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we include the indicator that captures the percentage of diabetic MA enrollees 18-75 years of age whose most recent HbA1c level is greater than 9%, or who were not tested during the measurement year. This measure for CMS public reporting is reverse scored, such that higher scores are better. Thus, to calculate this measure, CMS subtracts the submitted rate from 100. This is currently a hybrid measure. NCQA is developing a new ECDS-reported version of this measure for measurement year 2027 and plans to conduct testing for ECDS feasibility in 2025, prior to implementation. NCQA plans to maintain the hybrid measure in HEDIS, in parallel with the ECDS measure, during a two-year transition period, until the hybrid measure is replaced with the new ECDS measure in measurement year 2029. This change would be considered non- substantive since removing hybrid reporting and transitioning to ECDS will not change the eligible population for the measure or the data sources that contracts can use; the change is to the reporting method only. Most of the comments related to ensuring adequate time to transition to ECDS reporting. We have shared the comments with NCQA for their review. Concurrent Use of Opioids and Benzodiazepines (COB) (Part D). The PQA updated the COB measure specifications in the 2025 PQA Measure Manual to exclude beneficiaries with cancer- related pain treatment diagnosis during the measurement year to align with the 2022 CDC Clinical Practice Guideline for Prescribing Opioids for Pain (2022 CDC Guideline).37 CMS plans to exclude beneficiaries with cancer-related pain treatment diagnosis from the COB measure beginning with the 2025 measurement year (2027 Star Ratings). This would be a non-substantive update under § 423.184(d)(1)(iii) because it updates the clinical codes with no change in the target population or the intent of the measure. Commenters supported updating the COB measure to exclude beneficiaries with cancer-related pain treatment diagnosis. Therefore, this exclusion will be applied for the 2025 measurement year. Medication Adherence for Diabetes Medications/ Medication Adherence for Hypertension (RAS Antagonists)/ Medication Adherence for Cholesterol (Statins)/ Statin Use in Persons with Diabetes (SUPD)/ COB/ Polypharmacy: Use of Anticholinergic Medications in Older Adults (Poly-ACH) (Part D). CMS excludes contracts with 30 or fewer enrolled members in the denominator from the Star Ratings; in other words, only contracts with 31 or more enrolled members receive a measure rate. The PQA recommends excluding contracts with fewer than 30 enrolled members from the measure rate calculations since it is an insufficient sample size for measurement purposes. Therefore, CMS plans to align with the PQA to exclude contracts with fewer than 30 enrolled members from the measure rate calculations, and contracts with 30 or more enrolled members will be included in the measure rate calculation starting with the 2025 measurement year (2027 Star Ratings). This would be a non-substantive update under § 423.184(d)(1). All commenters supported this update to these measures to include contracts with 30 or more members in the denominator for the measure rate calculation. Commenters noted that this update

37 https://www.cdc.gov/mmwr/volumes/71/rr/rr7103a1.htm