Why HCC Gaps Are Harder to Catch Under V28—and What to Do About It

Rose

May 27, 2025

HCC Gaps 

 

HCC Gaps used to hide in obvious places: old problem lists, partial diagnoses, or notes missing a single staging detail. Under the new model, those same oversights blend into the background, leaving coders and clinicians with less room for error and fewer cues to spot what’s missing.

Version 28 Shrinks the Margin for Error
The latest update trims the code map by thousands and redistributes weight across more condition groups. Some chronic illnesses now split into finer categories, while others merge or lose value altogether. A single word—“acute,” “chronic,” or a stage number—can swing the risk score by multiple points. Because the thresholds are tighter, a diagnosis captured last year might no longer boost the score unless every qualifier appears in the visit note.

Hidden Gap #1: Re-Used Templates
Pre-set macros save clicks yet often carry forward outdated staging or acuity. When the provider relies on auto-populated language, the record looks complete at a glance but fails the new specificity test. Build smart EHR prompts that grey out last year’s stage until today’s exam confirms it.

Hidden Gap #2: Partial Problem Lists
Version 28 engines rank related diseases within a family. If documentation lists only “diabetes” without the complication or insulin status, the hierarchy collapses to a lower weight. Train outpatient staff to add complication codes at intake, not after the fact.

Hidden Gap #3: New Hierarchies in Mental Health and CKD
Certain mental-health and kidney codes lost weight or tightened grouping logic. Coders scanning for high-value conditions may overlook them. Use a dashboard that flags any chronic diagnosis whose weight changed more than 10 percent so reviewers know where revenue could slip.

A Four-Step Fix That Sticks

  1. Run Dual Scoring on Last Quarter’s Claims
    Score each chart in both Version 24 and 28, then sort patients by score drop. Focus CDI queries on the top quartile of losses—these charts hold the quickest wins.
  2. Embed Real-Time Prompts
    Neuro-symbolic tools read the note as it’s typed, nudging the clinician to add “Stage 3 CKD” or “with neuropathy” before signing. A prompt that appears while memory is fresh cuts query response time by 70 percent.
  3. Put Coders and Clinicians on One Dashboard
    Shared metrics—note completeness, query turnaround, RAF lift—turn compliance into a team sport. When a clinic sees another department’s 24-hour query streak, pride does the coaching.
  4. Reward Precision, Not Volume
    Tie bonuses to first-pass claim acceptance and minimized denials rather than raw query counts. This shifts focus from catching mistakes to preventing them.

Small Wins, Big Payoff
A regional Medicare Advantage plan used these tactics on 15,000 lives. In six weeks, they recovered 4.3 percent of projected score loss, cut coder queries by one-third, and trimmed denial appeal time by 120 labor hours.

Conclusion
The journey from CMS HCC V24 to V28 rewards those who tighten documentation habits before the model fully phases in; teams that adapt now will see fewer surprises and steadier revenue when the final weights drop.