CMS is excluding unlinked chart review diagnoses from Medicare Advantage risk adjustment starting with 2026 dates of service. Every HCC now has to trace to a documented encounter. Here is what changes, and how to stay ahead of it.
Let's talkAn unlinked chart review is a chart audit that produces a diagnosis code with no encounter record showing a service was actually provided. CMS is now excluding those diagnoses from Medicare Advantage risk scores.
Plans have long used unlinked chart reviews to raise beneficiary risk scores, and payments, without a documented visit behind the code. Starting with 2026 dates of service, CMS is finalizing the exclusion of unlinked chart review records (and audio-only encounters) from risk adjustment. The change is projected to reduce MA payments by roughly 1.53%, or more than $7 billion, in 2027. There is a limited exception for beneficiaries who switch from one MA organization to another.
Codes recovered by chart audit without a linked encounter no longer count. Back-end review alone is no longer enough.
The reliable way to keep every HCC is to capture and document it during the visit, tied to a real encounter.
With tighter scrutiny and expanding RADV audits, every diagnosis needs MEAT-supported evidence behind it.
Inferscience is built for the world after unlinked chart review. Its HCC Assistant surfaces missed and suspected HCCs during the visit, inside the EHR, at 98% coding accuracy, so diagnoses are documented against a real encounter rather than recovered afterward.
Its HCC Validator then confirms every diagnosis meets MEAT criteria before submission and links each code to its source documentation, building a defensible, RADV-ready trail. Together they replace the risk-adjustment value that unlinked chart review used to provide, in a way that holds up under CMS scrutiny. A 700-provider clinically integrated network has coded with Inferscience inside athenaOne since 2020.
An unlinked chart review is a chart audit that generates a diagnosis code without any encounter record showing a service was actually provided. CMS is excluding these diagnoses from Medicare Advantage risk adjustment.
CMS finalized the exclusion in its CY2027 Rate Announcement (April 2026). It applies starting with 2026 dates of service, affecting 2027 payment.
CMS projects the change will reduce MA payments by roughly 1.53%, or more than $7 billion, in 2027 compared to 2026.
Shift from recovering codes by retrospective chart audit to capturing and documenting diagnoses at the point of care, tied to a real encounter and supported by MEAT evidence. Real-time, EHR-native coding is the most reliable way to do this.
HCC Assistant captures HCCs during the visit inside the EHR, and HCC Validator confirms MEAT support and links each code to its documentation, so your risk scores stay accurate and defensible without relying on unlinked chart reviews.
See how Inferscience keeps your risk scores defensible after unlinked chart review.
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