Last week was a big week for anyone working in the Medicare Risk Adjustment space. Earlier in the week CMS published the long-awaited announcement on the final rule for RADV (Risk Adjustment Data Validation) Audits. Two days later, we got our first look at the “2024 Advance Notice with Proposed Payment Updates for the Medicare Advantage and Part D Prescription Drug Programs” notice and the proposed changes for the CMS-HCC Risk Adjustment Model for CY2024.
The proposed model V28 will be replacing V24. There are significant differences between these models. Let’s look at a few of the highlights:
Hierarchical condition categories restructuring
Nearly all the hierarchical condition categories (HCCs) have been renumbered and many have been renamed. The proposed model will include technical updates including restructuring of the condition categories based on ICD-10 rather than ICD-9 diagnosis codes, resulting in more granularly defined conditions within the categories. CMS is proposing to add 268 ICD-10-CM codes to the V28 model that do not risk adjust in the V24 model, and they have added 29 more HCCs.
Even with all these additions, there are 2,027 diagnoses that will no longer map to an HCC for payment. A few notable examples of diagnoses that are not in the V28 model: atherosclerosis of the extremities (PVD), angina pectoris, acute kidney failure, protein calorie malnutrition and toe amputations.
Another striking change is solid organ transplants were previously in HCC186 are now included in their corresponding body system condition. For example: Liver transplant status previously in HCC186 is now HCC62 along with other liver conditions.