Model Scope
Products and services that add up to success in the ACA Marketplace.
LEAD will operate for 10 performance years, from January 1, 2027 through December 31, 2036. This is the longest performance period CMS has tested for an accountable care model — ACO REACH ran for 6 years and MSSP agreement periods are 5 years. The model is available nationally. (RFA §III.A)
Implementation Period: An optional implementation period beginning September 15, 2026 allows accepted applicants to begin voluntary alignment activities (collecting signed attestation forms, conducting beneficiary outreach) before PY 2027 begins. (RFA §III.B)
Application Timeline
- 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 PM ET: Applications due for first cohort
- August 2026 (estimated): Financial guarantee templates released to accepted ACOs
- September 15, 2026: Implementation period begins
- December 31, 2026: Financial guarantee documentation due
- January 1, 2027: PY 2027 begins
(RFA §IV.A)
ACOs that participated in ACO REACH for PY 2026 are eligible to submit an abbreviated application. Organizations not ready for the first cohort may submit a non-binding Letter of Interest. Questions may be directed to with the subject “Application Question.” (RFA §IV.A)
Risk Sharing Options
LEAD offers two risk sharing arrangements (RFA §IX.A):
| Feature | Global Risk Option | Professional Risk Option |
| Savings/Losses sharing | Up to 100% | Up to 50% |
| Discount (CMS share) | Yes — 1.75%–3.0% (ramped) | None |
| TCC eligible | Yes | No |
| NPCC eligible | Yes | No (non-PC specialists only) |
| CARA eligible | Yes | No |
| MSR/MLR | None — first dollar | None — first dollar |
| Minimum tenure before switch | N/A | 4 years before switching to Global |
Key Insight: No Minimum Savings Rate (MSR) or Minimum Loss Rate (MLR) applies under either option — both generate first-dollar savings or losses. This contrasts with MSSP, which applies an MSR for one-sided models and permits ACOs in two-sided models to select an MSR/MLR. (RFA §IX.A)
Frequently Asked Questions
Yes, but ACOs must remain in the Professional Risk Option for at least four performance years before transitioning to Global Risk. (RFA §IX.A)
Standard ACOs must maintain at least 5,000 aligned beneficiaries with at least 3,000 claims-based aligned in at least one base year. Newly Entering ACOs start at 1,000 (growing to 5,000 by year 5). ACOs with ≥40% High Needs beneficiaries start at 800 (growing to 1,600 by year 5). (RFA §VII.B.5)
ACOs that fall within 10% below minimums receive a two-time buffer before facing potential termination. (RFA §VII.B.5)
