By: Paul Mason, Director of Strategic Partnerships at LTCPro
For: Accountable Care Organization (ACO) executives, network directors, and the Skilled Nursing Facility (SNF) and Assisted Living Facility (ALF) partners inside their care networks who are responsible for keeping post-acute operations compliant, coordinated, and financially sound.
Key Takeaway: ACO REACH ends at the close of 2026 and CMS’s next accountable care model, LEAD, brings a 10-year performance window built around high-needs and dually eligible patients, the exact population most likely to move through a skilled nursing facility. ACOs that outsource the billing, documentation, and compliance work behind their SNF and ALF network gain the standardized, audit-ready operational foundation that both today’s Medicare Shared Savings Program and tomorrow’s LEAD model require to actually capture shared savings.
In This Article
- What’s Changing for ACOs and Their SNF Networks in 2026 and 2027
- The Real Operational Burden ACOs Put on Their SNF Partners
- The SNF 3-Day Rule Waiver: A Lever Most ACO Networks Aren’t Fully Using
- Why Outsourcing Is the Operational Answer
- How LTCPro Supports ACOs and Their LTC Networks
- What Results Look Like
- Frequently Asked Questions
CMS’s Innovation Center will close the ACO REACH model at the end of 2026 and replace it with the Long-term Enhanced ACO Design (LEAD) Model, a 10-year test running from January 1, 2027 through December 31, 2036, the longest performance window CMS has ever built for an accountable care model (CMS). LEAD is explicitly designed around better coordination for high-needs and dually eligible patients, populations that show up disproportionately in skilled nursing and assisted living settings. For any ACO with a long-term care network, this isn’t a distant policy footnote. It’s a direct signal about who CMS expects ACOs to coordinate with more closely, not less.
Accountable Care Organizations exist to hit a specific target: better outcomes at lower cost, with accountability CMS can actually measure. Under the Medicare Shared Savings Program, the largest and most established ACO model, 476 ACOs covered 11.2 million assigned beneficiaries as of January 2025, and the program’s 2023 performance year alone produced $3.1 billion in total earned shared savings (CMS). Every dollar of that savings depends on care coordination working cleanly across every setting a beneficiary touches, including the SNFs and ALFs an ACO doesn’t directly operate but is nonetheless accountable for.
What’s Changing for ACOs and Their SNF Networks in 2026 and 2027
The shift from ACO REACH to LEAD matters for long-term care specifically because of who LEAD is built to serve. The model integrates care for patients with complex needs and dually eligible beneficiaries directly into its design, with enhanced risk adjustment and benchmarking meant to reward ACOs that actually manage that population well rather than avoid it (CMS).
CMS is also opening a Medicaid integration planning phase under LEAD from March 2026 through December 2027, during which CMS will select two states to help define how ACOs and Medicaid organizations can coordinate care for dually eligible beneficiaries, the population that cycles between hospital, SNF, and home most often. Actual partnership arrangements only begin if that planning period succeeds (CMS).
None of this works if an ACO’s visibility into its SNF network stops at the referral. LEAD’s payment structure includes flexible, capitated population-based payments meant to support team-based care across settings, which means an ACO’s financial performance increasingly depends on how well its post-acute partners document, bill, and report, not just on the clinical coordination itself.
The Real Operational Burden ACOs Put on Their SNF Partners
ACOs are built on collaboration and shared accountability across the care continuum, but the SNFs and ALFs inside an ACO’s network carry a specific, uneven share of the operational weight. A handful of structural pain points show up in nearly every ACO-LTC relationship:
Documentation and data stay fragmented across facilities that each run their own systems, on their own timelines, with their own conventions. Billing and coding practices vary facility to facility, which is exactly the kind of inconsistency that turns into reimbursement delays and denials at the ACO level, not just the facility level.
Administrative and support-function staffing shortages hit SNFs and ALFs as hard as anywhere else in healthcare, and a facility running lean on billing and compliance staff has less capacity to meet an ACO’s reporting cadence. Regulatory scrutiny from CMS and payer contracts doesn’t ease up for facilities inside an ACO network; if anything, the accountability runs both directions. And every one of these pressures compounds against the ACO’s own mandate to reduce readmission rates, shorten length of stay, and lower total cost of care, targets that are only as achievable as the weakest link in the post-acute network allows.
An ACO can manage its own internal operations well and still get dragged down by a network partner that lacks the infrastructure to keep pace. That gap is structural, not a matter of any single facility trying harder.
The consequence shows up in the numbers that actually determine shared savings. A denied claim at one SNF in the network doesn’t just cost that facility revenue. It distorts the ACO’s total cost of care data for that beneficiary, complicates the readmission and length-of-stay metrics CMS is measuring, and makes the ACO’s own performance harder to explain during a program review. Because ACOs are evaluated on the coordinated outcome across every setting a beneficiary touches, one facility’s documentation gap becomes the whole network’s reporting problem.
The SNF 3-Day Rule Waiver: A Lever Most ACO Networks Aren’t Fully Using
One specific mechanism illustrates exactly how tightly ACO performance and SNF operations are already linked, and it’s one most ACO-facing content never explains clearly. Under traditional Medicare, a beneficiary generally needs a three-day inpatient hospital stay before Medicare will cover a subsequent SNF stay.
Certain ACOs in two-sided risk tracks can apply for a waiver of that requirement, letting eligible beneficiaries move directly into a covered SNF stay without the three-day hospitalization first.
As of January 2025, 162 Shared Savings Program ACOs held an approved SNF 3-Day Rule Waiver, and 2,732 SNF affiliates were connected to Shared Savings Program ACOs nationwide (CMS). That’s a meaningful share of the program’s participants, but it also means a large majority of ACOs either haven’t pursued the waiver or aren’t fully using it.
