# CMS CY 2027 Advance Notice

Feb 19, 2026

Last week, CMS released the CY 2027 Advance Notice, which included some significant developments. We asked our CMO, [Terrell Bacchus, M.D, FAAFP](https://www.linkedin.com/in/terrell-bacchus-m-d-faafp-8196a861?trk=organization_guest_main-feed-card-text), 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.”