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Response: Revisions to the CMS-HCC risk adjustment model improve payment accuracy, but as with every update of the risk adjustment model, the impact on each plan can vary, depending on the demographic and health characteristics of their enrollees. The CMS-HCC model is a national model, that captures average variation in costs between population subgroups. The goal of risk adjusted payments is to pay accurately using the appropriate relative risk across subgroups of beneficiaries. Comment: Some commenters requested that CMS provide more transparency in model development through the publishing of white papers, establishing technical expert panels, and overall increasing engagement with stakeholders or additional time to review. A commenter requested that CMS provide at least 60-day notice for changes to the risk adjustment model. Another commenter recommended that any major risk adjustment model changes be finalized two years before implementation to allow time for plans and providers to make necessary operational changes. Response: We acknowledge the commenters’ request for additional transparency and an extended comment period when updates are made to the CMS-HCC risk adjustment model. Per section 1853(b)(2) of the Act, the Advance Notice of proposed changes to the methodology and assumptions used to determine annual MA capitation rates and the risk and other factors used in adjusting MA capitation rates under section 1853(a)(1)(C) is required to have a minimum 30-day comment period. The CY 2026 Advance Notice was released on January 10th, 2025, and comments were accepted through 11:59 PM Eastern Time on Friday February 10, 2025 (30 days). The only exception to this statutory minimum was another statutory requirement for a 60- day comment period, as first described in Part I of the CY 2019 Advance Notice,9 that applied only to proposals to implement certain changes to the CMS-HCC model (based on section 1853(a)(1)(I) of the Act), in accordance with requirements in the 21st Century Cures Act (Pub.L. 114-255). CMS is finalizing the full implementation of the 2024 CMS-HCC risk adjustment model, which is the expected continuation of the three-year phase-in first proposed in the CY 2024 Advance Notice. CMS provided the required 30-day period for comments on the CY 2026 Advance Notice. In setting these timelines, we seek to achieve multiple goals, including providing the statutory-required amount of time for public comment while also releasing the Advance Notice using more current data to calibrate the model and ensuring that the Rate Announcement is published by the statutory deadline. We provided the public with sufficient information to review the proposals since we informed the industry that the evaluation to reclassify the model was underway as far back as 2018, and we provided a number of resources to evaluate the updated model. In addition, the model updates are in line with typical model updates for which CMS has provided a similar or shorter comment period per the existing statutory requirement at the time. We will continue to consider additional ways in which we can engage with stakeholders as we

9 See Part I of the CY 2019 Advance Notice.