CMS Continues to Plan AHEAD Amid Rising Healthcare Costs

On October 28, 2024, the Centers for Medicare & Medicaid Services (“CMS”) announced the latest states to participate in the voluntary state total cost of care (“TCOC”) model: the All-Payer Health Equity Approaches and Development (“AHEAD”) Model. The initiative aims to curb healthcare costs and improve population health by allowing states to assume responsibility for their own healthcare systems. Specifically, the program holds states accountable for meeting state-specific Medicare targets, reducing cost growth, primary care investment, and advancing health equity principles.

As of August 2024, Maryland, Vermont, Connecticut, Hawai’i, Rhode Island, and five downstate counties of New York have been selected to implement AHEAD. Program Overview In September 2023, CMS unveiled AHEAD, a new, voluntary state TCOC model that seeks to drive transformation of the health care system on state and regional levels by incentivizing multi-payer alignment. AHEAD builds on existing, successful state-based models including, Vermont All-Payer Accountable Care Organization (VT ACO) Model , the Maryland Total Cost of Care Model (MD TCOC) , and the Pennsylvania Rural Health Model (PARHM) .



With the implementation of AHEAD, CMS will be able to expand this state-based TCOC into multiple states at once. Under the AHEAD model, participating states uses their authority to assume responsibility for managing health care quality and costs within their respective health care systems by improving care coordination, strengthening primary and preventive care, and increasing connection of patients to community resources that address the social determinants of health. The goal is to motivate states to improve population health by: CMS will provide support to states in meeting these goals by: Timeline The AHEAD model is scheduled to operate through 2034.

There are currently three cohorts of states implementing the program: Cohort 1 includes Maryland and Vermont, and has an 18-month pre-implementation period from July 2024 – December 2025. Performance will begin in January 2026 and last 9 years. Cohort 2 includes Connecticut and Hawai’i, and has a 30 month pre-implementation period from July 2024 – January 2026.

Performance will begin in January 2027 and last 8 years. Cohort 3 includes five New York counties (Bronx, Kings, Queens, Richmond, and Westchester) and Rhode Island, and has a 24-month pre-implementation period from January 2025 – December 2026. Performance will last 8 years.

Considerations for Current Participants Current AHEAD states are recruiting hospitals to participate in Hospital Global Budgets, as well as primary care practices, Federally-Qualified Health Centers, and Rural Health Clinics to engage in Primary Care AHEAD. Performance periods will begin in 2026. Interested healthcare organizations should reach out to their State Medicaid Agencies for more information.

Considerations for Potential Participants Any governmental body interested in participating can apply for the entire state or a specified sub-region. Participating states can receive up to $12 million to support model implementation over the course of the first five to six years. Funding will be made available to states in an initial award and subsequent annual non-competing continuation awards over the course of up to six years.

Model performance periods for new applicant states are scheduled to begin in either January 2026 or 2027, depending on the cohort a state applies to. CMS is offering a longer pre-implementation period for states that need additional time to prepare. Participating states will also work closely with CMS on implementation of the program.

Participants are required to establish a model governance structure to guide implementation and will be responsible for ensuring healthcare quality and equity targets are being met. Considerations for Healthcare Entities Participating hospitals and primary care providers in participating states should anticipate increased cross-sector model governance and resulting governmental transparency. Additionally, mandated targets will likely lead to auditing and data sharing requirements.

See here for more information about Vermont and Connecticut’s AHEAD implementation plans. Listen to this post.