CMS-HCC V28 2026: 115 HCCs, 100% Phase-In

The V24/V28 blend schedule (2024 to 2027)

CMS introduced V28 as a three-year blend to smooth revenue impact on MA plans. Each payment year's RAF score is computed twice (once under V24, once under V28) and the results are weighted:

Coders auditing claims for a specific payment year should apply the weighted model in effect for that year. The RAF score calculator can toggle between V24 and V28 for the same diagnosis list, which is the fastest way to see how a mixed panel shifts between payment years.

One detail in that table catches teams out every year: the dates of service that drive a payment year run 12 to 24 months earlier than the payment year itself. PY2026 RAF, the first year scored on 100% V28, is built largely on encounters from January through December 2025. Those visits have already happened. V28 documentation work was never something that could wait for 2026 to start, and the same lag applies to every year that follows.

Code families to recheck: valid codes that stopped paying

A code being valid in the ICD-10-CM code set does not mean it still maps to a payment HCC. In its December 2024 Report to Congress, CMS puts the 2024 CMS-HCC model (V28) at 7,770 ICD-10-CM codes mapped to payment HCCs, down from 9,797 under the 2020 model (V24). Of the 2,236 codes that dropped out, CMS attributes 96.6% to routine ICD-10-CM clinical updates rather than a targeted policy decision, which makes this a specificity problem as much as a model change. These are the families most likely to still be sitting on an old tip sheet.

Angina is the clearest example

I20.9 (angina pectoris, unspecified) mapped to V24 HCC 88, Angina Pectoris. It carries no payment HCC under V28. The same holds for I20.1 (with documented spasm), I20.89 (other forms, which is where stable angina lands), and I25.119 (atherosclerotic heart disease with unspecified angina). V24 HCC 88 has no V28 successor.

Do not widen that to the whole family, because the exception is the one worth catching. Unstable angina kept its category: I20.0 and I25.110 both map to V28 HCC 229, Unstable Angina and Other Acute Ischemic Heart Disease, at 0.240, up from V24 HCC 87 at 0.195. So the split inside I20 and I25.11 is acuity: unstable pays, stable and unspecified do not. Two codes that pay in neither model, and are often assumed to: I25.10 (atherosclerotic heart disease without angina) and I10.

Unspecified PVD and claudication got much less forgiving

V24 rewarded a broad vascular bucket. V28 does not. I73.9 mapped to V24 HCC 108, Vascular Disease, and has no V28 payment HCC. Same for I70.213 (atherosclerosis with intermittent claudication, bilateral legs). The family did not disappear, though. Rest pain moves the code into HCC 264, Vascular Disease with Complications (0.455), and ulceration or gangrene reaches HCC 263 (1.118). The difference between I70.213 and I70.233 is documented severity, not the disease label. If the note stays at claudication, there is nothing to capture.

Unspecified depression lost the automatic path

F33.9 (recurrent, unspecified) mapped to V24 HCC 59 and carries no V28 payment HCC. F32.9 (single episode, unspecified) is the harsher case: it maps to nothing under either model, so it was never the safe fallback some worklists treat it as. F33.1 (recurrent, moderate) maps to HCC 155, Major Depression, Moderate or Severe, without Psychosis. F33.3 (severe with psychotic symptoms) maps to HCC 152, Psychosis, Except Schizophrenia. When you look up HCC 152 and see "Psychosis," that is correct; the psychotic features are what move the code there, not the depression severity alone. The chart that loses RAF is recurrent depression with no severity documented.

Malnutrition came off the model entirely

V24 rolled the whole malnutrition family into HCC 21, Protein-Calorie Malnutrition. Under V28 that category has no successor for these codes: E40 through E46, R64 (cachexia), and E88.A all carry no CMS-HCC V28 category. Severity never tiered this HCC in the first place, so there is no "keep the severe one" carve-out to hunt for. Keep coding it when the record supports it; it remains an audit-scrutinized diagnosis and it still drives acuity and quality measures. It just does not move the Part C RAF.

Substance use: the rule is not "moderate or severe only"

This one is widely mis-stated. For alcohol, only dependence maps: F10.20 reaches HCC 139 (0.242) while F10.10 (alcohol abuse, mild) carries no HCC at all. For other drugs, even mild uncomplicated use disorder maps: F11.10 (opioid abuse) reaches HCC 138, Drug Use Disorder, Mild, Uncomplicated, Except Cannabis, at 0.423, which outweighs the alcohol category and sits above it in the hierarchy. Check the substance before you assume the severity threshold.

