Risk Adjustment and Incentives for Upcoding in Medicare
In February 2023, CMS CMS published a notice of proposed rulemaking to update their HCC risk adjustment algorithm (v28). These changes included (i) leveraging ICD-10 rather than ICD-9 codes as the primary building blocks, (ii) use of 115 HCC indicators rather than 79, and (iii) constraining some coefficients to be identical across severity levels (e.g., diabetes, heart failure). The new algorithm will be phased in during 2024–2026.
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