The codes moved. The weight moved with them.
Here is the short version. Under the CMS-HCC V28 model, now fully in effect for the 2026 payment year, diabetes was consolidated and several vascular categories lost their risk weight entirely. A chart that was clean under V24 can quietly under-report risk under V28 if you keep documenting to the old categories. This page lays the two models side by side for the conditions that move your RAF the most: diabetes and peripheral vascular disease.
V28 is not a relabel. It is a smaller, stricter map.
CMS finalized V28 in the CY2024 Rate Announcement and phased it in over three years, so 2026 dates of service are scored on the full V28 model. Three structural shifts drive almost everything you will see below.
Up from 86 in V24. More categories, renumbered end to end, so old HCC numbers no longer map one to one.
Down from roughly 9,800 in V24. Thousands of ICD-10-CM codes that used to map to an HCC no longer do.
With, without, and unspecified complications now sit far closer in weight. The old gap you chased has largely closed.
Unspecified atherosclerosis and plain peripheral vascular disease can drop out of a payment HCC in V28.
Read it left to right: where each category lands in V28.
HCC numbers below follow the CMS V24 and V28 category structures and the FY2026 ICD-10-CM to HCC crosswalk. Verdicts show whether the weight is retained, shifted, or dropped from the payment model. Confirm exact coefficients against the current CMS software before any submission.
Diabetes mellitus (E08–E13)
Vascular & peripheral artery disease (I70–I79)
The quiet revenue leak
The vascular drop is the one that catches teams off guard. A patient coded to I73.9 (peripheral vascular disease, unspecified) or I70.209 (unspecified atherosclerosis of native arteries of extremities) captured an HCC under V24 and captures nothing under V28.
The fix is clinical specificity, not a code swap: capture the ulcer, the gangrene, the claudication severity, the affected vessel and side when the record supports it, so the encounter lands in HCC 263 or 264 instead of nowhere.
Relative category weight, V24 versus V28.
Bars show relative direction of the risk weight within each condition family, not exact coefficients. The pattern is what matters: acute and complicated categories hold, the unspecified floor thins out.
Four moves that keep diabetes and vascular risk on the model.
Stop chasing the diabetes complication gap
Under V28 the reward for pushing "with complication" over "without" shrank. Code the manifestation that is actually documented and MEAT-supported. Do not manufacture specificity the record cannot defend.
Flag every uncomplicated PAD chart
I73.9 and unspecified I70 codes now capture no HCC. Route these encounters to a query workflow: is there an ulcer, gangrene, rest pain, or a documented vessel and side that supports HCC 263 or 264?
Recode against the FY2026 crosswalk
Old V24 favorites can be dead weight now. Re-run active problem lists through the current ICD-10-CM to HCC mapping so recapture targets reflect what V28 still pays for.
Document to survive RADV
Every retained HCC is a RADV target. The ulcer site, the laterality, the complication link, and the provider signature all have to be in the note, not inferred from a code.
V28 recapture only counts if it survives RADV.
The CMS Risk Adjustment Data Validation program checks whether the diagnosis on the claim is supported by the medical record. As you recapture the diabetes and vascular HCCs that V28 still pays for, each one raises your audit surface. A retained HCC 263 needs the ulcer and its site in the note. A retained HCC 37 needs the chronic complication documented and linked. Map first, then make sure the chart can defend the map.
Every code you recapture under V28 should trace to provider documentation that meets RADV support standards for that date of service.
- CMS-HCC V28 condition-category structure, finalized in the CY2024 Medicare Advantage and Part D Rate Announcement, phased in through the 2026 payment year.
- ICD-10-CM to CMS-HCC mapping, FY2026 diagnosis crosswalk published with the CMS risk adjustment model software.
- CMS Risk Adjustment Data Validation (RADV) program requirements for medical-record support of submitted diagnoses.
- ICD-10-CM Official Guidelines for Coding and Reporting, FY2026, for diabetes (E08–E13) and vascular (I70–I79) code specificity.
HCC numbers and mappings reflect the published CMS category structures. Exact risk-adjustment coefficients change by payment year; confirm against the current CMS model software before submission. Weight bars show relative direction, not coefficient values.
See exactly which of your diabetes and vascular charts lost weight in V28.
ASP-RCM Solutions runs your active diagnoses through the FY2026 V28 crosswalk, flags the categories that dropped out, and builds the query and documentation workflow that keeps your legitimate risk on the model and defensible under RADV. No fabricated recapture, just the codes V28 still pays for.
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