For most of the past decade, ACO leaders have planned in short increments. Models changed every few years, benchmarks were rebased just as savings started to show, and investments in care management had to pay back before the rules moved again. The Long-term Enhanced ACO Design (LEAD) model, which the CMS Innovation Center announced in December 2025 as the successor to ACO REACH, changes that planning horizon. LEAD is scheduled to run from January 1, 2027 through December 31, 2036, the longest performance period CMMI has tested, and its benchmarks are designed to avoid the periodic rebasing that has eroded savings in earlier models.

ACO REACH ends on December 31, 2026. More than 100 ACOs currently participate, and every one of them now faces a decision about what comes next. Many details, including the full financial methodology and application terms, are expected with the Request for Applications that CMS has signaled for March 2026. But the core design is public, and it is enough to start reshaping strategy now.

What CMS Has Announced So Far

Based on CMS materials and early coverage, the main elements are:

  • A ten-year performance period starting January 1, 2027, with a direct transition path for REACH participants.
  • Two voluntary risk options: Global risk, with up to 100% of shared savings and losses, and Professional risk, with up to 50%.
  • A benchmarking approach without rebasing across the model period, intended to create a path to long-term, sustainable savings rather than a ratchet that resets each time an ACO succeeds.
  • Prospective, population-based payments, including flexible capitated options that let ACOs contract with downstream providers in value-based arrangements.
  • CMS-Administered Risk Arrangements (CARA), a mechanism for episode-based arrangements with specialists and a falls prevention program.
  • Stronger accommodation of high-needs patients through improved risk adjustment, so that complex patients are brought into the ACO rather than handled on a separate track.
  • Beneficiary enhancements, including Part B cost-sharing support and a Part D premium buy-down by 2029.
  • Medicaid integration planning with two states between March 2026 and December 2027, focused on dually eligible beneficiaries.
  • Lower barriers for rural, small and independent practices, including tailored payment options.

Why a Benchmark That Does Not Reset Changes the Math

Rebasing is the quiet tax on success in shared savings programs. When an ACO lowers spending, a rebased benchmark eventually absorbs those lower costs, and the organization ends up competing against its own past performance. That dynamic pushes ACOs toward quick wins (post-acute steerage, site-of-service shifts, readmission programs) and away from investments whose returns arrive in years four through eight, such as chronic disease management, behavioral health integration and early intervention for rising-risk patients.

A benchmark that is not rebased over ten years reverses that incentive. Savings generated in year three continue to count in year nine. That makes the net present value of slow-payback programs far more attractive, and it changes how a CFO should evaluate care management spending. A program that breaks even in year two under a three-year model might return several multiples of its cost over a decade.

The trade-off is exposure. A fixed baseline also means that early mistakes, such as poorly documented risk, weak attribution management or an underperforming network, are carried for longer. CMS has said it will improve risk adjustment, particularly for high-needs patients, but has not yet published the full methodology. Until it does, ACOs should assume that accurate, defensible documentation of patient complexity will matter more, not less.

Implications for Care Management Investment

A ten-year horizon rewards organizations that build durable care management capability rather than rented, episodic programs. Three shifts follow:

  1. Fund rising-risk programs, not just high-cost outreach. The patients who will drive costs in 2030 are largely identifiable today. Stratification that combines clinical risk, utilization history and social drivers of health becomes a long-term asset.
  2. Treat care manager capacity as infrastructure. Under a short model, hiring is a variable cost tied to contract risk. Under LEAD, the productivity of each care manager compounds over a decade. Reducing documentation and administrative load has a long tail of return.
  3. Plan for specialist and episode arrangements. CARA suggests CMS wants ACOs to share accountability with specialists. That requires data flows, referral tracking and shared care plans that most primary care-led ACOs do not yet have.

Implications for Data Infrastructure

REACH participants learned that benchmark accuracy, attribution and risk scores depend on the quality of data flowing through the organization. LEAD raises the stakes because the consequences last longer. Organizations should evaluate whether they can:

  • Calculate patient-level risk scores under the current CMS-HCC model and reconcile them against CMS reports.
  • Track documentation completeness for chronic conditions annually, at the encounter level, without relying on year-end retrospective sweeps.
  • Monitor attribution shifts and leakage monthly rather than at reconciliation.
  • Exchange care plans and episode data with specialists and community partners.
  • Integrate Medicaid and social needs data for dually eligible members, particularly if they operate in one of the states CMS selects.

A Practical Checklist for the Next 90 Days

Before the RFA arrives, ACO leadership teams can take several concrete steps:

  • Model the decade, not the year. Build a ten-year financial model under both the Global and Professional options, with sensitivity ranges for trend and risk score assumptions.
  • Audit documentation quality now. Baseline-period documentation will likely shape the model's starting point. Identify chronic conditions that are under-documented or captured only through retrospective review.
  • Inventory care management capacity. Measure current caseloads, time spent on administrative work and the share of high-risk patients with an active care plan.
  • Map specialist relationships. Identify the specialties where episode-based arrangements would have the most impact, typically cardiology, orthopedics and oncology.
  • Prepare governance for a longer commitment. Boards and physician partners should understand that LEAD is a decade-long commitment with correspondingly longer exposure.

How Technology Fits

A long-horizon model favors organizations that can run risk, quality and care management from a shared data foundation. Platforms that combine patient-level CMS-HCC V28 RAF scoring, risk stratification with SDOH weighting, HEDIS gap tracking and AI-assisted care plan drafting allow ACOs to see financial and clinical exposure in one place, and to scale care management without a proportional increase in headcount. Curitics Health supports this approach with a platform built for exactly this combination of risk, quality and care coordination work.

The Bottom Line

LEAD is CMS's clearest signal yet that it wants accountable care to be a long-term operating model rather than a series of short experiments. A benchmark that does not reset for ten years rewards patience, discipline and infrastructure. ACOs that use 2026 to strengthen documentation, care management capacity and data integration will enter 2027 with an advantage that can compound for a decade. Those that wait for the RFA to begin planning will spend their first performance years catching up.