The shift to CMS HCC Model V28 is not just a coding update—it’s a multi-year operational transformation that will require planning, coordination, and consistent execution to get right. With the final phase-in expected by 2026, health plans and provider organizations have a narrowing window to adapt their documentation, coding, and compliance programs to meet the model’s heightened requirements. Getting ahead of this curve is critical to safeguarding both revenue integrity and audit readiness.
Understanding the Timeline and Its Impact
The rollout of V28 is being phased in over several years to give organizations time to adjust. This transition period is an opportunity to analyze how changes to HCC categories, weighting, and specificity will impact current workflows. For many, the challenge lies not just in retraining teams, but in rethinking risk adjustment strategies to align with the new structure without disrupting patient care.
Key Milestones for a Successful Transition
- Immediate Assessment (Now – Early 2025)
Conduct a gap analysis comparing current coding practices against V28 requirements. Identify at-risk categories and workflows that will need adjustment. - Training and Education (2025)
Build tailored education plans for CDI teams, coders, and providers. Focus on the increased specificity requirements and the need for stronger linkage between diagnoses and supporting evidence. - Technology Integration (2025 – Mid 2026)
Update or deploy risk adjustment software that incorporates V28 logic and provides real-time prompts for compliant documentation. Ensure EHR systems can support the added detail. - Full Compliance Readiness (Late 2026)
By the end of the transition period, organizations should be operating entirely under V28 logic with minimal disruption to RAF accuracy or operational efficiency.
Reducing Risk During the Changeover
One of the most significant risks in the transition is revenue volatility caused by missed documentation opportunities or misaligned coding. To minimize this, leaders should implement proactive chart reviews and test RAF calculations under both models before full implementation. Aligning retrospective audits with V28 logic early will also help uncover gaps before they affect payment.
Why Cross-Functional Collaboration Matters
This is not solely a coding department initiative—it’s a whole-organization effort. Compliance, provider engagement, IT, and finance teams all play a role in ensuring the transition stays on schedule. Regular communication and shared accountability across teams will keep the project from slipping behind and will strengthen the organization’s overall readiness.
Conclusion
Meeting the 2026 deadline for CMS HCC Model V28 requires more than following a checklist—it demands a well-orchestrated strategy that addresses people, processes, and technology together. Organizations that start early, train intentionally, and test their workflows against the new requirements will position themselves for a smooth transition, sustained compliance, and stable revenue performance.
