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providing analyses of risk model impacts for SNP plans, while other commenters believed CMS should continue to monitor effects of the model updates on the market, such as tracking beneficiary out-of-pocket costs and formulary changes, which these commenters believe could result in financial burdens for certain high-cost, high-need populations. A commenter further asked CMS to provide guidance and training resources such as case studies and best practices related to risk adjustment changes. Some additional commenters asked CMS to publish model software alongside the proposed model update. Response: CMS appreciates the commenters’ feedback. Regarding the commenters’ request for more time to review the policy proposals, 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. Section 1860D- 15(c)(1)(D) of the Act requires that CMS publish the risk adjustment factors for Part D at the time of publication of risk adjustment factors for Part C, which we propose in the Advance Notice and finalize in the Rate Announcement for the applicable year, per § 423.329(b)(4). CMS believes that the period provided for comments on the CY 2026 Advance Notice is sufficient. 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 to calculate the risk and other factors used to adjust MA capitation rates and ensuring that the Rate Announcement is published by the statutory deadline. CMS acknowledges the commenters’ requests for more analyses, resources, and stakeholder engagement and will take these into consideration. When the CY 2026 Advance Notice was published, CMS provided model software on the CMS risk adjustment webpage16 and posted estimated plan-level risk scores under the RxHCC models discussed in the CY 2026 Advance Notice to provide opportunity to assist in the evaluation of the proposed model update. Additionally, CMS provides risk adjustment resources on the CSSC operations webpage,17 including FAQs, computer-based trainings, and processing guides, and when changes are made to the model that require changes in reporting, we provide guidance through the Health Plan Management System (HPMS). While CMS engages with stakeholders on a regular basis through various lines of communication, physicians should not adjust their diagnostic or coding practices in response to model changes; rather they should adhere to ICD coding guidelines in order to accurately diagnose and code for patients’ diagnoses. Section G. Normalization for the RxHCC Risk Adjustment Models CMS did not receive comments specifically regarding the normalization factor methodology for the RxHCC model calibrated on 2018 and 2019 data that is being finalized for use in payment

16 CMS Risk Adjustment website 17 CSSC Operations website