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Comment: A commenter urged CMS to make an adjustment to the Average Geographic Adjustments (AGAs) methodology to account for downward pressure of COVID-19 on FFS costs. A commenter expressed concern that CMS limits its adjustment of the AGAs for Innovation Center demonstrations and payment models to those listed in the Advance Notice and that CMS excludes Innovation Center payments that are not funded from the Trust Funds. The commenter recommended CMS reconsider this policy and include advance payment of shared savings in the calculation of FFS costs. The commenter also recommended CMS publish the amounts paid to FFS providers through the Innovation Center but not included in the benchmark calculations in the Rate Announcement. Response: As explained on pages 36-37 of the CY 2026 Advance Notice, we considered adjusting the FFS claims experience for care management fees, per-beneficiary-per-month fees, and/or advance payment of shared savings paid using the Innovation Center appropriation instead of the Medicare Part A or B Trust Funds for other Innovation Center models conducted in the 2019–2023 period. However, we intend to continue prior policy and will not take fees of this type into account in our adjustments to historical FFS experience when they were not funded under Medicare Part A or B Trust Funds. As we discussed on page 20 of the CY 2018 Advance Notice, the fees paid from administrative accounts authorized by section 1115A of the Act are not from the Parts A and B Trust Funds, from which Medicare claims are disbursed, so we do not consider those payments to be part of FFS costs. Per section 1853(c)(1)(D)(i) and (n)(2)(F) of the Act, CMS uses the “adjusted average per capita cost for the year involved, determined under section 1876(a)(4) [of the Act]” as the base payment amount for setting MA rates. Section 1876(a)(4) indicates that FFS costs used for MA rates are based on the estimated amount that would be payable for services covered under Parts A and B, and types of expenses otherwise reimbursable under Parts A and B (including administrative costs incurred by organizations described in sections 1816 and 1842). As these costs described in section 1876(a)(4) of the Act are paid from the Trust Funds, excluding costs paid from another appropriation is appropriate to determine FFS costs. See also sections 1817 and 1841 of the Act. In addition, section 1853(f) of the Act indicates that payments to MA organizations shall be made from the Trust Funds “in such proportion as the Secretary determines reflects the relative weight that benefits under Part A and under Part B represents of the actuarial value of the total benefits under this title.” Therefore, we will not make an adjustment to historical FFS claims to account for payments made from the funds appropriated under section 1115A(f). Comment: Several commenters urged CMS to use only beneficiaries eligible for MA (those with both Part A and Part B) in the calculation of MA benchmarks, instead of including Part A-only and Part B-only beneficiaries. Commenters cited various concerns such as actuarial principles