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Comment: Commenters offered differing views regarding the transition timeline. A few commenters encouraged CMS to continue being patient and cautiously optimistic as PACE organizations progress through the entire proposed four-year transition period and requested that CMS consider the operational challenges that PACE organizations face. A commenter was supportive of the tentative four-year transition while another commenter believed the proposed four-year transition period to be lengthy and would result in longer operational disruption and increased costs to the organization, suggesting for CMS to closely monitor first year transitions by PACE organizations, and if the first year of transition is smooth, to accelerate the transition. Response: CMS appreciates both the support, and the concerns raised, by the commenters on the timeline for the transition to the 2024 CMS-HCC risk adjustment model over time. CMS is finalizing the proposal in the CY 2026 Advance Notice to calculate 10 percent of the risk scores for PACE using the 2024 CMS-HCC model and will continue to provide guidance and assistance to support this transition. Attachment IV. Responses to Public Comments on Part D Payment Policy Section A. Annual Adjustments to Medicare Part D Benefit Parameters in 2026 No in-scope comments received. Section B. Part D Premium Stabilization Comment: A commenter asked that CMS release information related to the BBP calculation earlier in the bidding process. The commenter stated that greater visibility into BBP projections ahead of bid submission would be highly beneficial, given the complexity of Part D bid submissions and the need to balance plan design, affordability, and financial sustainability. The commenter also recommended that CMS consider providing illustrative scenarios to guide plan sponsors in their forecasting efforts. Response: CMS thanks the commenter for their input. Because the BBP is calculated based on the NAMBA, CMS is not able to provide the BBP calculation prior to bid submission. Section C. Part D Calendar Year EGWP Prospective Reinsurance Amount Comment: A commenter supported the continued use of prospective reinsurance payments for EGWPs and the continued use of the CY 2025 methodology for CY 2026. Response: CMS appreciates the support. Section D. Part D Risk Sharing Comment: Several commenters agreed with CMS’ assessment that risk in the Part D program varies widely and supported CMS’ proposal not to widen the risk corridors.