Last week, CMS released the CY 2027 Advance Notice, which included some significant developments. We asked our CMO, Terrell Bacchus, M.D, FAAFP, for his take on these changes.
“The CMS CY 2027 Advance Notice is out, and it contains a clear message for Medicare Advantage: The era of retrospective “code mining” is coming to a close.
CMS is proposing to exclude diagnoses from unlinked chart reviews—those diagnoses found in old records but not tied to an actual patient encounter this year. The projected impact? A $7.2 billion reduction in payments to plans.
For years, many in the industry relied on these unlinked reviews as a safety net. But as a Chief Medical Officer in the AI space and having lived in VBC for most of my career, I see this as a long-overdue shift toward Clinical Documentation Integrity (CDI).
Why this matters 👇
👩⚕️ Care over Coding: If a diagnosis isn’t worth a doctor’s visit, CMS is rightfully signaling it isn’t worth a higher risk score.
⏲️ From Retrospective to Prospective: Health plans and providers can no longer wait until the end of the year to “find” risk. It must be captured, validated, and linked at the point of care.
🤖 The AI Mandate: Solving this manually is impossible at scale. AI that enables real-time, encounter-based documentation is no longer a “nice-to-have”—it’s a compliance requirement. The health plans and providers that win in 2027 won’t be the ones with the best “miners,” but the ones with the best clinical enablement tools.”
#HealthcareAI #ValueBasedCare #MedicareAdvantage #RiskAdjustment #HealthTech