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calculate risk scores for PACE organizations using 10 percent of the risk score calculated using diagnoses from encounter data and FFS claims only (under the 2024 CMS-HCC model and the 2023 CMS-HCC ESRD models) and 90 percent of the risk score calculated using diagnoses from RAPS, encounter data, and FFS claims (under the 2017 CMS-HCC model and the 2019 CMS-HCC ESRD models. PACE organizations should continue following the instructions for submitting risk adjustment data to the EDS.13 These submission instructions balance the priority to move PACE submissions to the EDS while allowing for a simpler submission for diagnoses from PACE center services during the transition. As we have previously stated, we cannot fully move PACE to the updated CMS-HCC risk adjustment model until all diagnoses are submitted to the EDS. Although CMS has laid out a transition schedule to move PACE organizations from submissions to RAPS to fully submitting their diagnostic data to the EDS, we reiterate that PACE organizations can stop submitting data to RAPS as soon as they submit fulsome diagnostic data to the EDS, regardless of the transition schedule that CMS follows. Essentially, if PACE organizations are able to improve their submissions to the EDS, then the transition can be accomplished more quickly. By submitting fulsome data to the EDS and stopping submissions to RAPS, PACE organizations will simplify their submission process and reduce their submission burden. Further, a shorter transition period will move PACE organizations to the new CMS-HCC risk adjustment model faster. CMS acknowledges the operational challenges and capacity limitations associated with moving to the EDS for some PACE organizations. CMS is committed to working closely with PACE organizations and continuing to provide technical assistance and guidance to support the successful submission of the necessary data. In furthering this work, between the release of the CY 2026 Advance Notice and this CY 2026 Rate Announcement, CMS released a dedicated webpage for PACE organizations on the Customer Service and Support Center (CSSC) website.14 This new webpage provides technical resources to support PACE organizations’ submission of encounter data and serves as a central resource for information on HPMS memos and announcements, technical guides, and other relevant resources to assist PACE organizations with the submission of risk adjustment data to the EDS. CMS plans to continue updating the webpage to include additional resources as they become available. We encourage all PACE organizations to visit the CSSC webpage to familiarize themselves with the resources provided and to continue monitoring the page for updates. CMS will continue to provide technical support and to monitor and discuss successes and challenges PACE organizations have experienced with submitting encounter data.

13 See: https://www.cms.gov/about-cms/information-systems/hpms/hpms-memos-archive-weekly/hpms-memos-wk-5-january-29- 31. 14 CSSC Operations - Encounter Data Submission Resources for PACE Organizations.