How CMS Administered Risk Arrangements (CARA) bridge the gap between ACOs and specialists | Will Gordon (Manatt Health)

Will Gordon, senior advisor at Manatt Health and former CMMI Chief Informatics Officer, explains CARA (a voluntary component of the ACO REACH/LEAD model starting in 2027) and why it matters for value-based care in specialties. 

He outlines three converging themes: episode-based bundles—especially surgical/orthopedic—have shown savings (often from post-acute care); ACOs have struggled to operationalize bundles due to contracting, attribution, and reconciliation complexity; and specialists have largely remained outside value-based care. 

CARA aims to bridge these gaps by letting ACOs and specialists set up CMS-facilitated episode-based risk arrangements via a web-based portal, using predefined episodes or a customizable “max flex” option, while specialists continue billing fee-for-service and CMS performs retrospective reconciliation against target prices. 

The discussion also covers operational platform constraints, market-driven episode design, and the flow of funds in retrospective bundles.

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