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these reasons, CMS continues to believe that a uniform normalization factor is the best approach for achieving the goal of this technical adjustment to risk scores, which, as stated previously, is to account for the trend in FFS risk scores between the denominator year and the payment year. Per section 1853(b)(2) of the Act, the Advance Notice of proposed changes to the methodology and assumptions used to determine annual MA capitation rates and the risk and other factors used in adjusting MA capitation rates under section 1853(a)(1)(C) is required to have a minimum 30-day comment period. The CY 2026 Advance Notice was released on January 10th, 2025, and comments were accepted through 11:59 PM Eastern Time on Friday, February 10, 2025 (30 days). CMS provided the required 30-day period for comments on the CY 2026 Advance Notice. In setting these timelines, we seek to achieve multiple goals, including providing the statutory- required amount of time for public comment while also releasing the Advance Notice using more current data and ensuring that the Rate Announcement is published by the statutory deadline. We note that CMS proposed to continue using the multiple linear regression methodology that was first implemented for CY 2025 but using the most recent five years of FFS risk scores available. Additionally, we provided the public with sufficient information to review the proposal, including the publication of the average FFS risk scores used to calculate the normalization factors in the CY 2026 Advance Notice and the public availability of model software12 that can be used by plans to assess the impact of a policy change such as this on their risk scores. Section O. Sources of Diagnoses for Risk Score Calculation for CY 2026 Non-PACE Organizations CMS did not receive comments regarding sources of diagnoses for non-PACE organizations for CY 2026. CMS will continue the policy as proposed in the CY 2026 Advance Notice, first adopted in the CY 2022 Rate Announcement, to calculate risk scores for payment to MA organizations and certain demonstrations using only risk adjustment-eligible diagnoses from encounter data and FFS claims. PACE Organizations Comment: Among commenters who addressed our PACE proposal, all applauded CMS’ commitment to work closely with PACE organizations as they transition to submitting complete encounter data. Some of these commenters requested that CMS recognize the operational and administrative challenges faced by PACE organizations with encounter data reporting and to provide ample support and guidance to make this transition as straightforward as possible. Response: CMS thanks the commenters for supporting the transition to submitting all risk adjustment data to the encounter data system (EDS). As proposed, for CY 2026 CMS will

12 https://www.cms.gov/medicare/payment/medicare-advantage-rates-statistics/risk-adjustment.