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The growth percentages are based on CMS’ best estimate of historical program experience and projected trend at the time those values are announced. We continue to consider it best practice to base the growth rates on the most recent data and assumptions available at the time those values are announced. Therefore, for each release of the growth rates, CMS updates historical enrollment and claims, as well as projection factors, based on the most recent data. The baseline supporting the USPCCs and growth rates has been revised since the CY 2026 Advance Notice to incorporate additional program experience. The updated non-ESRD FFS USPCCs for both Part A and Part B are based on program experience through 4th quarter 2024 and incurred dates through 3rd quarter 2024. The CY 2026 Advance Notice non-ESRD FFS USPCCs were based on program experience through 4th quarter 2023 for Part A and through 2nd quarter 2024 for Part B. Additional updates since the CY 2026 Advance Notice include reflection of final 2025 FFS payment regulations, updates to economic forecasts, and revised projection factors. Comment: A couple of commenters expressed concern regarding the level of transparency regarding the analysis and assumptions used to calculate the growth percentages. Many commenters requested greater transparency related to the data, methodologies, and assumptions supporting the development of the USPCCs, with some commenters citing the Actuarial Standards of Practice, such as utilization and unit cost trends by type of service, key driving factors of trend changes, and sensitivity analyses of trend estimates to changes in data. Specific areas mentioned by commenters requesting additional transparency included the following: • Incurred and paid through dates of the experience data supporting the USPCCs for the Advance Notice and Rate Announcement. • Explanation of why more recent experience was not used in the FFS USPCCs in the Advance Notice, in particular 2024 Part A experience. • Details on how CMS will incorporate trend data from 2024 into the final CY 2026 growth rates. • Explanation of how the 2026 USPCCs account for the prior two years of lower growth rates and the proposed 2026 total payment impact. • Details regarding how IPPS and OPPS finalized payment rates were incorporated into the 2026 USPCCs (e.g., impacts to trends in utilization and unit costs by type of service). • Greater insight regarding how utilization trends for 2021-2023, and the long-term costs associated with COVID-19, were incorporated into the USPCCs. • USPCC tables without the medical education adjustment and 340B adjustment. • Explanation and impacts of the enrollment projection assumptions whereby the projected number of aged beneficiaries as a percent of the Social Security area population age 65 and older have decreased compared to the CY 2025 Advance Notice.