CMS 2027 Advance Notice

CMS is working to make the Medicare Advantage (MA) risk adjustment system more sustainable and provider-friendly. Their approach is guided by three key principles:

1. Simplicity — Reduce administrative burden for plans and providers

2. Fair Competition — Ensure all plan types can compete equally

3. Accuracy — Align payments with true patient health risk and promote integrity

What’s Changing in the Risk Adjustment Model?

• CMS will continue using Version 28 (V28) of the HCC model

• The model is now calibrated with 2023 diagnoses and 2024 costs (instead of older data)

• Audio-only visits and unlinked chart review diagnoses - diagnosis information not associated with a specific beneficiary encounter - will be excluded from risk score calculations starting in payment year 2027 with dates of service 2026.

• Plans can still submit these diagnoses, but they won’t count toward RAF scores

Bottom line: CMS is refining risk adjustment to be more accurate, fair, and defensible. Primary Care teams should prepare for tighter documentation standards and updated coding workflows.