In the transition from CMS-HCC V24 to V28, chronic conditions like Chronic Kidney Disease (CKD) and Chronic Obstructive Pulmonary Disease (COPD) remain risk-adjusting—but coding alone isn’t enough. To ensure these diagnoses hold up under scrutiny and contribute to accurate reimbursement, clinical documentation must demonstrate ongoing management.
Why This Matters in V28
Let’s look at how these chronic conditions are handled in the latest CMS-HCC model:
1. N18.32 – CKD, Stage 3b
HCC in V28: 328
Category: Moderate Chronic Kidney Disease (Stage 3b)
Relative Factor: 0.127
2. J44.9 – COPD, unspecified
HCC in V28: 280
Category: Chronic Obstructive Pulmonary Disease
Relative Factor: 0.319
While both diagnoses still map to HCCs, V28 emphasizes specificity and supporting clinical evidence more than ever. Payers and auditors expect clear, current indicators that the condition is being actively managed—not just mentioned.
Clinical Evidence That Supports CKD and COPD
N18.32 – CKD Stage 3b
To validate this diagnosis, your documentation should reflect:
GFR values consistently in the 30–44 range
Ongoing nephrology involvement
Regular labs: creatinine, BUN, electrolytes
Medication reviews (e.g., ACE inhibitors or ARBs)
J44.9 – COPD
To support this diagnosis under audit:
PFT results (showing FEV1/FVC < 0.7)
Prescribed inhalers or nebulizers
Specialist visits with pulmonology
Symptom notes: chronic cough, dyspnea, exacerbation history
Coding Tip: Link Diagnosis to Action
Coders must go beyond just capturing the diagnosis. Each encounter note should tie the chronic condition to a current assessment or plan:
Is the provider monitoring labs?
Was medication adjusted or prescribed?
Are symptoms being evaluated?
Without this level of detail, diagnoses like J44.9 or N18.32 may be excluded during risk adjustment filtering or flagged during RADV audits.
Final Thoughts
CMS’s V28 model continues to risk-adjust chronic conditions, but demands higher clinical specificity and documentation rigor. AI-enabled coding audits and encounter reviews can help flag insufficient documentation before submission—ensuring each diagnosis truly holds up.
Want to ensure your team is coding and documenting to V28 standards? Let’s talk