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Response: As explained in section III.B.6.a of this rule, we are finalizing the proposed changes to the IVA sampling methodology to exclude enrollees without HCCs, remove the FPC, and use the 3 most recent consecutive years of HHS-RADV data with results that have been released before that benefit year's HHS-RADV activities begin to calculate the standard deviation of risk score error ( S i,h ) in the Neyman allocation as proposed to align sampling with the error estimation methodology and improve sampling precision

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