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What is the CMS-HCC Risk Adjustment Model?

Every patient deserves to receive exceptional care – regardless of the costs. But with over 31 million Americans enrolled on Medicare Advantage, how can providers ensure they anticipate and manage long-term healthcare expenses – especially given how different patients’ requirements are?

The answer is CMS-HCC risk adjustment – and this article provides a complete overview of how it works.

What is the CMS-HCC Risk Adjustment Model?

The CMS-HCC risk adjustment model is a methodology, implemented by the Centers for Medicare and Medicaid Services (CMS), intended to meet two requirements:

  • It ensures healthcare practices receive fair payment for the care they offer Medicare Advantage (MA) patients.
  • It ensures MA patients with higher-than-average care costs are still able to find providers willing to take them on.

How Does CMS-HCC Risk Adjustment Work?

A Basic Overview of Risk Adjustment

The cost of long-term patient care varies wildly based on individual requirements, and this creates a major hurdle for providers that work with Medicare Advantage patients. If all MA patients received the same funding, taking on higher-cost patients would lead to potential losses for providers – and create an incentive to only onboard lower-cost patients.

Risk adjustment is designed to ensure this does not occur. The CMS-HCC risk adjustment model adjusts Medicare Advantage reimbursements based on individual patients’ expected care costs and requirements. The CMS establishes a baseline cost for each county and calculates how much each individual patient will vary against that baseline – offering more funding to providers that take on patients with above-average requirements.

Using this baseline allows the expense of higher-cost patients to be offset by lower-cost patients – ensuring all can receive the treatment they need. Providers can confidently take on any MA plan, safe in the knowledge that extra services and care costs will be covered through its risk adjustment model.

How Does the CMS Calculate Patient Risk?

The CMS-HCC model uses two categories of data to calculate Individual patient risk:

  • Demographic factors, including age, sex, and location
  • Medical diagnoses

These two factors are combined to produce a risk adjustment factor (RAF) score which determines the patient’s MA reimbursement. The RAF score is benchmarked at 1; any variation from this baseline score will result in a change in funding. For example, an RAF score of 1.25 will lead to 25% higher-than-average reimbursement for the provider.

But before we explain how RAF scores work, we need to understand how medical diagnoses are recorded and submitted to the CMS.

Understanding HCC Coding

The CMS has developed an extensive list of medical codes known as hierarchical condition categories (HCC), which map over 70,000 specific diagnoses to 115 distinct categories. For example, HCC category 19, Diabetes with Chronic Complications, has 400 different diagnoses attached to it.

Healthcare providers undertake HCC coding to record each individual patient’s relevant HCC codes; they then submit the patient demographic data and HCC codes to the CMS.

How RAF Scores Are Produced

Once the CMS has your patients’ demographic data and HCC codes, they can calculate the patient’s RAF score. The RAF score is the sum of the patient’s:

  • Demographic Risk Scores: Every intersection of demographic factors has a risk score attached, based on historic data about the group’s average care costs.
  • HCC Coding Risk Scores: Each HCC code is given a risk score, based on the expected annual costs associated with the diagnoses. This score is specific to each intersection of demographic factors. For example, A patient added 70-74 with HCC37 (Diabetes with PVD) has a risk score of 0.166.

The CMS calculates the total risk score of all submitted HCC codes and adds it to the baseline demographic risk score; this is the patient’s RAF score.

Evaluating the CMS-HCC Risk Adjustment Model: How Has it Changed?

The CMS HCC model was first introduced in 2004 and has remained relatively stable since then. While there have been adjustments to the risk scores associated with each HCC code, the scores tended to change relatively little. A study from 2018 showed that recent updates had led to an average increase of 0.78%.

Of course, even such small changes can have a dramatic impact on Medicare reimbursements, and providers should always be aware of the shift. But it was only when a wholesale shift to a new model, known as V28, that many providers really understood how much was at stake:

  • 19 new HCC groups have been introduced
  • 2,294 HCC codes have been removed
  • 268 new HCC codes have been added

All of which is expected to decrease risk scores anywhere from 2% to 16%, depending on the patient’s condition.

These changes have been phased in gradually, but they will come into full force in 2025. This has placed a new level of pressure on providers to understand and improve their HCC coding – to avoid the common mistakes that lead to lower-than-expected reimbursements.

Three Common Challenges with CMS Risk Adjustment

1. Data Gaps

Accurate risk adjustment requires specificity, but many providers have gaps in their patient data. The data may be stored in multiple digital systems that are not interoperable; in unstructured notes that are not easily available; or even in other healthcare organizations which the provider cannot access.

This not only negatively impacts care; it makes it harder to complete accurate HCC coding and therefore receive the full reimbursement you are owed.

2. Coding Errors

Even when providers do have access to a complete medical history, they may make errors in the HCC coding. Individual providers may be required to code for diagnoses that are outside of their area of expertise, which leads to a lack of specificity – and can lead to the wrong HCC code being used.

3. Provider Time Constraints

Both issues discussed above are exacerbated by a lack of time and resources to complete HCC coding. Providers are already over-worked and want to focus on patient care; the extra effort of manual coding can lead to understandable errors or even incomplete coding.

Increase Your RAF Scores by 35% with HCC Assistant

HCC Assistant is an innovative tool that uses natural-language processing (NLP) to ingest huge quantities of patient data and make HCC coding recommendations at the point of care, with 97% accuracy. Providers can simply review and accept the codes they believe are appropriate, while rejecting any they don’t agree with.

As a result, providers save hours of manual effort while improving the accuracy of their HCC coding – and increasing their RAF scores by an average of 35%.

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