Risk Adjustment Solutions for 2027: Moving from Year-End Coding to Continuous Management

Risk adjustment solutions for Medicare Advantage organizations are entering 2027 under a confirmed payment environment and a set of operational changes that require adaptation before January 1. CMS's April 2026 Rate Announcement projects MA payments to increase by 2.48% – over $13 billion – in CY 2027, while CMS expects MA risk scores to increase by 2.50% on average due to underlying coding trends [1]. The 2024 CMS-HCC model (V28) continues as the risk adjustment model for 2027 – CMS chose not to implement the updated model proposed in the Advance Notice – but key changes to how diagnoses are sourced and submitted take effect with the new year. For healthcare providers, 2027 is not simply a continuation of current practices. It is a structured opportunity to move from reactive, year-end risk adjustment to a continuous management approach – and to ensure that risk adjustment solutions are aligned with how CMS is calculating and scrutinizing risk scores going forward.

CMS's 2027 Rate Announcement, finalized April 6, 2026, establishes the payment environment that MA plans and their provider partners will operate in next year.

The projected 2.48% increase in MA payments – over $13 billion aggregate – reflects a combination of growth rate factors, model revisions, and normalization adjustments. CMS separately projects that MA risk scores will increase by 2.50% due to underlying coding trends.

For providers, the more immediate operational issue is what changed about how risk scores are calculated. For CY 2027, CMS is finalizing the exclusion of diagnoses from unlinked Chart Review Records (CRRs) from risk score calculation [1]. Diagnoses from chart reviews that are not linked to a specific beneficiary encounter will not count toward risk scores – with one exception for members who switch between MA organizations.

This change affects any risk adjustment workflow that relies on unlinked CRR submissions. Organizations whose risk adjustment solutions include chart review processes need to confirm that their documentation and submission workflows account for this requirement before CY 2027 begins.

In its Contract Year 2027 proposed rule, CMS solicited feedback on next-generation risk adjustment model approaches, including the use of artificial intelligence and alternative data sources, and signaled continued examination of how to reduce gaps between quality measurement and payment [2]. CMS also provides 2027 model software and ICD-10 mappings to help organizations align their systems with current-year requirements [3].

These signals matter for risk adjustment solutions planning because they indicate the direction of CMS oversight: more data-driven, more technologically enabled, and more focused on payment accuracy and program integrity. Technology can help organizations identify relevant information more efficiently, but its true value lies in how effectively it complements clinical documentation and experienced reviewers rather than replacing them.

More than half of Medicare beneficiaries are now enrolled in Medicare Advantage or other health plans. CMS's June 2026 enrollment data shows 70.1 million total Medicare beneficiaries, with 51.2% enrolled in MA and other health plans [4].

With the majority of the Medicare population in MA, the scale of accurate diagnosis capture has a direct effect on both plan payments and provider reimbursement. The focus should not be on adding diagnoses. It should be on building processes that capture every supported diagnosis throughout the year – rather than searching for gaps retrospectively at year-end.

2027 gives providers a structured opportunity to move risk adjustment from a year-end activity to a year-round process. Instead of treating it as a separate annual task, providers can integrate it into everyday clinical workflows.

That includes:

• Identifying documentation gaps earlier in the care cycle
• Connecting clinical documentation with coding in real time
• Reviewing patient records continuously rather than in retrospective bursts
• Using technology to surface areas that need attention
• Giving providers actionable, timely feedback
• Tracking performance over time

This approach also builds stronger readiness for risk adjustment audits. RADV audits are currently active for Payment Years 2020, 2021, and 2024 simultaneously – meaning organizations need audit-ready documentation as an ongoing operational standard, not a response to a specific audit notice. Risk adjustment solutions that connect coding, documentation validation, and audit preparation into one workflow create stronger outcomes across both areas.

As the risk adjustment environment continues to evolve, what risk adjustment companies provide needs to evolve with it.

Effective risk adjustment companies should combine experienced reviewers, data analysis, technology-supported workflows, provider education, quality checks, and performance reporting – with workflows aligned to the 2027 coding environment, including the unlinked CRR exclusion.

The goal is to make risk adjustment manageable throughout the year – not to simply increase the volume of coding activity at year-end.

Talk to 3Gen about building a 2027 risk adjustment strategy built for continuous management.

The role of risk adjustment services is changing – from finding diagnoses to helping providers understand where information is missing, where documentation needs attention, and where processes can be improved before they affect payment accuracy or audit outcomes.

This creates a more continuous workflow:

Find → Review → Improve → Monitor

That model helps providers make better use of the clinical information they already have, builds stronger documentation quality, and positions organizations more effectively when CMS conducts risk adjustment audits across multiple payment years.

3Gen Consulting provides risk adjustment solutions that help healthcare providers improve their processes through experienced review, technology, and ongoing quality support – aligned to the 2027 CMS requirements, including the V28 model and the unlinked CRR exclusion.

Our approach includes:

• Prospective, concurrent and retrospective chart review
• Documentation review and validation
• HCC coding quality checks aligned to V28 model
• Provider feedback and education
• Data analysis and performance reporting
• Risk adjustment audits preparation
• Ongoing risk adjustment support throughout the year

The focus is on helping providers build a process that works continuously – not treating risk adjustment as a once-a-year task that begins when the calendar pressure starts.

For healthcare organizations preparing for 2027, the providers that invest in stronger workflows, aligned risk adjustment solutions, and continuous management will be better positioned as CMS continues to refine both payment accuracy and program integrity oversight. Connect with 3Gen's risk adjustment specialists.