Did CMS finalize a new Part C HCC risk adjustment model for 2027?

No. In the final April 6, 2026 Rate Announcement, CMS said it will continue using the 2024 Medicare Advantage risk adjustment model for non-PACE MA organizations in CY 2027. CMS had proposed a newer model in the January 26, 2026 Advance Notice, calibrated with 2023 diagnoses and 2024 expenditures data, but did not finalize that change for non-PACE plans. For coders, the active Medicare Advantage HCC model does not reset for 2027.

What should HCC coders recheck after the 2027 Medicare Advantage Rate Announcement?

Four things are worth a coder's time. First, check whether internal education still reflects the January 26, 2026 proposal rather than the April 6, 2026 final policy, especially on the audio-only exclusion, which is conditional not absolute. Second, check whether diagnoses came from audio-only visits, and if so, whether another eligible service line exists on the same encounter. Third, confirm chart review findings are linked to a valid encounter. Fourth, verify documentation support is strong enough to defend the submitted ICD-10-CM code.

Does the 2027 model decision apply to PACE organizations the same way?

No. CMS finalized a different approach for PACE organizations in 2027, using a blended model rather than continuing the 2024 MA risk adjustment model at 100%. The non-new-model decision described in this post applies specifically to non-PACE Medicare Advantage organizations. Teams supporting PACE plans should review the 2027 Rate Announcement directly for the PACE-specific model details.

2027 MA Rate Announcement: What HCC Coders Need

CMS finalized 2027 MA payment rules on April 6, 2026. No new Part C model, audio-only and unlinked CRR exclusions now final. Here's what changes your workflow.

CMS finalized the 2027 Medicare Advantage Rate Announcement on April 6, 2026.

The Part C model does not reset for 2027. CMS will keep using the 2024 MA risk adjustment model, the same one that reached 100% implementation in CY 2026.

What does change: two source-of-diagnosis rules are now final policy. Diagnoses from audio-only services will be excluded from risk score calculation under specific conditions, and diagnoses from unlinked chart review records (unlinked CRRs) will also be excluded, with a narrow exception for beneficiaries who switch between MA organizations.

Your code mapping work doesn't reset for 2027. The pressure point is source quality and encounter linkage, not the HCC map.

What Changed in the Final 2027 Rate Announcement

Expected average MA payments increased by 2.48 percent year over year, or more than $13 billion.

At the same time, CMS tightened which diagnoses can count toward risk scores.

1. CMS Kept the Current Part C HCC Model for 2027

In the January 26, 2026 Advance Notice, CMS proposed updating the Part C risk adjustment model with more recent Original Medicare data.

In the April 6, 2026 final Rate Announcement, CMS stepped back from that proposal for MA organizations and said it will continue using the 2024 MA risk adjustment model for CY 2027.

The V28 transition just hit 100% in PY2026. You are not also rebuilding a new Part C crosswalk for 2027.

If you're on the V28 model mappings now, you stay there. No new crosswalk to rebuild, no new HCC numbering to relearn.

For PACE organizations: CMS finalized a different blended model for 2027. This post covers non-PACE MA organizations only.

2. Audio-Only Diagnoses: Final Rule Has a Condition

CMS finalized the exclusion of diagnoses from audio-only services using modifiers 93 or FQ.

Here's where the original drafts of internal education may have gotten this wrong: the exclusion is conditional, not absolute.

CMS excludes the audio-only diagnosis only when no other line on the same encounter data record, chart review record, or FFS claim is risk-adjustment eligible. If another eligible service line exists on the same encounter, the diagnosis can still count toward the risk score.

What that means in practice: don't treat modifier 93 or FQ as an automatic disqualifier. Check the full service record first. If a valid risk-adjustment eligible service line appears on the same encounter, the diagnosis path may still be open.

If an audio-only service is the only eligible line, the diagnosis won't count for 2027 risk score calculation. It may still matter clinically and operationally. The exclusion is a payment rule, not a documentation rule.

3. Unlinked Chart Review Records Will Not Count

CMS also finalized the exclusion of diagnoses from unlinked CRRs from risk score calculation.

