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Announcement due to emerging actual 2024 claims experience, including for physician administered drug costs, which they believe demonstrates the need to use as much actual experience as possible for data accuracy. A few commenters cited specific drivers of expected increases in utilization and costs, including increased use of GLP-1 (Glucagon-like peptide-1) drugs and ongoing utilization recovery following the COVID-19 pandemic. A couple of commenters stated that the forward-looking trends (for 2024-2025 and 2025-2026), after adjusting for the technical update for medical education payments, are lower than the average trends observed for 2022-2023 and 2023-2024 without evidence or support that the trend drivers are being mitigated or decreasing (citing as one example the trends in physician administered drug costs). Another commenter expressed concern with using 2023 experience data as the base year for projections. A couple of commenters urged CMS to use consistent experience periods for the Advance Notice and Rate Announcement each year and across each data source used in a given year and communicate the experience periods used (e.g., incurred and paid-through dates). A couple of other commenters requested that CMS adjust the growth rate estimates for CY 2026 to be consistent with OACT’s estimates in the Medicare Trustees Report. Another commenter suggested that CMS give more credibility to recent trends that demonstrate an acceleration of trend. Several commenters believe it would be actuarially appropriate for CMS to incorporate an assumption that Congress will likely alter Medicare physician fee schedule reductions before they are scheduled to take effect in 2026, based on 2021-2024 Congressional actions and considering rate adjustments made for CYs 2014-2016, as a more reasonable expectation than the scheduled reductions. A commenter expects that CMS will update the growth rates to incorporate actual claims experience through the fourth quarter of 2024. Another commenter urged CMS to review fourth quarter 2023 data to help refine trend projections, since several health plan sponsors had publicly reported higher-than-average medical utilization and cost trends. Response: Section 1853 of the Act requires that FFS per capita cost estimates be used in developing MA rates and sets the general approach to updating the USPCCs and growth rates. Additionally, the projections are consistent with the law as it exists on the date of the Rate Announcement. The USPCC modeling approach used by CMS reflects projected changes in the factors used to update Medicare FFS payment rates. The projected expenditures for some of the Medicare payment systems include the expectation of inflation, including projected market basket changes for inpatient, SNF, home health agency, and outpatient hospital projections and consumer price index (CPI) updates for durable medical equipment projections.