AHEAD Model Frequently Asked Questions

• General Achieving Healthcare Efficiency through Accountable Design (AHEAD) Model Details FAQs
• Hospital Participation in the AHEAD Model FAQs
• Primary Care Participation in the AHEAD Model FAQs
   

General Achieving Healthcare Efficiency through Accountable Design (AHEAD) Model Details

What are the changes to the model that are announced September 2025?

The changes to the model include:

• Replacing Health Equity Plans with Population Health Accountability Plans (PHAP), with a focus on preventive care, including chronic disease prevention.
• Adding new payment reforms for Medicare fee-for-service (FFS) beneficiaries, including capitated pathways in Primary Care AHEAD (PC AHEAD) and a two-sided risk accountable care organization (ACO) program incorporating novel elements of geographic alignment and bids against a discounted benchmark (Geo AHEAD; starting in 2028).
• Participating states to implement at least two policies focused on promoting choice and competition in their health care markets during the Implementation Period of the model designed to support states in achieving their total cost of care (TCOC) target.
• New requirements related to transparency around TCOC and primary care investment targets (PCITs).
• Strengthening the TCOC guardrail.
• Removing the option for states with statewide hospital rate-setting or budget setting authority to establish a state-designed Hospital Global Budget (HGB) methodology for Medicare FFS.

• Extending the end date of the AHEAD Model through December 31, 2035.

   

What is the Geographic-Based ACO Program (Geo AHEAD)?

Geo AHEAD is a geographic-based ACO program to support TCOC performance designed to align the AHEAD Model with CMS’ priorities of promoting prevention, supporting healthier lives, and encouraging choice and competition within our health care markets to reduce costs and improve quality.

Geo AHEAD will include two 4-year contract periods: 2028 to 2031 and 2032 to 2035. An important innovation of Geo AHEAD is that ownership, management, and control of Geo Entities is not required to be provider-led, meaning that non-provider organizations such as health plans or technology and digital health companies may come together to form and lead Geo Entities.

The program will engage otherwise unattributed Medicare beneficiaries in AHEAD states in value-based care and will test the novel feature of allowing entities to provide a discounted bid in relation to a CMS-determined TCOC Benchmark. Geo AHEAD will also provide an additional layer of TCOC accountability for beneficiaries who receive care in HGB hospitals and/or are aligned with PC AHEAD Practices.

How does Geo AHEAD align with other AHEAD components?

Geo AHEAD integrates TCOC accountability across HGB and PC AHEAD. HGB providers can choose to participate in Geo, allowing for more coordination with non-hospital providers and opportunities for shared savings. PC AHEAD providers can participate in capitation within Geo AHEAD, allowing new options to distribute risk and develop care management tools in coordination with the Geo entity. In addition, the Geo entity can help coordinate population health efforts and offer beneficiary engagement incentives.

How does the AHEAD Model support choice and competition?

During the Implementation period of the model, states will use their respective regulatory levers to implement at least one policy from the range of listed options focused on promoting consumer choice and one policy from a range of listed options focused on promoting market competition.

Promoting choice (states choose one option from the following):

• Implement Medicaid site neutrality
• Improve access to new and/or additional modes of care delivery via telehealth
• Advance prescription drug price transparency
• Free up provider movement by banning non-compete clauses

Promoting competition (states choose one option from the following):

• Change scope of practice restrictions (including for both Physician Assistants and Nurse Practitioners)
• Remove certificate of need requirements for all non-hospital settings
• Expand access to care by revising network adequacy provisions in compliance with federal requirements
• Expand contracting flexibilities by repealing any-willing-provider laws

How will quality measures be established for each state?

Each participating state will select a set of quality and population health measures from a menu of options provided by CMS. States will set specific targets for each selected measure, subject to CMS approval, that they will be accountable for meeting under the AHEAD Model.

CMS will also use quality measures and other data across the model to monitor impact and protect against any unintended consequences in the care delivered to beneficiaries or any negative changes in healthcare access or costs.

How is state performance assessed in the model? 

CMS will assess state performance on generated savings relative to the state’s projected TCOC growth absent the model. CMS will include state-specific factors (e.g., historic spending) in setting cost growth and primary care investment targets and projected state TCOC growth. TCOC growth and primary care investment targets will apply to the entire state or sub-state region in which the model operates, regardless of the level of participation in hospital global budgets.

Each participating state will be assessed and held accountable for state-specific Medicare FFS and all-payer cost growth and primary care investment targets. Medicare FFS cost growth targets will include Medicare Part A and Part B expenditures for beneficiaries residing in the state or sub-state region who meet eligibility criteria (e.g., residents in the state for a minimum defined period). All-payer cost growth targets will include expenditures for Medicare FFS, Medicare Advantage, Medicaid, commercial, state employee health plans, and Marketplace-qualified health plans.

States will be responsible for performance on All-Payer (including Medicaid, commercial, Medicare FFS, and Medicare Advantage) and Medicare FFS primary care investment targets. These targets will be set by measuring primary care expenditures for beneficiaries residing in the state or sub-state region as a percent of state TCOC for those beneficiaries. The Medicare FFS Primary Care Investment Targets will be set by CMS. States will have flexibility to set all-payer targets, subject to CMS approval.

Hospital Participation in the AHEAD Model

What provider types are eligible for participation in the AHEAD Medicare HGB?

The following table describes which hospital types are eligible or ineligible for participation in the CMS-Designed Medicare FFS HGB. Hospital participation in AHEAD is voluntary and will be subject to state-level coordination and oversight.

Primary Care Participation in the AHEAD Model

Can other provider organizations, such as Federally Qualified Health Centers (FQHCs), participate in Primary Care AHEAD?

Yes. FQHCs, including Health Centers and Health Center Look-Alikes (as defined by HRSA), and RHCs located in participating states and sub-state regions are eligible to participate in Primary Care AHEAD. FQHCs and RHCs that choose to participate in Primary Care AHEAD will do so in the same way as non-safety net primary care practices.

How will primary care practices and staff benefit from participation in AHEAD?

Through participation in Primary Care AHEAD, primary care practices will receive prospective, flexible, and enhanced payments intended to increase their capacity to deliver advanced primary care services for all attributed Medicare Part B beneficiaries. The model payments will fund care transformation in care coordination, behavioral health integration, and health-related social needs interventions, all tailored to the priorities of the state Medicaid Primary Care APM or Patient-Centered Medical Home (PCMH) program. This will also give participating practices the opportunity to hire staff to provide team-based, whole-person care, increase their quality reporting and performance capacities, and strengthen their coordination with specialty providers and community-based organizations.

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