The LEAD ACO RFA is now open. Application deadline: May 17, 2026. Talk to Pathways today.

What participation actually looks like

No jargon. No fine print surprises. Here's what it means for your practice to join the LEAD Model with Pathways.

What Stays the Same

Your practice name, your staff, your patients

Nothing changes on your door or your letterhead

Your clinical autonomy

You practice medicine. We handle the ACO infrastructure.

Your existing payer contracts

LEAD is Medicare only. Your commercial contracts are untouched.

How you bill and see patients day-to-day

No workflow disruption. You keep doing what you do.

What You Gain

Share in Medicare savings

When total cost of care comes in under benchmark, you share the difference

A clinical team extending your reach

Hospital, SNF, and home-based support for your patients

Advanced analytics on your panel

Risk stratification, care gap identification, utilization insights

Better outcomes for your patients

Fewer preventable admissions, smoother transitions, proactive care

The Partnership in Practice

1

We Align Your Medicare Patients

Medicare beneficiaries are attributed to your practice based on their primary care utilization. This happens at the TIN level -- all primary care providers under your TIN are included automatically.

2

CMS Sets a Benchmark

A total cost of care benchmark is established based on historical spending for your attributed patients. This is the target. Under LEAD, this benchmark does not reset when you improve -- your savings compound over the full 10 years.

3

You Practice Medicine. We Handle the Rest.

Pathways manages the full care coordination infrastructure -- coordinating with hospitalists and ER providers, SNF care management, home health skilled services, care coordination, case management, disease management, non-emergency medical transportation, data analytics, quality reporting, and CMS model compliance. We also offer a full spectrum of practice management services including billing and CDI, payroll, health insurance for staff, marketing, outreach, and HR. You focus on your patients in the office.

4

We Share in the Results

When the total cost of care for your patients comes in below the benchmark, the savings are shared. Better care, lower costs, shared reward. Pathways operates at full risk on the Global track because we have the conviction and infrastructure to deliver.

LEAD Was Designed for Practices Like Yours

Independent Primary Care

Solo practitioners and small groups who want the benefits of value-based care without the overhead of building an ACO.

Internal Medicine Groups

Established IM practices with significant Medicare panels looking for a partner to help manage total cost of care.

Large Multi-Provider Groups

From modest groups to organizations with 200+ providers -- Pathways has the infrastructure to support practices at any scale.

Long-Term Care & Institutional

Practices serving long-term care and institutional populations bring unique expertise that drives value in accountable care models.

Rural Practices & FQHCs

LEAD offers rural add-on payments and lower alignment minimums. FQHCs and RHCs are explicitly eligible and supported.

Experienced in Value-Based Care

Already participating in an ACO or value-based arrangement? Bring your experience to LEAD with a partner built to maximize performance.

New to Value-Based Care

Never been in an ACO? LEAD's "Newly Entering ACO" designation starts you at just 1,000 beneficiaries in year one, ramping to 5,000 by year five -- with full historical baselines and weighted base year calculations that favor your most recent data.

From the RFA: What Practices Get Under LEAD

Primary Care Capitation -- up to 7% of your benchmark paid monthly, upfront, for primary care investment
Part B Cost-Sharing Support -- ACOs can cover patient copays for high-value services
Advanced APM Status -- LEAD qualifies under QPP, protecting you from MIPS reporting burden
Benefit Enhancements -- 3-day SNF waiver, telehealth from home, home health without homebound status
Hybrid Alignment -- add voluntarily aligned patients monthly, not just once a year
Stop-Loss Protection -- optional residual-based reinsurance against high-cost outlier patients
Provisional Settlement -- get paid on savings mid-year, not just at year-end
NP/PA Flexibilities -- expanded certification authority for hospice, cardiac rehab, infusion therapy, and more

A Fundamental Shift

Your complex patients are now an asset -- not a liability.

Under previous ACO models, practices serving high-acuity, long-term care, and institutional populations were penalized. Their patients' costs drove losses, while the benchmarking methodology failed to account for their complexity.

LEAD changes this entirely. High Needs beneficiaries now receive their own separate benchmark category with concurrent risk adjustment that captures actual acuity -- not just last year's diagnosis codes. Their complexity adds to the benchmark value, not only to the cost.

This means practices no longer need to fit their populations into programs designed for healthy community-dwelling patients. LEAD was built to recognize the value of caring for the patients who need the most care.

Separate Benchmarking

High Needs beneficiaries get their own per-beneficiary per-month benchmark, calculated independently from the general Medicare population. No more blending complex patients into averages that don't reflect their care needs.

Concurrent Risk Adjustment

LEAD uses a concurrent risk model for High Needs patients -- capturing current-year diagnoses and conditions, not just prior-year data. This typically captures 15-25% more risk than prospective models, meaning benchmarks more accurately reflect the true cost of caring for complex patients.

Once Qualified, Always Qualified

Once a beneficiary meets High Needs criteria, they retain that status for the full 10-year model. No annual re-qualification. No risk of losing benchmark value when a patient's condition stabilizes.

The math favors joining now.

Pathways has modeled LEAD's financial methodology against our actual ACO REACH performance. The results are clear.

10yr

Fixed benchmarks -- no rebasing for the entire model duration

7%

Enhanced Primary Care Capitation -- up to 7% of benchmark paid monthly, upfront

100%

Shared savings on Global Risk -- first-dollar, no minimum savings rate

What LEAD Unlocks That ACO REACH Couldn't

1.

Concurrent risk adjustment for complex patients -- High Needs beneficiaries are risk-adjusted using current-year data, not just prior-year, more accurately reflecting true acuity

2.

No benchmark rebasing for 10 years -- savings compound instead of being penalized. Every dollar you save stays in the benchmark baseline

3.

Administrative add-on for higher-spending ACOs -- 1.5% of benchmark paid monthly to fund care transformation investments

4.

Prior savings adjustment -- ACO REACH performance carries forward, rewarding the work you've already done

5.

Prospective trend uplift (ACPT) -- benchmarks grow slightly faster than realized spending, creating a sustainable savings wedge

6.

Part B cost-sharing support -- share savings directly with patients by covering their copays for high-value services

Straight Answers

No. There is no cost to participate. Pathways covers the operational infrastructure. You continue to bill Medicare as you do today.
Pathways operates on the Global risk track and manages the financial risk. Our job is to coordinate care effectively so that total cost stays below benchmark. Your practice shares in the upside without taking on ACO-level financial exposure.
No. You continue practicing medicine the way you always have. Pathways provides the extended care team, analytics, and coordination. We'll share insights about your panel, but clinical decisions remain entirely yours.
Yes. While LEAD is a 10-year model, individual practice participation has defined exit provisions. We want partners who want to be here -- not practices locked into something that isn't working for them.
The biggest difference: LEAD doesn't rebase your benchmark. In MSSP, when you improve, your benchmark drops -- penalizing success. LEAD locks your benchmark for the full 10 years. LEAD also offers prospective capitated payments (not retrospective FFS), specialist integration through CARA, and enhanced patient benefit tools.
Keep providing great primary care. Engage with our care team when they share insights about your patients. That's it. We handle the data, the reporting, the compliance, the care coordination, and the CMS relationship.

Interested? Let's talk specifics.

Every practice is different. Let's have a conversation about what LEAD participation would look like for yours.

Schedule a Conversation