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Section L. Frailty Adjustment for PACE Organizations and FIDE SNPs Frailty for FIDE SNPs Comment: A few commenters supported the continued use of the 2024 CMS-HCC model frailty factors. Response: CMS appreciates the support. As proposed, CMS will continue use of the 2024 CMS- HCC model frailty factors in CY 2026. Comment: A commenter expressed support for CMS’ CY 2025 methodology which considered all 2024 HOS-M respondents to be full-benefit dually eligible individuals and requested that CMS extend this methodology for CY 2026. Response: CMS appreciates the comment. As required by the CY 2023 final rule (CMS-4192-F, 87 FR 27741) titled “Medicare Program; Contract Year 2023 Policy and Technical Changes to the Medicare Advantage and Medicare Prescription Drug Benefit Programs; Policy and Regulatory Revisions in Response to the COVID–19 Public Health Emergency; Additional Policy and Regulatory Revisions in Response to the COVID–19 Public Health Emergency,” FIDE SNPs must have “exclusively aligned enrollment” beginning for contract year 2025, which means that enrollment in FIDE SNPs is limited to full-benefit dually eligible individuals beginning January 1, 2025. In the CY 2025 Advance Notice, we made clear that only for CY 2025, we would use the full Medicaid factors regardless of beneficiary dual status to calculate all frailty scores for FIDE SNPs; this policy decision was secondary to differences in the enrollment requirements for FIDE SNPs during the survey data collection period (CY 2024) and the calendar year in which frailty adjustments would be made (CY 2025). For CY 2026, CMS will rely on the data as submitted on the State Medicare Modernization Act (MMA) files, the Point of Sale data, and the Commonwealth of Puerto Rico monthly Medicaid file to determine the dual status of a beneficiary for frailty score calculation as has been done historically, with the exception of CY 2025. As noted in the CY 2025 Advance Notice, we anticipate that all 2025 enrollees considered for survey collection used for Activities of Daily Living (ADL) assessment for calculating CY 2026 frailty scores will be reported as full-benefit dually eligible individuals in compliance with 42 CFR § 422.2. As such, CMS anticipates that the CY 2026 frailty scores will exclusively use the full Medicaid factors, consistent with the outcome of the approach used for CY 2025. MA organizations that are planning to sponsor a FIDE SNP and wish to be considered for frailty payments in CY 2026 must contract with a CMS-approved survey vendor to field the 2025 HOS or HOS-M at the PBP level so that the necessary information to calculate a frailty adjustment for the FIDE SNP’s risk scores is available, as described in the January 17, 2025, HPMS memorandum, “Participation in 2025 HOS/HOS-M for MA Organizations Planning to Sponsor FIDE SNPs in 2026 – Notification of Upcoming Release of the HPMS HOS/HOS-M Survey Participation Module for Frailty Consideration.” For FIDE SNPs, CMS uses plan-level ADL