Wakely provides participating issuers with risk adjustment estimates for the Affordable Care Act’s (ACA) individual and small group markets under the Wakely National Risk Adjustment Reporting (WNRAR) project. We collected WNRAR participants’ data scored with the 2019 Department of Health and Human Services (HHS) Hierarchical Condition Category (HCC) model as well as the proposed 2021 HHS HCC model as published in the 2021 proposed Notice of Benefit and Payment Parameters (NBPP). We compared results from both models and summarized our observations in this paper.