Aligning your ACO Participation with Your Health System’s Strategic Priorities

In December 2025, the Centers for Medicare & Medicaid Services (CMS) announced its newest accountable care organization (ACO) program to be tested by the CMS Innovation Center (CMMI), the . LEAD represents the latest in a series of ACO demonstrations tested via CMMI since the passage of the Affordable Care Act, which established CMMI as a sandbox for flexible, more advanced payment and care delivery models alongside the Medicare Shared Savings Program (MSSP), a permanent program run through CMS. As LEAD’s predecessor model, , sunsets at the end of this year, provider organizations are facing a participation decision between the longstanding and LEAD, with the deadline to apply for each program’s January 1, 2027 start date fast approaching.

ACOs and health systems will likely evaluate expected financial performance and appetite for risk under each program as a first step in the participation decision-making process, given the differences between their benchmarking methodology, payment mechanisms and provider risk arrangements. While financial modeling is critical, health systems, in particular, must also consider how each model’s goals and care delivery framework align with their own strategic priorities. Though MSSP and LEAD share certain foundational features, such as requiring all providers billing under the same tax identification number to participate, their differences may require more nuanced discussions across a health system’s leadership team to weigh their participation in either program. This article will outline the key considerations of each program against three strategic priorities for health systems, as well as an that highlights the key differences between core components of MSSP, ACO REACH and LEAD.

Applications to LEAD were due May 17, 2026 (see ) and initial applications for MSSP are due June 23, 2026.