And the trap that runs the other way

Not every V28 story is a loss. E11.65 (type 2 diabetes with hyperglycemia) started in the V24 chronic-complications tier (HCC 18, the same tier as diabetic CKD and neuropathy) and lands in V28 HCC 38, the no-or-unspecified tier. It dropped a full tier, not just a number. Meanwhile E11.9 went the other way, from 0.105 under V24 to 0.166 under V28. The honest summary is that the diabetes tier itself stopped being where the value sits, since V28 sets HCC 36, 37, and 38 to the same 0.166; the value now comes from the separate manifestation HCCs that stack on top. Before you write off any familiar code, check it against the current mapping file rather than last year's deck. A code that paid under V24 but not V28 is still a valid code, and an auditor does not care what the old training said.

The 2026 HCC list, chronic conditions by category

The 2026 V28 payment HCC list is organized by clinical body system. The categories below are the highest-frequency HCCs across the Medicare Advantage population, the ones most MA plans see on 60%+ of risk-adjustable enrollees. A full category-to-category mapping against specific ICD-10 codes lives on the ICD-10 to HCC mapping hub, and every individual code can be looked up via the HCC Buddy encoder.

The top 10 HCC codes across the MA population and the top 10 miscoded HCCs reports are the quickest way to prioritize chart review capacity for 2026. Both lists are HCC Buddy-maintained and updated against the current V28 coefficient set.

MEAT documentation under V28

V28 did not change the MEAT documentation standard, every HCC submitted still requires Monitor, Evaluate, Assess, or Treat evidence in a face-to-face encounter during the payment year. What V28 changed is which conditions are worth the documentation effort. Provider education decks that previously emphasized vascular disease and mild depression should be reweighted toward diabetes specificity, heart failure severity, and CKD stage. See the MEAT criteria hub for the framework, the provider query templates for AHIMA-compliant prompts, and the RADV audit prep guide for how V28 documentation stands up under audit.

The parallel 2023 RADV final rule removed the fee-for-service adjuster and allowed CMS to extrapolate audit findings across contracts, which means unsupported V28 HCCs now produce larger payment recoveries than unsupported V24 HCCs would have under the prior rule. Compliance teams treating V28 as "just a coefficient change" are misreading the risk.

Practically, the MEAT bar under V28 is higher for the conditions that still pay. A diabetes encounter that previously cleared audit with "DM, on metformin, stable" now needs to name the complication (neuropathy, CKD stage, retinopathy) to land on a V28-mapped code like E11.22 , and the MEAT narrative has to support that specificity. Heart-failure notes that said "CHF, continue Lasix" need to document systolic vs diastolic, acute vs chronic, and the clinical monitoring that justified the encounter. Coders who learned V24-era shortcuts, accepting a "history of" phrase as MEAT, or letting ambiguous laterality ride, will see those charts flagged on the first RADV pull under the 2023 rule. Retraining the chart-review rubric is not optional; it is the difference between keeping and refunding V28 dollars.

The shift also changes what provider-education sessions should emphasize. Under V24, "code to the highest specificity" worked as a generic mantra because almost every chronic condition carried some RAF weight. Under V28, the three diabetes tiers (HCC 36, 37, and 38) all carry the same 0.166 base weight, so moving E11.9 to E11.22 does not, by itself, lift the diabetes coefficient. What specificity unlocks is the separate manifestation HCC: documenting the CKD behind E11.22 lets you also capture the kidney-disease category on top of diabetes, and documenting a foot ulcer (E11.621) captures HCC 383 in its own right. The uncomplicated code is not unmapped; the RAF lift comes from the additional mapped condition the specificity lets you code, not from a higher diabetes tier. Education content should lead with the map, not with the alphabet, and coder-QA dashboards should surface under-specified diabetes and heart-failure encounters as rework candidates, not as pass-through clean claims. Teams that rebuild their provider-facing cheat sheets to the V28 hierarchy code to the categories V28 actually pays; decks still written to V24 categories can steer coders toward HCCs that no longer map under V28, under-capturing where the model now rewards specificity. The same logic applies to retrospective chart review: V24-trained reviewers will flag dozens of "missed" HCCs per chart that no longer map, burning reviewer hours on zero-yield rework. Re-scoping the review queue to V28-mapped categories is a one-time project that pays back in the first quarter.

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