The "No UPCODE Act" seeks to enhance the accuracy and integrity of risk adjustment payments within the Medicare Advantage program. Beginning in 2026, it mandates that the Secretary of Health and Human Services utilize two years of diagnostic data when available for risk adjustment methodologies, providing a more comprehensive view of beneficiary health status. A key provision of the bill is the exclusion of diagnoses collected solely from chart reviews and health risk assessments for payment adjustment purposes, aiming to prevent potential overpayments based on less robust diagnostic information. The Secretary is also required to establish procedures for identifying and verifying such diagnoses. Finally, the legislation directs the Secretary to annually evaluate and publicly report on the impact of coding pattern differences between Medicare Advantage plans and traditional Medicare. This evaluation will ensure that risk adjustment fully accounts for any identified discrepancies, potentially through plan- or contract-level adjustments, to ensure fair and appropriate payments.