Risk Adjustment

Strategic Questions for Leaders

The questions every executive should be asking about risk adjustment — organized by stakeholder role

Source: CMS, MedPAC, OIG, industry analysis • Last updated March 2026

Why These Questions Matter

Risk adjustment is at a major inflection point: V28 is fully phased in, CMS has proposed excluding unlinked chart reviews ($7.2B impact), and RADV audits are expanding to all 550 eligible contracts. The organizations that ask the right questions now will be better positioned for what comes next. These questions are designed to surface blind spots, quantify exposure, and drive strategic action.

For Medicare Advantage Plan Executives

7 strategic questions

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Cross-Cutting Questions for All Stakeholders

Which risk adjustment model has the largest financial exposure for your organization?

Organizations operating across MA, MSSP, and ACA markets are exposed to three different risk adjustment regimes simultaneously. Understanding which model drives the most revenue — and the most risk — is foundational.

Is your CDI program calibrated for V28 specificity requirements?

V28 requires greater documentation specificity than V24. Many CDI programs are still optimized for V24 patterns. Conditions that used to be captured at a general level now require more specific coding to count toward risk scores.

How are you balancing risk score optimization with regulatory compliance?

The line between thorough documentation and inappropriate coding is being drawn more sharply with each passing year. OIG, MedPAC, and CMS are all signaling that aggressive coding practices will face increased scrutiny.

Are you investing in AI-assisted coding and documentation tools?

Organizations using NLP and AI tools report significantly higher coding accuracy and audit success rates. CMS itself is deploying AI for RADV — organizations that use AI for documentation will be better positioned when CMS uses AI for validation.

From Questions to Action

These strategic questions are designed to drive board-level and C-suite conversations. For each question your organization cannot answer with confidence, consider it a gap that needs immediate attention. The regulatory environment is moving faster than many organizations' ability to adapt.