for high needs beneficiaries, and testing new risk adjustment approaches, will provide accountable care organizations with greater freedom and tools to allow providers to focus on meeting patients’ needs. Importantly, the benchmarking methodology outlines an approach that reflects the financial realities organizations face in participating in accountable care. We urge CMS to include similar protections for ACOs participating in Medicare Shared Savings Program, so providers are not penalized by the inaccurate Accountable Care Prospective Trend.
Additionally, we are encouraged that CMS is working to safeguard accountable care providersfrom the financial fallout of fraud, waste, and abuse in Medicare. Accountable care organizations are on the front lines of identifying and addressing fraud, waste, and abuse in health care, but they are also financially accountable for costs associated with fraud, waste, and abuse when spending exceeds financial benchmarks. Today’s actions by CMS will ensure all ACOs are not held accountable for fraudulent activity for urinary catheters, alginate dress, and orthotics, as well as ensuring REACH ACOs are held harmless for flagrantly abusive skin substitute billing for Performance Year 2025. These changes will help ensure accountable care organizations remain viable and can continue to serve as valued partners in the fight against fraud, waste, and abuse.
NAACOS and our members are committed to improving seniors’ health outcomes and sustaining robust provider-led health care transformation and stand ready to partner with CMS to ensure the success of the LEAD Model as well as continued success for providers in existing ACO models.
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About NAACOS. The National Association of ACOs (NAACOS) is a member-led and member-governed nonprofit of more than 500 ACOs and value-based care entities in Medicare, Medicaid, and commercial insurance working on behalf of physicians, health systems, and other providers across the nation to improve quality of care for patients and reduce health care cost. NAACOS represents more than 10 million beneficiary lives through Medicare’s population health-focused payment and delivery models.