For years, retrospective chart review has been a pillar ofHCC risk adjustment strategy. Payers funded it. ACOs and IPAs operationalized it. Practices tolerated it. That era is now ending.
CMS's January 2026 Advance Notice for CY 2027 proposes a significant change: diagnoses from unlinked Chart Review Records will no longer count toward risk score calculation. If a diagnosis isn't tied to a specific beneficiary encounter — with a face-to-face visit and documented MEAT criteria— it won't be included. Audio-only encounters are excluded as well.
The estimated payment impact: -1.53% average across MedicareAdvantage plans. That's the price tag on a workaround the industry has relied on for years, and CMS is removing it.
Why This Change Is Coming
The logic behind CMS's move is straightforward: retrospective chart review, by design, captures diagnoses after the fact —often without clear evidence that a condition was actively managed, evaluated, assessed, or treated during the relevant period. It has also been a vector for inconsistent coding practices and audit risk under RADV.
CMS is signaling clearly that the future of risk adjustment is encounter-linked, clinician-confirmed, and prospective. Codes need to be documented during a face-to-face visit, tied to an encounter, and supported by clinical evidence that satisfies MEAT criteria — not abstracted from historical records months after the fact.
What This Means in Practice
For Medicare Advantage plans still dependent on retrospective workflows, the -1.53% hit is a direct financial consequence. But the downstream effects extend further. Risk scores that have been inflated by unlinked retrospective diagnoses will contract. Revenue projections built on those scores will need to be revised. And provider networks that have relied on post-visit chart reviews to close coding gaps will need to fundamentally change how they operate
For ACOs, CINs, and IPAs, the transition is equally significant. The administrative and financial infrastructure built around retrospective review — the chart chase vendors, the abstraction workflows, the post-visit outreach programs — loses its compliance footing under the new rule.
The Only Compliant Path Forward
The rule change doesn't eliminate HCC coding. It clarifies what counts. The compliant path is prospective, encounter-linked capture: conditions documented by a clinician, during a face-to-face visit, with MEAT criteria met, written into the EHR at the time of the encounter.
This is not a new clinical standard. It's the standard that was always intended. What's new is CMS's willingness to exclude data that doesn't meet it.
How Kennar Health Is Built for This
Kennar Health's platform was designed around prospective, point-of-care HCC capture from the start. When a patient with diabetes has lab values meeting criteria for CKD Stage 3, Kennar surfaces the HCC opportunity —with the specific supporting evidence — directly in context during the encounter. The clinician reviews the evidence, accepts or rejects the code, and pushes it into the EHR. Encounter-linked. MEAT-supported. RADV-defensible.
No retrospective chart chase. No unlinked records. No audit exposure.
For payers and risk-bearing entities working with practices on Kennar Health, this rule change isn't a penalty. It's a competitive advantage. While other plans absorb the -1.53% impact, organizations with prospective capture already in place are positioned to maintain accurate risk scores under the new standard.
The retrospective era is ending. Point-of-care is the only compliant lane remaining. The question for every MA plan, ACO, and IPA is whether their provider network is ready.
Kennar Health helps risk-bearing organizations capture HCC conditions prospectively, at the point of care, in a way that is encounter-linked, MEAT-supported, and RADV-defensible. To learn more, visitkennarhealth.com.
