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INFERSCIENCE | POINT-OF-CARE AI | THOUGHT LEADERSHIP

The Encounter Is Now
the Evidence.

What Health Systems and Providers Must Do Right Now in Response to CMS's CY 2027 Final Rule and Rate Notice

2.48%
Finalized
Rate Change
$13B
Projected Boost
Above 2026
11
Stars Measures
Removed
CY 2027
Effective
Year

CMS published its CY 2027 Final Rule on April 2nd and the Rate Announcement on April 6th. Between the two documents, one message is unmistakable: the strategy of relying too much on retrospective diagnosis capture is not going to be sustainable.

The regulatory changes CMS finalized do not penalize clinical care—they penalize the distance between clinical care and documentation. That distance is exactly what Inferscience’s point-of-care AI platform is designed to close.

For health systems and providers managing Medicare Advantage patient populations, these two documents are not primarily about plan management. This impacts YOU and your physicians. They are a clinical workflow problem—one that begins and ends at the encounter.
“

CMS finalized the exclusion of unlinked chart review diagnoses from risk score calculation. This change combined with an increase in the rates in a heightened audit environment is a ‘double edged sword’ in complex HCC documentation and Care Gap closure. Every dollar and lift in quality scores needs to be encounter-based documentation. The right HCC Assistance & Validation in the EMRs will give clinicians like me the focus on actual patient care and the right reimbursement from my value-based care arrangements.

— Dr. Sunil Nihalani

1
The Unlinked Chart Review Exclusion: Documentation Must Live at the Encounter

Effective CY 2027, diagnoses submitted through chart review records that are not linked to a specific beneficiary encounter date will no longer count toward the risk score calculation. This is not a technical change. It is a fundamental redefinition of what counts as a valid clinical finding for payment purposes.

What Health Systems Must Do Now
  • Audit which HCC diagnoses in your MA population are currently captured through unlinked chart reviews versus encounter-linked documentation. Quantify the gap.
  • Deploy point-of-care AI that surfaces relevant HCC conditions at the time of the visit, before the note is closed, so that documentation happens at the encounter—not weeks later in a retrospective review.
  • Redesign clinical documentation workflows so that condition specificity, HCC-level coding, and complication capture become part of the encounter rather than an audit function.
2
Depression Screening & Follow-Up: Stars Performance Starts in the Exam Room

The Depression Screening and Follow-Up measure will enter Star Ratings in 2029 using 2027 measurement-year data, meaning the infrastructure work starts right now. It is the first behavioral health measure in Stars’ history, and it requires HEDIS ECDS reporting built on LOINC codes captured at the clinical encounter.

What Health Systems Must Do Now
  • Embed PHQ-2 and PHQ-9 screening into primary care workflows as a structured, LOINC-coded encounter element—not a paper form or a narrative note.
  • Configure point-of-care AI to alert clinicians when a patient is due for depression screening and to surface the PHQ-2 and PHQ-9 for positive screens within the same encounter workflow.
  • Establish automated 30-day follow-up triggers within the EHR or population health management platform for every patient who screens positive, making compliance a natural output of the clinical workflow.
3
Stars Clinical Measures Now Carry More Weight: Care Gap Closure at Point of Care

With 11 measures removed from Stars—most of them operational compliance metrics—the clinical measures that remain carry more mathematical weight per measure than at any prior point in the Stars program’s history. Diabetes care, medication adherence, preventive screenings, and CAHPS will separate high-performing contracts from the rest.

What Health Systems Must Do Now
  • Surface care gaps at the point of care—retinal eye exams for diabetic patients, medication adherence flags, overdue preventive screenings—so clinicians can act during the visit rather than through outreach after the fact.
  • Use point-of-care AI to prioritize the care gaps with the highest Stars impact for each patient, giving clinical teams actionable, measure-weighted recommendations rather than undifferentiated care gap lists.
  • Track care gap closure in real time against Stars measure denominators, giving population health teams visibility into performance trajectory before the measurement window closes.

The Bottom Line

CMS has drawn a clear line: documentation that occurs away from the clinical encounter counts for less—or not at all. Risk Adjustment performance that depends on retrospective outreach is structurally disadvantaged compared to performance built into the clinical workflow.

Health systems that deploy point-of-care AI to make encounter documentation complete, care gap closure automatic, and behavioral health screening systematic are not just responding to regulation—they are building the infrastructure that enables sustainable quality performance.

The encounter is now the evidence. Inferscience is built to make sure every encounter produces it.

INFERSCIENCE

Point-of-care AI helping health systems optimize clinical HCC documentation, Stars performance, and risk adjustment accuracy—in the flow of care, not after it.

inferscience.com