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recognizes that continued reliance on pre-pandemic risk scores would not adequately reflect current trends in MA risk scores and coding practices. For CY 2026, CMS is using a two-year risk score trend calculation using 2022 and 2023 MA risk scores. This reflects the most recent post-pandemic data available and aligns with CMS’ approach of ensuring that the MA risk score trend estimates are based on the most up-to-date information. CMS determined that 2021 risk scores, which reflect 2020 dates of service, were significantly affected by underutilization due to the pandemic as discussed in prior Rate Announcements, and therefore, including 2021 in the calculation would not provide a reasonable measure of typical risk score growth. While CMS acknowledges that this approach differs from prior years, it remains consistent with the underlying methodology used historically to estimate the MA risk score trend. CMS anticipates returning to a three-year approach for CY 2027, when three years of post-pandemic MA risk scores will be available for trend estimation. Risk Adjustment Model Development Using MA Encounter Data Comment: Many commenters expressed a range of perspectives on a potential transition to an encounter data-based risk adjustment model. Some commenters, citing growing MA enrollment and their own investments in encounter data submission, supported the development of an encounter data-based risk adjustment model. Other commenters, including those neutral or open to the transition, emphasized the need for robust stakeholder engagement, transparency, and additional time before a model is proposed so that stakeholders can meaningfully provide feedback. Some commenters expressed concerns relating to data accuracy and completeness, operational challenges across plan types, and potential geographic disparities. Many commenters recommended a phased-in implementation, continued segmentation to reflect differences between FFS and MA populations, and further research on potential impacts to complex populations. Some commenters also noted the need for continued coding pattern adjustments, despite statutory constraints. A few requested a longer comment period, stating the belief the typical timeframe is insufficient for meaningful stakeholder input. Response: CMS appreciates the thoughtful feedback, support, and concerns from stakeholders regarding the potential for an encounter data-based model for a future year. We acknowledge commenters’ request for an extended comment period. CMS remains committed to evaluating these concerns carefully while we continue engaging with stakeholders as part of the model development process. We are committed to evaluating the feasibility, transparency, and timing of a future transition to an encounter data-based risk adjustment model, as we’ve done with previous risk adjustment model updates.