LEAD Model Updates
This page tracks updates to the LEAD Model as CMS releases new guidance, methodology papers, and RFA revisions. Each entry documents what changed, where to find it on this site, and what it means for LEAD participants.
April 15, 2026
LEAD RFA — First Revision
CMS released a revised version of the LEAD Model Request for Applications on April 15, 2026, clarifying nine areas of the original March 31, 2026 document. The revision does not change the model’s fundamental design but addresses methodological ambiguities and corrects errors in the original release. Pages 2–3 of the revised RFA list the changes.
Significant
Benchmark adjustment cap raised for higher-spending former MSSP ACOs
The original RFA capped benchmark adjustments at 3% of risk-standardized USPCC for all former MSSP ACOs. The revision limits the 3% cap to lower-spending former MSSP ACOs only. Higher-spending former MSSP ACOs now receive the standard 5% cap, and the “previous two years” MSSP participation window is now explicit.
Affects: Benchmarking
Clarification
Hybrid Alignment lookback windows specified
The original RFA described Hybrid Alignment conceptually but did not specify the lookback windows. The revision confirms that the initial alignment run uses October 1 – September 30 prior to the PY, and the mid-year refresh for new Participant TINs uses January 1 – December 31 prior to the PY. The two runs use different 12-month windows.
Affects: Alignment
Clarification
Regional efficiency adjustment now uses Base Year 3 only
The original RFA compared an ACO’s baseline to regional spending “during the historical base years” (BY1–BY3 average). The revision clarifies that the comparator is Base Year 3 only. CMS also clarified that the calculation is performed separately for each beneficiary category (A&D, HN, ESRD), then combined into a single population-weighted adjustment.
Affects: Benchmarking
Correction
Efficiency Adjustment Capitation option removed
The original RFA’s benchmarking graphic footnote suggested that a portion of the Regional Efficiency or Prior Savings adjustments “may be converted to capitated payments.” This language has been removed entirely. CMS has apparently decided not to offer this conversion option. The benchmark adjustments remain as annual settlement adjustments only.
Affects: Benchmarking, Capitation
Correction
HN risk score cap graphic corrected to 3–8%
The original RFA’s benchmarking graphic footnote stated the High Needs risk score cap as “10%” — inconsistent with the body text, which said 3–8%. The revision corrects the graphic footnote to 3–8%, aligning with the body text.
Affects: Risk Adjustment
Correction
High Performer Pool criteria updated and REACH references removed
The original quality scoring graphic contained erroneous references to “REACH ACOs” and omitted the Prevention and Quality Plan (PQP) from the High Performer Pool eligibility criteria. The revision removes the REACH references and confirms that an ACO receiving a CI/SEP score of 0 can still qualify for the HPP if it receives the full PQP Reporting Adjustment.
Affects: Quality
Minor
Physical therapists added to RISE to Age in Place team
The RISE to Age in Place coordinated care team composition now includes physical therapists (PTs) alongside occupational therapists (OTs), registered nurses (RNs), and handypersons.
Affects: CARA
