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For Medicare Advantage Plans, ACA Plans & Risk-Bearing Provider Groups

How to Choose a Risk Adjustment Coding Company

With CMS-HCC V28 fully phased in and RADV activity rising, your HCC coding vendor shapes both revenue accuracy and audit exposure. Here is what to evaluate, what to ask, and which red flags should end the conversation.

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Why Your HCC Coding Vendor Matters More Now

Three shifts have raised the bar. Any vendor you shortlist should explain how its process handles each one.

V28 Is Fully in Effect

CMS phased in V28 over payment years 2024 and 2025, and payment year 2026 runs entirely on it. V28 restructured the HCC hierarchy and dropped many diagnosis codes from payment, so V24-era rules and mappings now mislead.

RADV Exposure Is Growing

CMS has said it intends to audit far more Medicare Advantage contracts, and ACA issuers face HHS-RADV each year. Recovery rules have been litigated, but the core test is unchanged: every submitted HCC needs record support.

Chart Reviews Get Scrutiny

Federal oversight and enforcement have targeted diagnoses found only in chart reviews or health risk assessments, and programs that searched for adds without removing unsupported codes. Vendor method is now a compliance question.

Retrospective, Prospective, or Concurrent Review?

Most programs need more than one review type. A capable vendor supports all three and explains where each fits in your year.

Retrospective Review

Coders review past encounters before the submission deadline to find supported diagnoses that never reached claims and flag codes the record does not support.

Retrospective Review →

Prospective Review

Pre-visit chart preparation that surfaces suspected or previously documented conditions so the provider can assess and document them at the next visit.

Prospective Review →

Concurrent Review

Coding review after the visit and before the claim is final, so gaps can be fixed through a compliant provider query while the encounter is fresh.

Concurrent Review →

Chart Retrieval

No review beats the records behind it. Ask whether the vendor also retrieves charts from EMRs, fax, and onsite sources with secure chain of custody.

Chart Retrieval →

Six Things to Evaluate in Any HCC Coding Vendor

Compare proposals side by side. Ask for written answers and sample output, not slides.

Two-Way Coding

The vendor should report diagnoses to add and to delete, with both counts in every report. Deletes go to CMS as chart review delete records, cleaning your data before an audit does.

MEAT and TAMPER Support

Each coded condition should cite its support under MEAT (Monitor, Evaluate, Assess or Address, Treat) or TAMPER, from an acceptable face-to-face or audio-video encounter with an acceptable provider type, within the year.

Coder Credentials

Ask what share of your assigned team holds the AAPC Certified Risk Adjustment Coder (CRC) credential, what else they carry (CPC, CCS), and how V28 retraining was handled.

Accuracy and QA

Ask how accuracy is measured, what share of charts gets second-level QA, and whether high-impact HCCs get dual review. Tracking inter-rater reliability (IRR) shows consistency, not just averages.

Compliance Posture

Expect a signed BAA, HIPAA-compliant PHI handling, role-based access, guidelines tied to the ICD-10-CM Official Guidelines and Coding Clinic, and a query policy that never leads the provider.

Turnaround and Pricing

Get turnaround in writing, tied to your deadlines and volumes. Per chart pricing suits retrospective projects; hourly or FTE pricing suits ongoing prospective and concurrent work. Tie pricing to accuracy, never to HCCs added.

Warning Signs in a Retrospective Chart Review Vendor

Any one of these on the left is a reason to slow down. Two or more is usually a reason to walk away.

Red Flag
What Good Looks Like
Coding direction
One-way coding: only reports diagnoses to add
Two-way coding with adds and deletes in every report
Incentives
Fees or bonuses tied to HCCs added or RAF lift
Fees tied to charts, hours or FTEs, with accuracy standards
Sales pitch
Guaranteed RAF increases before seeing your data
A sample review first, then a scoped estimate
Evidence
Codes returned without page-level support
Every HCC linked to the MEAT evidence in the record
Source of codes
Codes from problem lists, labs or HRAs with no assessment
Codes only from acceptable encounters with documented assessment
QA
No second-level review, no IRR tracking
Defined QA sampling, dual review on high-impact HCCs, IRR reported

Ten Questions to Ask Before You Sign

Send these to every shortlisted vendor. Strong vendors answer directly, with sample reports.

  1. Do you code two ways? Show us a sample report with both add and delete counts.
  2. How is your process aligned to V28? When were your coding guidelines and software mappings updated, and how were coders retrained?
  3. What evidence comes with each HCC? Do you cite MEAT or TAMPER support with page references?
  4. Who will code our charts? How many hold the CRC, and what is their risk adjustment experience?
  5. How do you measure accuracy? What is your QA sample rate, do you dual review high-impact HCCs, and do you track IRR?
  6. How are you paid? Is any part of your fee tied to HCCs added or RAF change?
  7. What is your turnaround? How do you scale before the final submission deadline, and what happens if you miss it?
  8. How do you protect PHI? Will you sign a BAA, and how are access, devices, and offshore teams controlled?
  9. How do provider queries work? Can we see your query templates and query policy?
  10. Can you support a RADV audit? How do you help locate the best medical record and document support if CMS or HHS selects our members?

Valiant Lifecare works this way by default: credentialed coders, two-way findings, MEAT-linked evidence, and QA review, delivered from our Pune delivery centre with US-based account management. See how it fits together on our risk adjustment services and risk adjustment optimization pages, or read how we support plans on our health plans page.

Common Questions About Risk Adjustment Coding Services

Straight answers for health plan and provider group teams comparing vendors.

What does a risk adjustment coding company do?

A risk adjustment coding company reviews medical records for Medicare Advantage, ACA, and other risk-based members, abstracts diagnoses that are supported by face-to-face documentation, maps them to HCCs, and returns coded results that a health plan or provider group can submit or correct. A good vendor also flags unsupported diagnoses for deletion and feeds documentation issues back to providers.

Why does two-way coding matter for RADV audits?

RADV audits check whether submitted diagnoses are supported by the medical record. If a vendor only looks for diagnoses to add, unsupported codes already in your data stay there and become audit exposure. Two-way coding reports both adds and deletes, so the data you submit reflects what the record actually supports.

How does the CMS-HCC V28 model change vendor selection?

CMS phased in the V28 model over payment years 2024 and 2025, and payment year 2026 is calculated fully on V28. V28 restructured the HCC hierarchy and removed a number of diagnosis codes from payment HCCs. Your vendor's coding guidelines, software mappings, and coder training all need to reflect V28, not the older V24 model.

What credentials should risk adjustment coders hold?

Look for coders who hold the AAPC Certified Risk Adjustment Coder (CRC) credential, often alongside a CPC or an AHIMA credential such as CCS. Ask what share of the team assigned to your work holds the CRC, how often coders are retrained, and who reviews their work.

How are risk adjustment coding services usually priced?

The most common models are per chart, per hour, and dedicated FTE. Per chart pricing is predictable for retrospective projects but should be tied to accuracy standards. Hourly and FTE models fit ongoing prospective or concurrent programs. Be cautious of pricing tied to the number of HCCs added, since it rewards volume over accuracy.

Can Valiant Lifecare review a sample of our charts before we commit?

Yes. Our free HEDIS and risk adjustment gap review looks at a sample of your records and coding output and shows where documentation gaps, unsupported codes, and missed conditions sit, so you can judge our work before signing a larger engagement.

Test Us on Your Own Charts Before You Commit.

Send a sample of records and coding output. We will show where supported conditions are missing, where codes lack support, and what a two-way program would look like.