Annova Vantage May 2026
A monthly briefing on healthcare strategy, risk, quality, and compliance.
In April, CMS made the economics of Medicare Advantage more challenging for payers and providers alike. The chart review exclusion is now final, the RADV audit cycle is running on a quarterly cadence, and OIG published its first comprehensive MA compliance guidance in over two decades. Underneath the headline rate increase of 2.48%, operational demands now appear to outpace revenue tailwinds, but is that really the case? In this month’s Annova Advantage, we break it all down for you.
CMS Finalizes Exclusion of Unlinked Chart Review Diagnoses from CY 2027 Risk Scores
CMS finalized the exclusion of diagnoses from unlinked chart review records in the Rate Announcement published on April 6, save a narrow exception for MA-to-MA switchers. FFS-to-MA switchers do not qualify. The net payment impact is negative 1.53%, or negative 1.78% without the exception.
Fundamentally, the chart review program is not the problem for many health plans, but rather broken encounter linkage workflows. The plans likely to struggle with this requirement don’t have a clean system-level match between chart review findings and encounter data. They have misaligned retrieval vendors, coding teams, and reconciliation processes that were not built for this requirement. The September 2026 PY 2025 final reconciliation window is the first hard checkpoint. What percentage of your 2025 retrospective output can be matched to a qualifying encounter today? Is your system optimized right now to meet this requirement?
CMS Finalizes 2.48% Net Payment Increase for CY 2027 After Pulling Back on V28 Recalibration
CMS finalized a net payment increase of 2.48%, adding approximately $13 billion to MA payments for CY 2027, substantially above the 0.09% in the January Advance Notice. The driver was CMS’s decision not to finalize the proposed recalibration to 2023 and 2024 data, leaving V28 unchanged for CY 2027.
The 2.48% belongs in your June 2026 bid assumptions. What does not belong there is confidence that recalibration is permanently off the table. CMS was explicit that it will revisit recalibration for CY 2028. A plan that builds its multi-year financial model around a frozen V28 might be underpricing a scenario CMS has already telegraphed.
Forced MA Disenrollment Reached 2.9 million in 2026, a Tenfold Increase from Historical Averages
Johns Hopkins researchers found approximately 2.9 million MA enrollees faced forced disenrollment in 2026, which represents a 10x increase from historical averages. Seven states saw net enrollment decline for the first time.
Payers that adopt displaced members from competitor exits don’t just increase enrollment; they inherit populations with documentation histories that do not match your internal assumptions. A member coded under a different plan’s retrospective program can enter your RAF calculation with HCCs your team did not capture but you must manage. This represents an immediate integrity problem sitting in your 2026 bid-to-cost ratio. How can plans ensure the actual risk carried aligns with new members’ documentation history? Hint: it begins with tried-and-true chart retrieval.
CMS Final Rule Removes 11 Star Measures and Adds Depression Screening Starting Measurement Year 2027
The CY 2027 Final Rule removes 11 Star Ratings measures including Plan Makes Timely Decisions About Appeals and Reviewing Appeals Decisions. The Health Equity Index reward was not implemented. A new Part C Depression Screening and Follow-Up measure begins measurement year 2027, affecting Star Year 2029.
The administrative measures being removed were performing well for most plans and masking weaker CAHPS and HOS positions. With that safety net gone, CAHPS plus HOS moves toward roughly 40% of Star weight by 2029. The behavioral health screening workflow has a January 1, 2027 compliance date. This means that for most plans, there is not enough runway to build from scratch. There is enough, however, to adapt what you already have, provided you start now.
Coding Intensity Adjustment Held at Statutory Minimum of 5.9% for CY 2027
CMS held the coding intensity adjustment at the statutory floor of 5.9% for CY 2027, continuing downward pressure on effective risk scores regardless of the V28 model freeze.
Plans that improved documentation quality under V28 and expect to see that reflected in RAF score growth need to account for this offset. The coding intensity adjustment applies before risk scores translate into bid-level revenue. What does this mean in real-world scenarios? A program that added 2% to average risk score through better documentation may capture less than 1.5 points in actual payment. This is frequently where internal dashboards diverge from what actuaries are working with.
CMS Confirms PY 2020 RADV Audits are Active with Five-Month Record Submission Window
CMS confirmed PY 2020 RADV audits initiated on March 20, 2026 are inside their five-month medical record submission window. PY 2021 through 2024 audits are initiating on a roughly quarterly cadence with sample sizes ranging from 35 to 200 enrollees per contract.
If your contract is on the PY 2020 list, the records submission deadline is August 2026. Vendors supporting simultaneous retrospective review programs and RADV record pulls will triage under volume. Contracts not currently in the audited cohort should still budget retrieval capacity for one cycle in 2026 and another in early 2027. It’s generally accepted that episodic audits are now a thing of the past—continuous auditing appears to be the norm.
OIG’s 2026 Compliance Guidance Identifies Risk Adjustment as a Systemic Enforcement Priority
The OIG also released its first comprehensive compliance guidance for Medicare Advantage organizations in over two decades on February 3, 2026. The guidance applies explicitly to vendors and downstream entities, not just health plans, and places risk adjustment at the center of it all. Under increased scrutiny are chart review and HRA programs that add diagnoses without paired processes to verify accuracy.
For health plans, this means that capturing diagnoses and auditing documentation are no longer separable activities. OIG’s framework describes a compliance architecture most plans have partially but not fully built. This guidance lands at the same time CMS is running a continuous RADV audit cycle and DOJ has a renewed FCA working group with MA as its priority. It’s easy to see that these are not independent developments. Plans that treat this as a strategic roadmap rather than advisory commentary will be in a materially different audit posture when enforcement cases start to close.
Upcoming Conferences: Connect with us
Annova Solutions will be exhibiting and presenting at the 15th Annual Medicare Stars, HEDIS®, and Quality & Risk Summit in Chicago this June. We’re proud to be a Premier Sponsor!
The 15th Medicare Stars, HEDIS®, Quality & Risk Summit
Dates: June 2-4, 2026
Location: Hilton Rosemont O’Hare, Chicago, IL
The conference agenda centers on navigating the CY 2027 regulatory changes, Stars weight redistribution, and HEDIS performance in a tightening measurement environment. As a Premier Sponsor, we have a limited number of complimentary passes to give away! If you want to attend the conference at no cost to you, let us know ASAP. Complimentary guest passes are available on a first come first serve basis. Email us at info@annovasolutions.com and claim yours.
About Annova Solutions: With expertise in high-yield chart retrieval and HCC reviews, we support mission-critical Medicare Advantage operations for both payers and providers. We guarantee quality, accuracy, defensibility, and complete transparency. If documentation gaps, HEDIS chase, or risk adjustment data integrity are on your list, learn how we can help by visiting our website or, if you’re in Chicago this June, stop by our booth to discuss your needs.