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Higher Adjustment Factor: Several commenters recommended a higher adjustment factor than the statutory minimum. These commenters expressed concern that the statutory minimum does not account for the full impact of coding pattern differences between MA and FFS, and a few commenters highlighted analyses from MedPAC that the MA coding pattern adjustment factor should be several percentage points higher. A few commenters who recommended a higher adjustment factor expressed concern that the current application of the minimum adjustment and the HCC-based risk adjustment model incentivize plan sponsors to code their enrollees with as many conditions as possible, driving up payments. Specific Methodological Recommendations: • Targeted Approaches: Several commenters requested that CMS consider an approach that addresses variation in coding by targeting plans with higher coding intensity. o General comments supporting targeted approaches. Several commenters expressed concern that there is wide variety in coding patterns across the industry and applying an across-the-board MA coding pattern adjustment factor fails to recognize differences across plans which could result in an inequitable outcome. A few commenters recommended targeted approaches, aimed at plans that tend to code more intensely. This was based on their concern that certain MA organizations code much more aggressively than others, with higher levels of coding intensity due to various structural payment incentives, including payments between MA organizations and their contracted providers. o Segmented/tiered approach. Several commenters suggested that CMS consider a segmented or tiered approach to estimating the MA coding pattern adjustment factor that recognizes different levels of coding patterns among organizations such that the lowest factor is applied to lower coding organizations while the highest factor is applied to higher coding organizations. The commenters believe that a tiered approach could ensure the MA coding pattern adjustment accounts for differences in coding patterns without negatively affecting plans that adhere to proper coding guidelines. o Contract-specific approach. A few commenters recommended tailoring the MA coding pattern adjustment factor to the relative level of coding intensity seen in individual MA contracts – rather than the across-the-board adjustment that CMS applies today to all MA contracts. o One commenter stated their belief that the 2024 CMS-HCC model reduced coding differences by eliminating or constraining certain HCCs but deemed it inadequate to fully address growing MA coding intensity. One commenter recommended a