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ARTICLE · 14 JANUARY 2026

CMS LEAD Model Cracks Door Open To Cannabis Conversation

Foley Hoag LLP
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The LEAD Model's Substance Access Beneficiary Engagement Incentives (BEI) allow participating ACOs to advise patients on eligible hemp products as part of preventive, team based care in Medicare.

United StatesCannabis & Hemp
Edo Banach
Edo Banach
Eli Greenspan
Eli Greenspan
Matthew Piscitelli
Matthew Piscitelli
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Key Takeaways:

  • The LEAD Model's Substance Access Beneficiary Engagement Incentives (BEI) allow participating ACOs to advise patients on eligible hemp products as part of preventive, team based care in Medicare.
  • The BEI creates a standardized on-ramp for provider education, informed patient choice and outcomes tracking within value based care.
  • The Substance Access BEI signals support for evidence-guided conversations about hemp as a preventive or maintenance option for chronic conditions.

On the heels of an executive order1 that is intended to reschedule medical marijuana and increase federal cannabidiol research, the Centers for Medicare & Medicaid Services (CMS) Innovation Center recently announced hemp product flexibilities in the context of the Long-term Enhanced ACO Design (LEAD) model.2

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