In this paper, Wakely examines the proposed Part C FFS Normalization factor for CY2025. As proposed, the factor is estimated to have about a -2.5% impact on risk scores for CY2025. We consider the implications of the method CMS is using and offer alternative approaches to calculating the normalization factor in order to provide further perspective on CMS's proposal.

A Deeper Look at the CY2025 Part C FFS Normalization Factor