America's Health Insurance Plans is urging the Centers for Medicare & Medicaid Services to consider making "targeted changes" to improve the risk adjustment model it uses to stabilize the Affordable Care Act marketplaces. In a letter sent this week to the agency, AHIP calls for CMS to: adopt a durational factor into the risk-adjustment model to better capture the risk of partial year enrollment; Support the inclusion of prescription drug data to improve payment accuracy under the risk adjustment model; and not go forward with the high-risk pooling approach described in the agency's recent discussion paper, among other commments and recommendations. Letter (.pdf)