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Response: CMS notes that membership in EGWPs is outside the scope of this document. Section J. CMS-HCC Risk Adjustment Model for CY 2026 Comment: Many commenters were generally supportive or neutral on finalizing the phase-in of the 2024 CMS-Hierarchical Condition Category (HCC) model, stating it improves payment accuracy and program integrity and helps address excess payments to MA organizations that have negatively affected taxpayers and beneficiaries. Additional examples of support included the following comments: • Continued implementation of the revised model helps to reduce incentives for MA plans to code intensively. • Belief that the model will improve risk adjustment across the industry and promote more responsible and equitable risk adjustment practices. • A commenter noted that finalizing one model significantly reduces administrative burden for payers, providers, and CMS. • Multiple commenters believe the model improves competition in the MA program so that plans compete on price and benefit design rather than coding. • A commenter cited research suggesting that concerns the model will substantially cut benefits for beneficiaries and harm disadvantaged beneficiaries are unfounded. The commenter noted that the MA market has remained stable, and that enrollment and plan options, especially SNPs, have increased, and that MA organizations have rebate levels that are at record highs. Response: We thank the commenters for their support. CMS is finalizing the phase-in of the 2024 CMS-HCC model as proposed in the CY 2026 Advance Notice such that 100 percent of the risk scores are calculated using the 2024 CMS-HCC risk adjustment model. We think that finalizing this model at 100 percent will improve payment accuracy and reduce burden for CMS and MA organizations. Comment: Many commenters expressed concern with the 2024 CMS-HCC model, including concerns that organizations that serve beneficiaries with complex chronic conditions, dually eligible beneficiaries, and certain beneficiary populations, locations (e.g., Puerto Rico), and plan types are disproportionately impacted. Some commenters are concerned that the model has resulted in higher costs and/or reduced access to providers or benefits for beneficiaries, increasing disparities among MA organizations. Commenters believed there are decreases in zero premium plans and increased deductibles, arguing that these trends will remain or worsen with finalizing the phase-in of the model.