LEAD Model Overview

CMS has provided more details on the Long-term Enhanced ACO Design (LEAD) Model, its successor model to ACO REACH. NAACOS has slides from the webinar available, and key details are highlighted below. We expect that the model Request for Applications will be released by mid-April.

Model overview

  • The model has 3 overall goals—including more small, rural, independent practices, and Community Health Centers; promoting evidence-based prevention including high needs and duals; empowering patients
  • 10-year participation window:
    • NAACOS appreciates the recognition that providers need time to make changes; however, challenges in other models were due to changes implemented during the participation window. We’ll continue to encourage CMMI to retain stable, predictable model parameters.
    • CMMI noted they will likely have additional application windows, but that certain model parameters or eligibility requirements might change depending on how the model is progressing, so they encourage interested parties to apply for the first cohort.
  • Win—High needs beneficiaries will be treated as a distinct population type for all LEAD ACOs, with its own benchmark and trend factor, and concurrent risk adjustment. This is something NAACOS has specifically recommended to CMMI.
    • All ACOs will benefit from this
    • ACOs with greater than 40% of aligned population as high needs and certain capabilities will qualify for lower beneficiary alignment minimums
  • Medicaid Integration—CMMI will identify 2 partner states and test Medicaid-based alignment (ideally one FFS Medicaid state and one managed care state)
  • Participation requirements:
    • Full-TIN participation for participant providers, not NPI
    • Preferred providers at NPI level
  • Alignment—claims-based and voluntary
    • Prospective (no alignment updates during the PY)
    • Hybrid (monthly updates to voluntary alignment and allows one mid-year update to claims-based alignment for newld added participant TINs)
  • All existing Benefit Enhancements/Beneficiary Engagement Incentives from REACH, plus some additional:
    • Tailored Part B cost-sharing support
    • Chronic disease prevention reward—healthy food products to beneficiaries
    • Part D premium reductions starting in 2029
    • Tech Enabler option—standardized business requirements for certain technology use cases; designed to support smaller ACOs in utilizing high-value technologies
  • Quality
    • 4 claims measures (same as from REACH), CAHPS, and 2 eCQMs (A1c poor control and BP control)
      • The eCQMs will be optional for first two years, pay-for-reporting next two years, and required starting model year 5. By phasing in eCQMs, CMS is acknowledging the additional challenges ACOs face in aggregating data across disparate health record systems to report eCQMs.
    • Similar to REACH, there will be a high performers pool (HPP); continuous improvement/sustained exceptional performance (CI/SEP); quality withhold of 3%
    • Prevention and quality plan

Payment overview

  • Risk sharing options—Similar to REACH; Global (100%) and Professional (50%)
    • Win—Benchmarks not rebased for the full 10-year performance period! Model begins with historical benchmarks similar to MSSP. Second half of the model moves to a ratebook approach
    • There will be a 4-year lock in period for those who select Professional risk sharing
    • Global option will include a discount, but CMMI didn’t indicate what the benchmark discount will be; allows more capitation options
    • Positive-only regional efficiency adjustments and prior savings adjustment, similar to MSSP
    • National/regional trend factors, with prospective growth factor with guardrails
  • Capitated payments: primary care capitation (PCC), total care capitation (TCC); similar to REACH
    • Advanced payment option (reconciled against FFS billing)
    • Non-primary care capitation option (reconciled only against TCOC)
    • Add-on capitation payments; only for those with higher spending relative to peers to encourage more participation
  • CARAs (CMS Administered Risk Arrangements)
    • Episode-based cost models, intended to better engage specialists
    • Episode-based falls prevention to boost independence at home; features time-limited HCBS

Additional LEAD Model resources:

NAACOS Resources:

CMS Resources: