V28 is fully phased in, RADV is now extrapolating, and MA crossed 51 percent.

Welcome to the first issue of The HCC Operator. We put this together for medical group execs, ACO leaders, and practice administrators working with Medicare Advantage. Each month we cover three things happening in the industry that affect your captured revenue, what they mean operationally, and one thing we're working on at ASP-RCM.

If you're not the right person for this, reply "unsubscribe" and we'll remove you. If you'd like to introduce us to the right person in your group, we'd appreciate it.

01V28 is fully phased in. Your RAF scores have moved.

CMS finished phasing in the V28 risk model this year. The headline number: the average RAF score is down 9.3 percent from V24 for the same patient population. That isn't because patients got healthier. It's because 2,300 ICD-10 codes were re-weighted and over 200 codes were removed entirely from the risk model.

Action item: run a V28 vs V24 RAF comparison on your last 1,000 closed encounters. If the average RAF dropped more than 5 percent, your coders are working from outdated rules. We see this in about 7 of every 10 practices we audit.

02RADV audits are back, and CMS is enforcing extrapolation.

The CMS RADV audit final rule has been in effect since 2024, and CMS is now actively recovering overpayments. Q1 2026 data shows $1.4 billion in MA plan recoveries. Most of that flows back to physician groups as contract clawbacks.

The shift that matters: extrapolation. A 200-chart audit finding a 12 percent error rate gets extrapolated across your full membership. A practice with 8,000 MA lives can see $1.2M to $3.8M in clawbacks from a sample of just 200 charts.

If you haven't run a RADV-readiness audit in 18 months or more, your downside risk has compounded.

03MA enrollment crossed 51 percent of Medicare.

KFF's April 2026 data: 51.4 percent of Medicare beneficiaries are now in MA plans, up from 48.2 percent in 2024. AHIP projects 58 percent by 2030. For physician groups, HCC capture isn't a niche program anymore. It's the dominant revenue stream for most multi-specialty practices.

Most of the practices we audit are at 60 to 72 percent capture rates. The top quartile sits at 88 percent or better. The gap is fixable with the right pre-encounter prep and real-time NLP support.

One thing worth 30 minutes this week

Pull your top 20 MA patients by visit volume. Compare each one's current problem list against last year's HCC codes. Count how many chronic conditions are missing from this year's documentation.

In our experience, the number is usually 4 to 7 per patient.

Multiplied across your full panel, that's where the $2 to $5M lives.