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MA Risk Score Trend Comment: Some commenters expressed concerns that the CY 2026 Advance Notice did not provide adequate transparency on the methodology, assumptions, and data used for developing the MA risk score trend. Several commenters do not believe CMS has released enough information for their organizations to adequately comment on the MA risk score trend. Commenters requested that CMS publish more information about how the MA risk score trend is calculated and detail of how the MA risk score trend is used by CMS. Response: Each year, CMS releases a Fact Sheet that shows the year-to-year percentage change in payment associated with the proposed (in the Advance Notice) or finalized (in the Rate Announcement) policies. The Fact Sheet shows the overall average impact on MA revenue, as well as the average impact of key individual updates or policy proposals. As part of the impacts released in the Fact Sheet, CMS also estimates the average growth of MA risk scores in the payment year, known as the MA risk score trend. The MA risk score trend is the average increase in MA risk scores, not accounting for normalization and the MA coding pattern adjustment (which are included separately). As discussed in the CY 2026 Advance Notice, CMS calculated the MA risk score trend by calculating the increase in MA risk scores over two prior years and then calculating the average annual year-over-year change. The two years of risk scores are calculated using the risk adjustment model to be used in the upcoming payment year. This average annual change is the MA risk score trend provided in the Advance Notice and Rate Announcement Fact Sheet. The trend is an industry average and individual plans’ experience will vary. Comment: Some commenters stated the belief that the MA risk score trend published by CMS does not accurately reflect the current state of the MA program. A few commenters are concerned that the use of two years of risk scores is not appropriate and relying on a single year- over-year data point is inadequate. The commenters stated that CMS should be consistent and continue to use the historical methodology of incorporating three years of data points to calculate the MA risk score trend. A commenter, noting that there is a two-year lag in the data years used to produce the MA risk score trend, believes CMS should consider an adjustment to the methodology to calculate the MA risk score trend reflecting current utilization trends which they cite as rapidly increasing across the market. Response: CMS appreciates the commenters’ concerns and recommendation regarding the approach to calculating the MA risk score trend as the average annual change in risk scores over two years, as opposed to over three years as historically done. Historically, CMS has calculated the MA risk score trend using the three most recently available years of risk scores to measure the average annual change in MA risk scores. Since CY 2023, CMS has used 2018 through 2020 MA risk scores for this calculation, as these were the most recent three years of continuous data unaffected by the COVID-19 pandemic. However, CMS