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Comment Letter

Comments on How to Improve and Modernize Medicare Advantage

Press Contact: Jason Millman (213)-821-0099

CMS should consider updating its risk adjustment approach to ensure that Medicare Advantage and traditional Medicare remain viable for future beneficiaries.

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Schaeffer scholars responded to a Nov. 25, 2025, request for information from the Centers for Medicare & Medicaid Services (CMS) on how to improve and modernize Medicare Advantage, with a focus on risk adjustment.

Scholars identified key deficiencies in the current risk adjustment approach—namely favorable selection and upcoding—and offered specific considerations for reform.

Read the full comment letter here.