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multipronged approach to addressing coding pattern differences between MA and FFS. Their recommendation included three parts: 1) develop a risk adjustment model that uses two years of FFS and MA diagnostic data; 2) exclude diagnoses that are documented only on health risk assessments from either FFS or MA; and then 3) apply an MA coding pattern adjustment factor that fully accounts for the remaining differences in coding between FFS Medicare and MA plans. Response: We appreciate commenters’ feedback. Section 1853(a)(1)(C)(ii) of the Act establishes a minimum MA coding pattern adjustment, which was originally adopted beginning with 2014 payment. The current statutory minimum coding pattern adjustment is 5.9 percent. In accordance with statute, CMS analyzes coding pattern differences and determines what the coding pattern adjustment factor should be on an annual basis. Based on our analysis, we have found that for CY 2026, the minimum adjustment, applied uniformly is sufficient to reflect differences in coding patterns between MA plans and providers under FFS Parts A and B. Therefore, we are finalizing our proposed MA coding pattern adjustment factor for CY 2026. We appreciate the comprehensive and thoughtful comments and feedback we received on this proposal. Ensuring that the coding pattern adjustment policy appropriately addresses differences in coding patterns between the FFS program and MA is essential, and we will consider these recommendations in the development of future proposals regarding the coding pattern adjustment. Comment: One commenter requested sufficient time and information to comment on any potential changes to the MA coding pattern adjustment in the future. Response: CMS appreciates the comment. Section 1853(b)(2) of the Act requires that CMS provide notice of proposed changes in the methodology and assumptions for setting MA capitation rates and risk and other factors used to adjust the capitation payments, with a comment period of at least 30 days to comment on the proposed changes. We will continue to consider additional ways in which we can engage with stakeholders should we consider changes to the MA coding pattern adjustment. Comment: A couple of commenters provided suggestions for what they referred to as “over- coding” or “upcoding.” One commenter suggested that CMS target RADV audits on health plans with significant variation from industry or regional risk score averages. Another commenter recommended that CMS exclude the use of diagnoses from chart reviews and health risk assessments for risk adjustment. Response: We appreciate the suggestions and are regularly evaluating ways to improve the accuracy of the data we receive and the payments that we make. With respect to the commenters’ suggestion regarding over-coding , it is important to note that the coding pattern adjustment is not an adjustment for inaccurate or fraudulent coding, but rather is a program-wide adjustment designed to account for the impact on MA risk scores of the differential coding patterns between