The Complex Care Alliance welcomes the announcement of a new 10-year ACO model with a commitment to care for high needs patients
Washington, D.C. (December 18, 2025) – The Complex Care Alliance (CCA) welcomes CMS’s announcement of the LEAD Model and is encouraged to see the Innovation Center recognize the distinct needs of patients with complex illness and high needs as it looks beyond ACO REACH. These design choices also reflect input from CCA and its members, who have consistently urged CMS to ensure that any successor to ACO REACH maintains a strong, explicit focus on high-needs and complex populations. The CCA is particularly supportive of CMS identifying accurate benchmarking for patients with complex needs and that organizations that specialize in those patients can include more of their patients in an accountable care framework. These LEAD elements and others—including long-term benchmark stability, prospective payments, and an emphasis on prevention and care coordination—closely align with recommendations CCA has advanced for sustaining and strengthening complex care models beyond 2026.
We are particularly encouraged that LEAD maintains a dedicated focus on high-needs populations, including dually eligible and homebound beneficiaries. The High Needs ACO Model is already showing positive results: CMS evaluation findings show that High Needs ACOs generated $143 million in gross savings in 2023 with a 13.3 percent net savings rate, and earlier evaluations demonstrated gross savings of 3.5 percent along with reductions in emergency department visits and hospitalizations. Preserving a clear pathway for these organizations within LEAD is critical to ensuring continuity of care for some of Medicare’s most vulnerable patients.
CCA looks forward to continued engagement with CMS as LEAD is further developed and implemented, and to working together to ensure the model enables providers with specialized expertise to reach more patients who can benefit from accountable care.
To learn more about the Complex Care Alliance, please visit: https://accountableforhealth.org/cca/
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The Complex Care Alliance sent a letter to Senator Cassidy and Chairman Crapo responding to the Committee’s announcement they are considering including the No UPCODE Act (S. 1105) in the reconciliation package. The letter outlines CCA message to ensure that the definitions of “health risk assessments” are clear and do not unintentionally include appropriate care provided to the most vulnerable Medicare beneficiaries where they live.
Introducing the launch of a new Alliance focused on improving models of care for the most complex and vulnerable Medicare beneficiaries to strengthen and continue the model beyond its current expiration date in 2026.
The High Needs ACO track launched under the Global and Professional Direct Contacting model during the Trump Administration and continued today as ACO REACH, provide high quality, coordinated care to patients with multiple chronic conditions, functional impairments, and significant social needs.
