Risk Adjustment / CMS-HCC V28

V28, Fully Phased In: What the Final Blend Year Does to 2026 Risk Scores

CY2026 is the first payment year that runs on 100% CMS-HCC V28. The three-year blend is over, and the softening effect of the old V24 weights goes with it.

The short answer: in 2026 there is no V24 cushion left. Every risk score is calculated entirely on the V28 model, so the categories V28 remapped to lower coefficients or dropped from payment stop being partly offset by the old model. The conditions that lose the most are diabetes without a mapped complication, several vascular and atherosclerosis codes, and a large block of ICD-10 codes that no longer map to any payment HCC. The fix is coding specificity and documentation, not new diagnoses.
33%
CY2024
First V28 year, blended with 67% V24
67%
CY2025
V28 majority, 33% V24 remaining
100%
CY2026
Blend complete, V28 only

The phase-in, year by year

Three years to reach full weight

CMS introduced V28 in the CY2024 Rate Announcement and blended it against V24 on a fixed schedule. Each year the share of the risk score coming from V28 climbed. In 2026 it hits the top of the ramp and stays there.

24
CY2024Blend begins
V24 · 67% V28 · 33%

V28 arrives, but two-thirds of the score is still calculated on V24. Plans and provider groups feel a nudge, not a shock. The remapped diabetes and vascular categories are mostly masked by the old weights.

25
CY2025V28 majority
V24 · 33% V28 · 67%

The weighting flips. Now two-thirds of the score runs on V28, and the gaps left by dropped codes start showing up in year-over-year score trends. Groups that leaned on soft diabetes and vascular capture begin to see the drift.

26
CY2026Blend complete
V28 · 100%

No V24 left. The 2026 Medicare Advantage and Part D Rate Announcement (released April 7, 2025) confirms the final step. Every remap and removal now lands at full weight, on top of the statutory 5.90% minimum coding-pattern adjustment and the updated normalization factor. This is the year the model change is fully priced into revenue.

What changed under the hood

The V24 to V28 structural shift

115
Payment HCC categories in V28, renumbered from the 86 in V24. More buckets, but tighter clinical definitions.
~2,000+
ICD-10-CM codes that mapped to a payment HCC under V24 but no longer map under V28.
5.90%
Statutory minimum MA coding-pattern adjustment, applied again in the 2026 Rate Announcement.
3yr
Blend runway from CY2024 to CY2026, ending at 100% V28 with no phase-in left.

Category and code counts reflect CMS-HCC model V28 as published in the CY2024 Rate Announcement and carried through the CY2026 Rate Announcement. Figures describe the model structure, not any single plan's results.

Where the 2026 hit concentrates

The HCC categories that move scores the most

Not every condition changed. The revenue impact clusters in a handful of high-volume categories where V28 either remapped the code to a lower coefficient or removed it from payment entirely. A few categories actually improved. Here is where to look first.

Diabetes

Highest-volume category in most panels, so small per-member changes scale fast.

Largest aggregate hit

Under V24

  • Separate, higher-weight buckets for diabetes with complications
  • Vague diabetes still captured meaningful value

Under V28 (2026)

  • Diabetes categories consolidated with a flatter coefficient
  • The old complication differential is compressed, so unspecified diabetes loses ground unless the linked complication is coded to specificity

Vascular disease and atherosclerosis

Peripheral vascular and several atherosclerosis codes no longer stand alone.

Codes removed from payment

Under V24

  • Peripheral vascular disease mapped to a payment HCC
  • Atherosclerosis without complication carried weight

Under V28 (2026)

  • Many of these codes drop out of the payment HCC set
  • Value now depends on documenting the downstream event or complication, not the underlying vascular diagnosis alone

The unmapped-code block

Roughly 2,000+ ICD-10 codes that used to map now map to nothing.

Silent leakage risk

Under V24

  • Broader code-to-HCC crosswalk captured softer documentation

Under V28 (2026)

  • Coders keep submitting the same codes, but they no longer generate a payment HCC
  • The loss is invisible on the claim, which is why it survives into the blend's final year

Chronic kidney disease, stage 3

One of the categories that V28 expanded rather than cut.

Newly capturable

Under V24

  • Earlier-stage CKD often fell outside the payment set

Under V28 (2026)

  • CKD stage 3 is recognized in the payment model
  • An offset for panels that document renal staging cleanly, so the lab-to-code workflow is worth the effort

What operators should do before year-end

Turning the model change into a work plan

Re-map your top codes

Run your highest-volume diagnosis codes against the V28 crosswalk and flag the ones that no longer produce a payment HCC.

Tighten diabetes capture

Where a complication exists, document and code it to specificity so the linked condition carries the value the flat diabetes weight no longer does.

Chase the expansions

Build a lab-to-code loop for CKD staging and the other categories V28 added, so you capture the offsets you are now entitled to.

Re-baseline the model

Reset revenue expectations to a 100% V28 run rate. Any forecast still carrying blended assumptions from 2024 or 2025 is now optimistic.

Guidelines referenced on this page. Everything above traces to published CMS materials. Coefficients and category treatment come from the CMS-HCC risk adjustment model V28 as issued in the CY2024 Rate Announcement, and the phase-in completion is confirmed in the 2026 Rate Announcement.
▸ CMS-HCC Risk Adjustment Model, Version 28 (V28) ▸ 2026 Medicare Advantage and Part D Rate Announcement (released April 7, 2025) ▸ V24-to-V28 three-year blend schedule: CY2024 33% / CY2025 67% / CY2026 100% ▸ Statutory MA coding-pattern adjustment, minimum 5.90%

Know your 2026 exposure before it hits the remittance

ASP-RCM Solutions re-maps your active diagnosis panel against V28, quantifies the categories bleeding value in the first full-weight year, and builds the documentation and coding workflow to recover it. No fabricated projections, just your codes against the current model.

Request a V28 impact read → or talk to a risk-adjustment lead