Writer: Hemant Apte, Chief Executive Officer
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 in
Hemant Apte, Founder & Chief Executive Officer of 3Gen Consulting, is a seasoned executive leader with deep domain expertise in US healthcare management practices. He founded 3Gen Consulting in 2006 and has been instrumental in offering thought leadership to his clients and providing services and solutions that are unique in the market.