No UPCODE Act

S 1105, the No UPCODE Act, changes how Medicare Advantage plans are paid by altering risk adjustment rules. It requires using two years of diagnostic data (starting in 2026) for payment calculations and excludes diagnoses from chart reviews or health risk assessments from those calculations. The bill also mandates that the Medicare program evaluate how coding differences between plans and providers affect payment accuracy and publicly report the findings. These changes directly affect Medicare Advantage plans and their payment rates based on enrollee health status.