CMS’s Calendar Year 2027 Advance Notice, released on January 26, 2026, proposed changes to fee-for-service (FFS) expenditures and introduced a new risk adjustment model. Together, these updates could result in material changes in the average geographic adjustment (AGA) factors, which drive the county-level Part C benchmark rates. In this whitepaper, we describe three key proposed changes and highlight geographical areas that are at risk for material financial impact.
