Key Dates & Decision Points

This page summarizes major milestones from RFA release through Performance Year launch, and highlights factors organizations should weigh when evaluating LEAD participation.

Full Timeline (RFA §IV.A)

• March 31, 2026: RFA released, application portal opens
• April 20, 2026: Letter of Interest (LOI) form available for organizations interested in future cohorts
• May 17, 2026, 11:59 p.m. ET: Applications due for first cohort
• July 14, 2026: PY 2027 Alignment and Financial Methodology Paper and SSP Policy Update released. Professional savings rate raised to 60%; High Needs cap set at 4%; ACPT moved to annual setting.
• August 2026 (estimated): Financial guarantee templates released to accepted ACOs
• Before PY 2027 (date TBD): Time-limited window for selected applicants to change their Risk Option election following the Professional savings rate increase.
• September 15, 2026: Implementation period begins
• December 2026: Preliminary Benchmark Report (Jan to Sep 2026 claims with completion factors and Q4 seasonality adjustment); preliminary higher-/lower-spending designation; alignment minimum standard determinations.
• December 31, 2026: Financial guarantee documentation due
• January 1, 2027: PY 2027 begins
• February 2027: Preliminary Benchmark Report Update (full CY 2026, no run-out).
• May 2027: Q1 Benchmark Report (full CY 2026 with run-out through March 2027); final higher-/lower-spending designation; ACOs whose designation flipped elect which to use for PY 2027.

ACOs that participated in ACO REACH for PY 2026 may submit an abbreviated application for the first LEAD cohort. (RFA §IV.A)

Decision Framework

Organizations evaluating LEAD should analyze model financials (benchmark trajectory, capitation elections, discount and add-on interactions; see benchmarking and capitation), risk tolerance (Professional vs. Global, corridors, stop-loss; see settlement), operational readiness (alignment, EHR, quality reporting, care management; see participation and quality), and overlap considerations with other CMS models at the TIN level (see participation).

Beneficiary Engagement and Marketing (RFA §VII.C)

LEAD ACOs must comply with beneficiary engagement and marketing requirements including:

• Providing beneficiaries with information about the model, their alignment status, and their rights
• Offering beneficiaries the opportunity to decline data sharing
• Following CMS-approved marketing guidelines
• Not engaging in activities that could mislead or coerce beneficiaries

ACOs must notify beneficiaries carried over from ACO REACH voluntary alignment attestations and provide opt-out instructions. (RFA §VII.C)

Data Sharing and Reports (RFA §XIII)

CMS will share data with LEAD ACOs to support care management and population health activities:

• Claims and claims line feed (CCLF) files for aligned beneficiaries
• Beneficiary-level alignment and eligibility data
• Preliminary and final benchmark reports
• Quality performance reports
• Shadow bundles data (for CARA preparation)

Beneficiaries may opt out of data sharing. Claims for opt-out beneficiaries are excluded from capitation fee reductions. (RFA §XIII.B)