CMS LEAD Model Replaces ACO REACH — 10-Year Horizon, Fixed Benchmark, 3% FQHC/RHC Savings Wedge

CMS Innovation Center launched the Long-term Enhanced ACO Design (LEAD) Model on March 31, 2026 — a 10-year voluntary ACO model (PY 2027 through PY 2036) that replaces ACO REACH (sunsetting Dec 31, 2026). Two-sided risk with capitation options. Three structurally important features for FQHCs: (1) up to 3% savings 'wedge' specifically reserved for FQHC and RHC participation (shared between ACO and Medicare); (2) financial benchmark NOT rebased for the entire 10-year period — fixed historical baseline updated annually by blended national/regional growth factors (huge improvement over MSSP's 5-year rebasing that punished successful ACOs); (3) current ACO REACH participants get a streamlined 'abbreviated' application; New Entrant minimum 5,000 beneficiaries, High-Needs ACOs 1,250. Application window closed May 17, 2026 — so for CY27 PY1 entry, the gate is now whether your enabler (C3, MHN, Aledade) applied; future cohorts expected. Strategic implication: this fundamentally rewrites the Dec 31, 2026 'triple cliff' story. Until LEAD, ACO REACH was sunsetting with no successor — a real existential question for the FQHC-governed Medicare-ACO model. LEAD answers that with a 10-year horizon + fixed benchmark + 3% FQHC wedge. Pairs with C3 / Carina / MHN as the enabler-MSO chassis CA FQHCs can join.