Risk Adjustment · CMS-HCC V28 · PY2026

Recapture season has a clock, and it resets every January 1st.

Under CMS rules, a chronic condition only counts in the year it is documented from a face-to-face encounter. It does not roll forward. If diabetes with complications was captured in 2025 and never re-documented in 2026, the risk score drops to zero on that condition. This is the checklist our V28 engine runs on every chart to make sure that does not happen quietly.

The
answer

Every chronic HCC must be re-documented at least once each calendar year. Our engine takes last year's captured conditions, cross-checks 2026 encounters, and surfaces the ones that are suspected but not yet coded for provider review. It flags the gap. It never invents the diagnosis.

01 / Why recapture is not optional

The annual reset is a CMS requirement, not a best practice

CMS-HCC risk scores are rebuilt from scratch every payment year off the diagnoses documented in the prior calendar year. A condition documented in 2025 does not persist into the 2026 model run. Miss the re-documentation window and the member's risk score, and the care they qualify for, silently deflates.

JAN 1 RESET 2026

Zero carryover. Every condition re-earns its place.

The risk-adjustment year runs on the calendar. On January 1, 2026, every chronic HCC captured in 2025 dropped back to unproven. It has to be re-documented through a qualifying 2026 encounter to count for the payment year.

V28 is the model doing the counting. The CMS-HCC V28 model, finalized in the CY2024 Rate Announcement, completes its three-year transition at PY2026, when payment is fully weighted to V28.

Source: CMS CY2024 & CY2026 Rate Announcements
V28
The model that pays in 2026

PY2026 payment is fully weighted to CMS-HCC V28. The V24 blend that softened the transition is gone.

Remapped
ICD-10 to HCC crosswalk

V28 recalibrated the crosswalk and constrained several categories. Codes that mapped to an HCC under V24 may no longer, so last year's capture logic cannot be trusted blind.

RADV
Audit exposure

The CMS RADV Final Rule (2023) enables extrapolated recovery of unsupported diagnoses. Every recaptured condition needs encounter-level documentation behind it.

02 / The gap-closure checklist

The chronic conditions the engine flags for 2026 re-documentation

These are archetype conditions, not real patients. For each one the engine watches the prior-year capture plus the clinical signals in this year's chart, then hands the provider a prompt to confirm and document with MEAT (Monitor, Evaluate, Assess, Treat). The checkmark is earned only when the 2026 encounter closes the gap.

Diabetes with chronic complications

E11.2– / E11.3– / E11.5–
Recapture signal watched

Active A1c orders, insulin or GLP-1 on the med list, standing ophthalmology or podiatry referrals.

MEAT reminder

Link the complication, not just "diabetes." The generic code and the complication map to different HCCs under V28.

Congestive heart failure

I50.– (specify type)
Recapture signal watched

Loop diuretics, a recent echo or BNP result, cardiology follow-up on the calendar.

MEAT reminder

Document systolic vs diastolic and acuity. Unspecified heart failure leaves specificity, and score, on the table.

V28 · CKD granularity

Chronic kidney disease, stage 3–5

N18.30 – N18.5 / N18.6
Recapture signal watched

An eGFR trend line in the labs, a nephrology referral, dialysis or transplant status codes.

MEAT reminder

V28 keys on stage. Stage 1–2 no longer carries the same weight, so the specific stage has to be in the note.

COPD

J44.0 / J44.1 / J44.9
Recapture signal watched

Inhaled bronchodilators or steroids, a prior exacerbation, pulmonary function testing.

MEAT reminder

Note whether an exacerbation is active. Acuity changes the code and the documentation the auditor expects.

V28 · BH restructure

Major depressive disorder

F32.– / F33.– (recurrent)
Recapture signal watched

Antidepressants on the med list, a documented PHQ-9, behavioral health referral.

MEAT reminder

V28 reorganized behavioral health categories. Capture severity and single vs recurrent episode, not "depression, unspecified."

Vascular disease & PAD

I70.– + Z-status
Recapture signal watched

Antiplatelet therapy, a prior revascularization or amputation status, an ABI result.

MEAT reminder

Tie atherosclerosis to the vessel and any complication. Bare "history of" language does not support the recapture.

How the engine surfaces the gap without inventing a diagnosis

This is the line that keeps recapture compliant. Suspect analytics point a clinician at a condition that looks likely from the record. They never write the diagnosis. Confirmation is a clinical act, documented at a face-to-face encounter, every time.

Pull prior-year captures

Every chronic HCC documented in 2025 becomes a candidate that must be re-earned in 2026.

Read this year's signals

Labs, med lists, referrals and problem lists in the 2026 chart, aligned to CMS chart-review and HRA guidance.

Flag suspected, not coded

Where a signal is strong but no 2026 diagnosis exists yet, the engine raises a suspect prompt for the provider.

Provider confirms with MEAT

The clinician evaluates, confirms or rules out, and documents. Only then does the checkmark turn green.

The guardrail, stated plainly. The engine never fabricates data and never auto-adds an unconfirmed condition. It surfaces a documented signal and hands the decision to the clinician. That is what keeps a recaptured diagnosis defensible under RADV, and it is a hard line we do not cross.

Run this checklist across your whole panel before the year gets away from you.

Recapture is a volume problem with a compliance edge. Doing it chart by chart in a spreadsheet leaves score, and defensibility, on the table. Our V28 engine runs the gap-closure checklist across every member, routes suspect prompts to the right clinician, and keeps the documentation trail an auditor will accept. You keep clinical judgment where it belongs. We handle the surfacing, the tracking, and the proof.

Guideline references: CMS-HCC V28 model (CY2024 Rate Announcement); CY2026 Rate Announcement (PY2026 fully weighted to V28); CMS annual diagnosis-recapture requirement (conditions documented each calendar year from a qualifying face-to-face encounter, no carryover); CMS RADV Final Rule (2023); CMS chart-review and Health Risk Assessment guidance. MEAT is a widely used clinical-documentation framework. Condition examples are archetypes and do not represent any real patient. This page is educational and is not coding or legal advice.