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Providers Are On a Deadline To Share Comments on the Future of Coding Risk Adjustment

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Hemant Apte, Chief Executive OfficerJanuary 20, 2026
Risk Adjustment Coding

Providers and payers have only a few days left to comment on proposed changes to the CMS risk adjustment model. If you want to keep up with and impact the future of coding risk adjustment, you should take action soon. 

CMS is actively reviewing aspects of diagnosis-based risk adjustment, including how the current HCC framework aligns with goals around equity, accuracy, and program integrity. While no replacement model has been proposed, CMS is seeking stakeholder input on potential refinements and whether additional data sources could complement existing approaches.

Proposed updates – particularly those related to how risk adjustment data is collected, used, and released – could have downstream implications for providers, including documentation workflows, audit strategies, and revenue cycle operations tied to risk adjustment coding.

For providers and revenue cycle leaders, this is an important opportunity to engage early. Thoughtful public comments grounded in operational experience can help ensure that future policy reflects real-world care complexity while maintaining compliance and transparency.

Public comments are currently due by the applicable Federal Register deadline (January 26, 2026).

Hemant Apte, Chief Executive Officer

Hemant Apte is the Founder and CEO of 3Gen Consulting, a leading healthcare revenue cycle management and technology company serving providers, ACOs, and health plans across the U.S. Since founding 3Gen in 2006, Hemant has guided the company’s evolution from a boutique consulting firm into a data-driven organization at the forefront of AI-powered RCM innovation. With decades of experience in U.S. healthcare operations, Hemant continues to provide thought leadership to clients navigating financial, compliance, and technology challenges in an increasingly value-based care environment.

Prepared for What Comes After CMS Risk Adjustment Changes?

Get expert guidance on how evolving CMS risk adjustment policies may impact your coding, compliance, and revenue strategy.

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Connect with our experts to:

  • Anticipate CMS risk model changes
  • Strengthen compliant coding workflows
  • Protect risk-adjusted revenue

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CMS is reviewing how diagnosis-based risk adjustment and the HCC model support equity, accuracy, and program integrity. While no replacement model has been announced as of January 2026, proposed refinements could affect documentation standards, data sources, and audit expectations tied to risk adjustment coding.

Changes to how risk adjustment data is collected, validated, or released can directly affect RAF scores and risk-adjusted revenue. Providers with weak documentation workflows or inconsistent coding practices may face increased audit exposure or payment volatility.

Public comments allow providers to share real-world operational insight on documentation burden, care complexity, and compliance risk. Engaging before the January 26, 2026 deadline helps ensure future risk adjustment policy reflects clinical reality – not just theoretical models.

Providers should assess clinical documentation integrity, HCC coding accuracy, audit readiness, and revenue cycle processes tied to risk adjustment management. Early review helps organizations adapt before policy changes are finalized.

Preparation starts with strengthening compliant coding workflows, improving prospective and retrospective reviews, and aligning clinical documentation with current CMS guidance. Organizations should also validate that internal QA and education processes are audit-ready.

3Gen brings nearly two decades of hands-on risk adjustment coding, compliance, and revenue cycle management experience. Our technology-enabled approach helps providers anticipate CMS changes, reduce risk, and protect risk-adjusted revenue – without sacrificing transparency or program integrity.