The paper next examines moving from a concurrent to a prospective model now that data are available as to the health status of marketplace enrollees. The paper decisively rejects this proposal. Finally, the paper considers using deidentified data collected in the current distributed external data gathering environment (EDGE server) to improve the risk adjustment program and increase transparency. CMS might be able to use these data, for example, to calibrate the risk adjustment model to account for socioeconomic status. CMS seeks comments on this approach.