HCC coding plays a critical role in risk adjustment models, particularly for Medicare Advantage, ACA, and Medicaid populations. The 2026 updates to Risk Adjustment documentation requirements focus on improving data accuracy, strengthening audit readiness, and supporting value-based care. Accurate documentation is essential not just for proper reimbursement but also for representing the true complexity of a patient’s health status.

This article outlines the HCC coding documentation requirements for 2026, providing coders, physicians, and compliance teams with actionable insights to meet regulatory expectations and avoid common pitfalls.

Key HCC Documentation Requirements for 2026

1. MEAT Criteria Still Applies But with Enhanced Scrutiny

MEAT (Monitor, Evaluate, Assess/Address, Treat) remains the cornerstone of HCC documentation. However, CMS and commercial payers have tightened expectations:

• Monitor: Tracking symptoms, labs, imaging, or signs of the condition.
  
• Evaluate: Reviewing test results or medication response.
  
• Assess/Address: Discussion of condition status or effect on patient care.
  
• Treat: Prescriptions, procedures, or referrals.
  

2026 Update: Each diagnosis must show clear provider engagement using MEAT elements. General mentions like “history of diabetes” will be considered insufficient unless properly substantiated with MEAT evidence.

2. Face-to-Face and Virtual Visit Validity

CMS recognizes face-to-face, telehealth, and audio-only visits under specific conditions.

• In 2026, only encounters with appropriate documentation, valid credentialing, and accurate diagnosis capture during eligible encounters will be accepted for risk scoring.
  
• Providers must clearly indicate the visit type, location, and credential in the note.
  

3. Chronic Conditions Must Be Documented Annually

Even if a chronic condition persists, CMS requires it to be evaluated and documented at least once every calendar year.

• Best Practice (2026): Don’t rely on historical data carry-forward. Every HCC-relevant diagnosis must be addressed with MEAT criteria each year.
  

4. Linkage Between Conditions and Treatment

The explicit connection between a diagnosis and treatment or management plan is vital.

• Example: Instead of saying HTN, stable, use:
  “Hypertension, well-controlled on lisinopril. Continue the same dose. BP 122/82.”
  
• 2026 Focus: Avoid ambiguity. Use clear language that links the disease with management steps.
  

5. Use of Standardized Terminology and ICD-10-CM

With the ICD-10 2026 updates, coders must:

• Use the most specific codes.
  
• Avoid using unspecified codes unless fully justified.
  
• Check for any HCC mapping changes introduced in the 2026 ICD-10-CM and CMS-HCC model updates.
  

6. Provider Signature and Credentials Mandatory

Documentation must include:

• Legible provider signature
  
• Date of service
  
• Credential (MD, DO, NP, PA)
  

2026 Compliance Warning: Notes without valid signatures or credentials will be rejected during RADV audits.

7. Valid Source Documents Only

HCCs must be abstracted from valid sources:

• Office visit notes
  
• Consultations
  
• Discharge summaries
  
• ER visits
  

Not accepted:

• Problem lists without supporting documentation
  
• MAO-generated suspect lists without MEAT documentation
  
• Historical notes without current year updates
  

Best Practices for 2026 HCC Documentation

Implement a Provider Education Program

Regular training sessions should emphasize:

• MEAT documentation
  
• Common HCC coding errors
  
• Use of specific ICD-10 codes
  
• Annual updates on CMS HCC model changes
  

Conduct Retrospective and Prospective Chart Reviews

• Retrospective reviews help identify missed HCCs and ensure compliance before submission deadlines.
  
• Prospective reviews aid providers in capturing accurate data during current visits.
  

Use EHR Smart Templates

Develop templates that prompt providers to:

• Address chronic conditions at least annually
  
• Document MEAT elements
  
• Link diagnoses to plans and treatment
  

Run Internal Coding Audits

Conduct audits quarterly or semi-annually to:

• Catch undercoding or unsupported diagnoses
  
• Ensure alignment with CMS guidelines
  
• Improve coder and provider performance
  

Monitor RAF Score Trends

Keep track of RAF scores at the patient and population level to ensure:

• Risk is appropriately captured
  
• Financial accuracy in payer contracts
  
• Proactive outreach for high-risk patients
  

Common Pitfalls to Avoid in 2026

• Documenting without MEAT
  
• Using outdated or nonspecific ICD codes
  
• Copy-pasting diagnoses without updates
  
• Relying on problem lists as primary sources
  
• Omitting provider credentials or signatures
  

How 2026 CMS-HCC Model Changes Affect Documentation?

CMS has shifted to Version 28 (V28) of the HCC model with the following implications:

• Fewer HCC categories, leading to greater specificity in accepted codes.
  
• Removal of certain combinations (e.g., diabetes + CHF) as weighted contributors unless independently documented.
  
• Greater emphasis on clinical validity of diagnoses.
  

Need help with HCC coding and Risk Adjustment audits?
At Alpine Pro Health, our certified coders and auditors specialize in compliant HCC abstraction, retrospective and prospective reviews, and AI-enabled RAF optimization. Contact us today to ensure your 2026 documentation meets every compliance benchmark.

Final Thoughts

The 2026 HCC coding documentation requirements reflect CMS’s ongoing push toward transparency, accuracy, and accountability. Coders and providers must work collaboratively to ensure that every chronic condition is properly evaluated and supported with compliant documentation.

By embracing MEAT-driven practices, updating coding protocols, and staying ahead of regulatory changes, organizations can improve their audit readiness, optimize RAF scores, and contribute to better patient care outcomes.