The waiver only pays off operationally if the ACO’s SNF network can handle the documentation, eligibility verification, and billing precision it demands, since a waiver that generates clean admissions but messy claims doesn’t produce shared savings. It produces denials instead.
This is where the case for outsourcing stops being abstract. A waiver like this is only as valuable as the billing infrastructure behind it.
See how LTCPro helps ACO-affiliated SNFs manage 3-day waiver billing and documentation. Get a walkthrough of how standardized billing supports your ACO’s post-acute network.
See How LTCPro Supports Waiver Billing →Why Outsourcing Is the Operational Answer
Leading ACOs have recognized that outsourcing non-clinical functions across their long-term care network is efficient, but the real payoff runs deeper than efficiency. It’s what separates a network that’s genuinely accountable from one that’s accountable only on paper.
Outsourcing eliminates the need for each individual facility to build and staff a full administrative team capable of meeting ACO-level reporting standards on its own. That reduces fixed overhead across the network while raising, not lowering, the accuracy and timeliness of billing, coding, and payroll.
Cleaner claims and consistent documentation directly improve revenue cycle performance: fewer denials, faster AR recovery, and more predictable cash flow across every facility in the network, which matters because delays and errors in billing translate directly into delayed or lost reimbursement at the ACO level.
Standardized, audit-ready documentation also gives an ACO’s compliance team something to actually rely on when CMS or a payer comes asking about discharge planning, transitions of care, or SNF utilization, rather than a patchwork of facility-specific recordkeeping assembled under deadline pressure. And centralized reporting across the network gives ACO leadership one consistent view of financial and operational performance instead of reconciling different formats from every partner facility, which is what real-time, network-wide decision-making actually requires.
Scale is where all of this compounds. Whether an ACO’s network includes five SNFs or fifty, outsourcing back-office functions gives every facility the same process, the same reporting structure, and the same compliance foundation, which is what lets an ACO actually expand its network without adding a new operational silo every time.
How LTCPro Supports ACOs and Their LTC Networks
LTCPro partners with ACOs and their long-term care networks specifically, not as an add-on to a generic medical billing service. Medical billing and claims management, accounts receivable recovery and denial management, and coding compliance and documentation accuracy form the financial core of the engagement, built to produce the clean, consistent claims an ACO network depends on.
Credentialing and provider enrollment support keeps facilities correctly set up with every payer an ACO’s network touches. Payroll and HR administration extends the same standardization to workforce operations across the network. And analytics and performance dashboards give ACO leadership visibility into financial and operational benchmarks across every partner facility, not just the ones large enough to have built their own reporting.
LTCPro’s teams integrate with an ACO’s existing systems and protocols rather than asking the network to adapt to a new one, bringing long-term care regulatory expertise to a relationship that most generalist billing vendors don’t carry.
Talk to LTCPro about supporting your ACO’s SNF and ALF network. Walk through your current network’s billing, compliance, and reporting structure and see where standardization strengthens shared savings performance.
Talk to LTCPro →What Results Look Like
The documented federal data sets the real benchmark: Shared Savings Program ACOs earned $3.1 billion in total shared savings in performance year 2023, and 162 ACOs are already capturing additional value through the SNF 3-Day Rule Waiver specifically (CMS).
Client-specific figures, once verified, carry more weight with a prospective ACO than the program-wide numbers alone, since they show what standardized outsourcing does for a network like theirs specifically.
Schedule a network operations assessment with LTCPro. See exactly where your ACO’s LTC network operations create risk or leave shared savings on the table.
Schedule My Network Assessment →Frequently Asked Questions
What is an ACO in the context of long-term care?
An Accountable Care Organization is a group of providers, which can include hospitals, physician groups, and affiliated post-acute facilities like SNFs, that takes on shared responsibility for the cost and quality of care for a defined Medicare population. When an ACO’s network includes long-term care facilities, those facilities’ billing, documentation, and compliance performance directly affects whether the ACO achieves shared savings.
What is the SNF 3-day rule waiver?
The SNF 3-day rule waiver allows certain ACOs in two-sided risk arrangements to admit eligible Medicare beneficiaries directly to a covered SNF stay without the traditional three-day inpatient hospitalization Medicare normally requires first. As of January 2025, 162 Shared Savings Program ACOs held an approved waiver, and the mechanism only delivers value when the ACO’s SNF network can handle the billing and documentation precision it requires.
What happens to ACOs currently in the ACO REACH model when it ends?
ACO REACH concludes at the end of 2026. CMS’s successor model, LEAD, launches January 1, 2027, and current ACO REACH participants are among the provider groups CMS anticipates will apply, alongside ACOs new to accountable care and organizations serving underserved and dually eligible populations.
Is outsourcing LTC operations safe for ACO compliance purposes?
Yes, when the outsourcing partner is built specifically for long-term care and understands ACO reporting requirements, CMS documentation standards, and HIPAA obligations. The relevant due diligence is confirming the partner’s compliance infrastructure and audit trail capabilities before engaging them, the same standard an ACO would apply to any vendor touching claims or patient data across its network.
Does outsourcing work for ACO networks with facilities in multiple states?
Yes. Outsourcing partners built for long-term care account for state-specific Medicaid rules and payer variation across state lines, which matters for ACO networks with SNF and ALF partners spread across more than one state in the United States.
LTCPro is a strategic outsourcing partner for ACOs and their long-term care networks, supporting billing, collections, compliance, credentialing, and analytics for SNFs and ALFs across the United States.
