HHS released a risk adjustment technical paper on October 26th, 2021 that discussed possible model changes to the current HHS risk adjustment model for the Affordable Care Act’s (ACA) individual and small group markets. In this paper, we analyze the impact of the possible risk adjustment model changes using national data collected through Wakely National Risk Adjustment Reporting (WNRAR) project, scored on the final 2022 and proposed 2022 HHS HCC risk adjustment models. The impact to risk scores and relative risk of issuers are summarized in this paper.