An unlinked CRR is a chart review record that isn't tied to a specific beneficiary encounter. Under the final policy, diagnoses from those records won't count toward 2027 risk scores.

The narrow exception: beneficiaries who switch from one MA organization to another. For everyone else, the linkage has to be there.

This is the same direction CMS signaled in the January 2026 proposal, now confirmed as final. The difference from what was proposed is the addition of that MA-switcher carveout.

What Didn't Change for Coders

If you were bracing for another full model reset, this is the calmer part.

The 2024 CMS-HCC model (V28) stays active for 2027.

The crosswalk doesn't move. The hierarchy rules don't change. The MEAT documentation standard doesn't change.

The main coding pressure point for 2027 isn't a new HCC map. It's whether the diagnosis source and chart support are defensible.

What to Recheck Now

Does This Diagnosis Come from a Valid Risk-Score Source?

For 2027, source matters as much as the code itself.

If a dx came from an audio-only service, check whether another risk-adjustment eligible service line exists on the same encounter before concluding it's excluded. If the audio-only visit is the only eligible line, the dx won't count for 2027 risk scoring.

If a dx came from a chart review record, check whether that record is linked to a beneficiary encounter. An unlinked CRR won't carry the diagnosis to the risk score under 2027 policy.

Linkage is now the gating question.

The /icd10-to-hcc tool can help you confirm whether the code itself still maps under the current model. Source verification is the coder's call from there.

Is the Diagnosis Linked to a Real Encounter?

The unlinked CRR policy reinforces what RADV has always required: encounter connection.

If your workflow has relied on retrospective chart review findings without encounter linkage, that workflow is now explicitly weaker for payment purposes. Tighten the encounter linkage, provider-addressed documentation, and support checks before submission.

For the documentation standard on what "addressed" means, the MEAT criteria hub is the practical starting point.

Is Your 2027 Training Still Teaching a New Model Rollout?

Some teams may have draft education built around the January 2026 proposal.

That content needs a reset. The final policy did not adopt a new Part C MA risk adjustment model for 2027. If your training deck says coders need to learn a new MA HCC model for 2027, it's stale.

The same applies to the audio-only exclusion: if internal training describes it as absolute, it needs the conditional language added.

Are You Over-Relying on Chart Review Without Encounter Linkage?

This is the operational risk inside the policy update.

If a team built productivity around unlinked chart review captures, that workflow is now weaker for payment purposes in 2027. The safest adjustment is tightening encounter-linked documentation review, provider-addressed conditions, and support checks before submission.

The encoder is useful for spot-checking HCC mappings and source code details as you review charts.

For Team Leads and QA Managers: A Starting Checklist

Pull a sample of recent diagnoses sourced from chart review and ask these questions:

Is the diagnosis tied to a valid encounter, or was it from an unlinked CRR?

If it came from an audio-only service, is there another eligible service line on the same encounter?

Was the condition addressed by the provider in defensible documentation?

Are internal tip sheets still describing the January 2026 proposal audio-only framing as absolute?

Does any 2027 training material still describe a new Part C HCC model rollout?

That review will tell you whether the real gap is coder education, source tagging, encounter linkage, or documentation support.

What Happened Before the Final: Context on the Proposal

If your team has been following the 2027 rulemaking since January, the final rule mostly confirmed what CMS proposed, with one meaningful addition.

CMS proposed both the audio-only and unlinked CRR exclusions in the January 26, 2026 Advance Notice. The final rule adopted both, and added the MA-switcher exception for unlinked CRRs.

The proposal to update the Part C risk adjustment model with newer data did not make it into the final rule for non-PACE MA organizations.

For the full backstory on the unlinked chart review proposal, see our earlier coverage: CMS proposes ban on unlinked chart reviews for Medicare Advantage 2027.

Where HCC Buddy Fits

HCC Buddy helps coders check ICD-10-CM code details, HCC mapping, and related references faster.

It doesn't decide whether a diagnosis came from a risk-adjustment eligible source. That's the coder's call, based on the service record, the encounter documentation, and the policy rules above.

For 2027, the lookup speed matters because your team needs more time on the part CMS is tightening: source quality and encounter support, not the code map itself.