Is Your Organization Ready for the Full Implementation of V28? Here’s What You Need to Know
- Rebellis Group
- Apr 11
- 2 min read
The Centers for Medicare & Medicaid Services (CMS) have introduced significant updates to the Hierarchical Condition Category (HCC) risk adjustment model, transitioning from Version 24 (V24) to Version 28 (V28). This change is designed to improve the accuracy of risk score calculations and better reflect current diagnostic, cost, and utilization patterns in the Medicare population, and will be fully implemented for PY2026 according to the 2026 Medicare Advantage (MA) and Part D Rate Announcement.
What’s New in V28?
Expanded HCC Categories
The number of HCC categories has increased from 86 in V24 to 115 in V28, providing a more granular and clinically accurate representation of patient conditions.
ICD-10-CM Integration
V28 fully integrates ICD-10-CM coding, enhancing specificity and better aligning diagnostic codes with risk adjustment logic.
Updated Data Calibration
CMS has updated the model using more recent data—2018 diagnoses and 2019 expenditures—to ensure the model reflects today’s healthcare environment.
Refined Condition Mapping
More than 2,200 diagnosis codes have been removed, and 200+ new codes added, improving the model’s predictive accuracy and relevance to patient outcomes.
Implementation Timeline
PY2024: Risk scores calculated using 67% V24 and 33% V28
PY2025: Transition to 33% V24 and 67% V28
PY2026: 100% V28 implementation
Strategic Recommendations
Enhance Documentation and Coding Practices
Educate physicians and coders to capture diagnoses with the specificity V28 demands.
Leverage Technology
Adopt AI and data analytics to support accurate risk capture and compliance.
Conduct Financial Impact Analyses
Understand how V28 affects your population and revenue outlook.
Invest in Continuous Education
Stay informed and agile as CMS continues to evolve models.
How Rebellis Group Can Help You Prepare for V28
At Rebellis Group, we specialize in helping health plans, providers, vendors and ACOs successfully navigate regulatory transitions like V28. Our support spans:
Risk Adjustment Impact Analysis
Analyze revenue shifts and prioritize conditions and coding strategies.
Coding & Documentation Review
Conduct detailed chart audits, identify gaps, and educate providers.
Compliance-Driven Strategy Development
Align with CMS rules to avoid compliance pitfalls and audit exposure.
Technology & Workflow Optimization
Enhance systems for complete diagnosis capture and coding accuracy.
Training & Stakeholder Engagement
Educate coders, clinicians, and leadership for lasting results.
Ongoing Monitoring & Support
Post-implementation tracking of RAF trends and strategic adjustments.
The Bottom Line
V28 isn’t just a coding update—it’s a shift in how risk and reimbursement are defined. Organizations that take proactive, data-driven steps now will be best positioned to protect revenue, improve care quality, and remain compliant.
Change is here—and Rebellis Group is already helping providers, plans, and vendors stay ahead. Ready to lead through the transition? Let’s move forward—together.
Missed our high-level analysis of the CMS 2026 Final Rule and Rate Announcement?
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