New: independent coding checks for insurers and providers. See how Lens works →

Back

How Often Must HCC Diagnoses Be Documented?

· 3 min read
Risk adjustment

HCC diagnoses must be documented at least once every calendar year at a qualifying visit. See which dates of service count for 2027 and why timing matters.

HCC diagnoses must be documented at least once every calendar year to count toward a Medicare Advantage risk score. The diagnosis has to come from a qualifying encounter: a face-to-face or audio-video visit with an acceptable provider, where the clinician addresses the condition. Conditions not documented during the year drop out of the next year's score.

The rule follows from how the CMS-HCC model works. It's prospective: diagnoses from one year predict cost in the next, and the slate resets every January 1. A patient's twenty-year history of heart failure counts for nothing next year unless it's documented, and addressed, this year. What "addressed" has to look like in the note is covered in our guide to documenting each chronic condition.

Which dates of service count for 2027

CMS calculates each payment year's risk scores in three runs. For payment year 2027, its July 2026 implementation memo sets these data windows:

Risk score run Applied Dates of service used
Initial January 2027 July 2025 to June 2026
Midyear About July 2027 January to December 2026
Final About June 2028 January to December 2026

The midyear and final runs use the full 2026 calendar year. The initial run uses a rolling 12 months ending June 30, because the full year's data isn't in yet when payments start.

That creates a practical reason to document chronic conditions early. A condition documented in the first half of 2026 counts in the January 2027 initial run. One documented only in November 2026 doesn't count until the midyear run, with the difference reconciled later.

What makes an encounter qualify

Documenting a condition once a year only works if that encounter counts. The record needs:

  • A face-to-face or audio-video visit. For payment year 2027, CMS excludes diagnoses from audio-only services billed with modifier 93 or FQ. The July 2026 memo applies that exclusion starting with the midyear run.
  • An acceptable provider type: hospital inpatient, hospital outpatient or physician, from an acceptable specialty.
  • Authentication: a signature and credentials on the note.
  • A date inside the year. For inpatient stays, it's the discharge date that has to fall in the year.
  • The condition addressed, not just listed. A problem list entry or medication on its own doesn't show the condition was managed at that visit.

How the diagnosis reaches CMS matters too. For 2027, diagnoses on chart review records that aren't linked to a specific encounter are excluded from risk scores for non-PACE plans, with an exception for members who switched MA organizations.

Once is the minimum, not the target

One qualifying encounter a year is enough for the risk score. It isn't enough for good care or a strong audit position.

Under the ICD-10-CM Official Guidelines, chronic diseases treated on an ongoing basis are coded each time they're addressed. A condition documented at several visits during the year gives a coder more than one record to choose from, which matters in a Risk Adjustment Data Validation (RADV) audit, where each audited HCC can be supported by a limited number of records.

Status conditions are the most commonly missed. Amputation, ostomy, transplant and dialysis status don't change, but they still need to appear in a qualifying encounter's assessment every year to count. Conditions managed mainly by a specialist are the next most common gap: if the nephrologist or cardiologist sees the patient once a year, that visit has to happen, and be documented, within the calendar year.

Tracking which chronic conditions each patient still needs documented this year, across thousands of patients, is where most programs fall short.

Do HCCs reset every year?

Yes. The CMS-HCC model uses each calendar year's diagnoses to set the next payment year's risk score. Every chronic condition has to be documented again, at a qualifying encounter, each calendar year.

Is one visit a year enough to capture an HCC?

For the risk score, yes, if the visit qualifies and the note shows the condition was addressed. Documenting it at every visit where it's managed is better practice and gives more support in an audit.

Do telehealth visits count for HCC documentation?

Audio-video telehealth visits can count. For payment year 2027, diagnoses from audio-only services, identified by modifier 93 or FQ, are excluded from risk scores, starting with CMS's midyear model run.

When should chronic conditions be documented?

Any time during the calendar year counts toward the midyear and final runs. Documenting by June 30 also gets the condition into the next year's initial run, which sets the first months of payment.

This page is general education on risk adjustment documentation. It isn't a coding determination for any specific patient or encounter.

More from the Journal

All articles

See it on your own charts.