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Four Magazine > Blog > Tech > Compliance by Design: Updating Policy Manuals for CMS HCC V24 to V28 Alignment
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Compliance by Design: Updating Policy Manuals for CMS HCC V24 to V28 Alignment

By Prime Star July 21, 2025 4 Min Read
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Ensuring that policy manuals are up to date is a critical step in maintaining compliance in risk adjustment. As CMS rolls out the changes from HCC V24 to V28, healthcare organizations must revisit their documentation and coding policies to align with new requirements. Policy updates that reflect CMS HCC V24 to V28 rules serve not only as a compliance safeguard but as a foundation for consistent, accurate risk adjustment across the organization.

Why Policy Updates Matter More Than Ever

CMS HCC V28 introduces refined definitions, new condition groupings, and updated coding guidelines that impact how chronic diseases and comorbidities are captured. Many existing policies remain anchored to previous versions, leading to potential misunderstandings or missed requirements. Without timely updates, providers and coders risk noncompliance, inaccurate risk scores, and financial penalties.

Policy manuals guide clinicians, CDI teams, and coders on documentation standards, query protocols, and coding practices. Ensuring these policies reflect the latest CMS guidance is essential to fostering consistent documentation quality, minimizing discrepancies, and supporting accurate risk capture.

Building Policies that Support Clinical Realities

Updating policies isn’t about adding complexity—it’s about clarity. Clear, accessible policies help providers understand exactly what details must be documented to support each condition under V28. For instance, specifying the need to document disease stage, severity, or causal relationships provides practical direction for capturing nuanced clinical information.

Policies should also align with clinical workflows. They must balance thoroughness with usability, avoiding overly burdensome requirements that can lead to resistance or superficial documentation. Involving clinicians, CDI specialists, and coders in policy development ensures that guidelines are both clinically relevant and operationally feasible.

Integrating Training and Communication

Policy updates only work when staff understand and embrace them. Rolling out new or revised manuals should be paired with comprehensive training programs tailored to each role. Providers need to grasp the connection between documentation detail and risk adjustment outcomes, while coders and CDI teams require clear instructions on how to apply updated guidelines consistently.

Ongoing communication channels help reinforce policies and provide forums for questions and clarifications. Regular audits and feedback loops tied to policy adherence support continuous improvement and build confidence across teams.

Leveraging Technology to Enforce Policy

Modern risk adjustment software can embed policy requirements directly into documentation workflows, prompting providers in real time to capture necessary details. Automated alerts and coding validations help prevent deviations from updated policies, supporting compliance without slowing care.

Technology also enables tracking of policy adherence, highlighting areas where documentation falls short of expectations. This data supports targeted training and policy refinement, creating a dynamic cycle of improvement.

Conclusion

Policy updates that reflect CMS HCC V24 to V28 rules are more than paperwork—they are strategic tools for embedding compliance into daily practice. By designing clear, practical policies and pairing them with education, communication, and technology, healthcare organizations can ensure that documentation and coding remain accurate, consistent, and aligned with evolving regulatory standards. This compliance by design approach strengthens risk adjustment outcomes and protects financial integrity, paving the way for long-term success.

TAGGED: Policy Manuals

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