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specifically CMS’ commitment to providing stakeholders greater visibility into the general methodology, data sets, and other technical components involved in deriving the USPCCs and calculating the FFS costs including the supporting data and files. Another commenter appreciated the publication of the components of the growth rates and encouraged CMS to continue this practice with future rate notices. Some commenters appreciated that the growth rate estimates were higher than the previous two years. Response: We appreciate the support and feedback. Comment: A large number of commenters encouraged CMS to incorporate the most recently available cost and utilization data (including 2024 experience) to ensure that the CY 2026 MA benchmarks reflect higher utilization and cost trends and inflation observed by commenters. Some commenters characterized the CY 2026 growth rate estimates as “inadequate,” particularly when following the lower growth rates of the past two years. A couple of these commenters cited published analyses of estimated accelerating cost trends varying geographically in Medicare FFS, MA, and the commercial health plan market. Many commenters cited analyses of ACO REACH model data which suggested that FFS costs grew at a higher rate between 2023 and 2024 than CMS’ FFS trend estimates, with one of these commenters acknowledging that the ACO REACH population is a subset of FFS. A large number of commenters noted that MA and Medicare Supplement (i.e., Medigap) data analyses indicated that medical costs and trends (e.g., for 2023-2024) were higher than CMS’ FFS estimated trend, specifically noting increases in MA utilization. Several commenters expressed concern that if the growth rates did not reflect higher utilization and cost trends in the U.S. health care market and the impacts of inflation, the rates would be insufficient to cover the cost of care for Medicare beneficiaries in CY 2026 which could lead to higher beneficiary premiums and/or reduced supplemental benefits. Several commenters expressed concern that restated estimates of FFS and Total USPCCs for recent years demonstrates consistent underestimation and bias toward under-forecasting of Medicare costs, with another commenter stating that this may be “suggesting the process is not immune to errors or deficiencies.” A commenter expressed concern regarding volatility in CMS’ projections of FFS spending. Another commenter believed that CMS should incorporate feedback from stakeholders who are seeing trends in care delivery, with less delay than annual restatements, including for experience periods where CMS has not yet received or analyzed complete information. A few commenters expressed concern that CMS is underestimating the Part B FFS USPCC trend given recent FFS experience. Another commenter noted that the restated 2024 FFS USPCC for Part B in the CY 2026 Advance Notice was higher than the estimate in the CY 2025 Rate