Adapting to CMS V28: Training Coders and Updating Documentation for Compliance

Adapting to CMS V28

The rollout of the cms v28 risk adjustment model is placing new demands on coding teams and documentation workflows, making targeted training and process refinement non-negotiable. With changes to HCC hierarchies, condition weighting, and specificity requirements, even seasoned coders need fresh guidance to ensure they meet compliance standards while safeguarding reimbursement accuracy. This is not just a matter of learning new codes—it’s about developing a shared understanding between providers, CDI teams, and coders to capture the most accurate representation of patient risk.

Elevating Coder Training to Match the Model’s Demands
The V28 updates require coders to interpret documentation with greater precision, particularly in linking conditions to their clinical context. Training should focus on identifying where common diagnoses have been reclassified or removed, and on understanding how to substantiate those that remain eligible. Hands-on case reviews, side-by-side coding comparisons, and model-based coding simulations can bridge knowledge gaps faster than traditional lecture formats.

Provider Engagement as a Compliance Strategy
Coders cannot work in isolation—provider documentation is the foundation of compliant coding. Building training programs that involve both providers and coders fosters a shared accountability for accuracy. Clear examples showing how one missing detail can change a patient’s risk profile help providers understand the direct impact of their documentation habits.

Embedding Documentation Updates into Daily Workflows
Updating templates, EHR prompts, and query processes to align with V28’s specificity requirements ensures changes are reinforced in real time. CDI specialists should monitor charts for omissions that could compromise both compliance and revenue, and provide immediate feedback to the clinical team.

Audit-Ready from the Start
Waiting until audit season to assess V28 readiness is risky. Internal audits should run parallel to daily operations, flagging documentation gaps before they affect submissions. Coders who are regularly exposed to audit-style reviews become more adept at self-correcting and maintaining consistency under the updated model.

Conclusion
Transitioning to the cms v28 risk adjustment model requires more than a one-time training session—it calls for a cultural shift toward continuous education, proactive documentation improvement, and closer collaboration between coding and clinical teams. By making these adjustments now, organizations can strengthen compliance, protect revenue, and ensure their coding practices remain resilient under ongoing regulatory change.

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