1. A method for programming in a 3D stacked non-volatile memory device, comprising: programming an initial set of memory cells using a respective starting program voltage, each memory cell of the initial set of memory cells is in a respective NAND string of an initial set of NAND strings; determining a count of program loops used in the programming of the initial set of memory cells; and programming a remaining set of memory cells using a respective starting program voltage which is determined based on the count, each memory cell of the remaining set of memory cells is in a respective NAND string of a remaining set of NAND strings, the initial set of memory cells and the remaining set of memory cells are arranged along respective memory holes at a common word line layer in the 3D stacked non-volatile memory device.