Scott Strickland

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283 appearances 1 recordings 1 series first heard Jun 2026 last heard 30 Jun

Scott Strickland’s voice in public audio — every appearance, attributed to the second.

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AHLA's Speaking of Health Law · CMMI and the Next Generation of Alternative Payment Models · 30 Jun 2026 podcast

if the total cost of care for the attributed population is above the benchmark.

Now in LEED, the LEED model, which is the new ACO model that CMMI is testing, that will start January 1 of 2027.

And the deadline for the RF the applications was yesterday.

Um so in this model.

It's

Everyone that participates, all the ACOs have to take on some level of risk.

So there is no one-side-only path.

Everyone is going to be in a two-sided risk path.

Now, what that has traditionally meant is that the ACO carries the risk.

And although it's certainly permissible for the ACO to pass that risk along to the participating providers.

practically speaking, as I know you're well aware, Neil, like just it's hard to get providers that are participating in these value-based models to agree that they are going to be on the hook to either ACO or CMS to actually pay back a portion of those losses.

So what CMS has said, or excuse me, what CMMI has said in the lead model for the first time is that there's a requirement that the ACO um

Or there's a prohibition against the ACO carrying 100% of that downside risk.

And so there's a requirement that the ACO pass along at least 1% of the potential risk of loss to the participating providers in the ACO.

And what that is going to look like practically, I think that's still up in the air, still not a lot from C.

In mind terms of like how it expects that relationship to look, it's going to be, I think, up to folks like um.

Me and you, Neil, to help our clients uh navigate what a compliant arrangement is going to look like that both satisfies CMS's requirement, but also just doesn't totally blow the relationship up between the provider and the ACO.

So more to come on that.

But I think that to me was um a like a canary in a coal mine, if you will.

I think that's a big signal for me that.

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