"The current [Risk Adjustment Validation (RADV)] process ... makes it extremely difficult for insurers to project RADV-related transfers and incorporate them into the rating process. In particular, the RADV approach has shown significant unpredictability and variability ... In the short term, it would be appropriate for CMS to focus on reducing issuer exposure to the variability and uncertainty in RADV-related transfers. In the long term, more significant changes to the program could be adopted that allow issuers more time to understand and adapt to changes."  MORE >>