CMS CY2027 ADVANCE NOTICE

Where CMS CY2027 Policy Meets Operational Reality

A Health Plan Playbook for Risk Adjustment Readiness

The CMS CY2027 Advance Notice marks a fundamental shift in Medicare Advantage risk adjustment. While headline payment impacts may appear modest, the underlying redistribution of CMS-HCC coefficients across populations and conditions is anything but.

CMS is not simply recalibrating coefficients — it is recalibrating behavior.

Risk adjustment is moving away from volume-driven HCC capture toward quality of confirmation, encounter linkage, and longitudinal evidence. Plans that rely on unlinked chart review and retrospective volume will experience outsized downside, particularly across Dual and Institutional populations.

Invent Health’s CMS CY2027 Advance Notice Playbook translates regulatory change into a clear, actionable operating model. It helps health plans quantify impact, identify exposure, and operationalize the execution changes required to protect RAF, maintain audit confidence, and ensure revenue continuity.

What This Playbook Delivers

  • Clear interpretation of CY2027 CMS-HCC coefficient recalibration and policy signals
  • Population-level impact assessment across Community, Dual, Disabled, and Institutional models

  • Quantification of high-volatility HCCs and identification of upside vs. downside conditions

  • Insight into CMS’s emerging execution hierarchy and evidence expectations

  • A practical risk adjustment “ladder” from suspect to audit defense

  • Operational redesign guidance for supplemental data, specialty escalation, and longitudinal validation

  • A forward-looking framework to transition risk adjustment from coding activity to execution system

Key Focus Areas Covered

  • Population Sensitivity Analysis
    Understand where coefficient volatility is concentrated and why Dual Disabled and Institutional models face heightened exposure.

  • HCC Repricing Signals
    Identify conditions with significant coefficient expansion or compression and the documentation depth now required to sustain them.

  • CMS Execution Priorities
    Decode CMS’s implicit reward structure around encounter-linked diagnoses, specialty confirmation, and chronic persistence.

  • Operational Playbook
    Move beyond identification toward a closed-loop system that integrates suspecting, EMR linkage, specialty escalation, and audit defense.

Proven Strategic Value

  • Early visibility into RAF risk driven by CY2027 coefficient volatility

  • Reduced reliance on unlinked chart review and retrospective submission

  • Improved audit defensibility through longitudinal evidence chains

  • Clear prioritization of high-impact populations and conditions

  • Stronger alignment between risk, quality, encounters, and compliance teams

Access the Full Playbook

Download the CMS CY2027 Advance Notice Playbook to explore detailed population impacts, HCC-level shifts, and the operational changes Medicare Advantage plans must implement now to remain competitive.