The End of Audio-Only Risk Adjustment: Why the CY 2027 Proposal Makes Documentation Quality Non-Negotiable

The CY 2027 Medicare Advantage Advance Notice sent a clear message that extends beyond just the crackdown on unlinked diagnoses. CMS is taking a hard look at the quality of the data sources used for risk adjustment, and another practice is squarely in the crosshairs: the use of diagnoses from audio-only telehealth encounters.

Alongside the proposal to exclude unlinked chart reviews, the notice reinforces the policy to exclude diagnoses sourced solely from audio-only visits from risk score calculations. For organizations that leaned heavily on telephonic wellness checks during and after the pandemic, this represents another critical revenue and compliance challenge that must be addressed now.

Why CMS is Devaluing Audio-Only Encounters

The logic behind this exclusion is straightforward and clinical. While audio-only visits are convenient, CMS argues they are not a sufficient basis for accurately diagnosing or managing many complex, chronic conditions.

• Lack of Objective Data: An audio call lacks the visual assessment of a video or in-person visit. A provider cannot observe a patient's physical condition, assess non-verbal cues, or perform a physical exam.
• Lower Standard of Care for Complex Conditions: For many HCCs, a thorough evaluation is required. CMS's position is that a simple phone call does not meet the clinical standard necessary to support a high-stakes diagnosis for payment purposes.
• Risk of Inaccurate Coding: Without a comprehensive evaluation, diagnoses made over the phone are more likely to be non-specific or based on patient reporting rather than objective clinical findings, increasing the risk of inaccurate coding.

This policy aligns perfectly with the broader CMS goal: to ensure that risk adjustment payments are based on high-quality, verifiable evidence of active disease management, not just a casual mention.

The Path Forward: A Strategy Built on Rich Documentation

This change doesn't mean telehealth is obsolete; it means the quality of the telehealth encounter is paramount. Video telehealth, which allows for visual assessment, remains a valid source. However, the most robust and defensible strategy will always be one built on a complete view of all clinical documentation.

This is where the MedChartScan platform provides an essential advantage. Our system is designed to thrive in a world that demands high-quality evidence.

• We Analyze the Full Spectrum of Clinical Data: MedChartScan ingests and understands the rich, detailed information from in-person visits, specialist consult notes, hospital discharge summaries, and video-based telehealth encounters. We turn this complex, unstructured data into your greatest asset.
• We Build a Defensible Audit Trail: Our platform was built to create an unbreakable link between a diagnosis and its proof. By focusing your risk adjustment efforts on evidence from high-quality encounters, you build a process that is natively compliant with the new CMS standards.
• We Insulate You from Regulatory Shifts: By relying on MedChartScan to build a comprehensive, evidence-based picture of patient health, your organization is insulated from the financial impact of policies that devalue low-documentation sources. Your risk scores are built on a foundation of clinical truth, not administrative shortcuts.

The message from CMS is clear: the source and quality of your data matter more than ever. It's time to move beyond practices that may have been permissible in the past and embrace a future built on deep clinical evidence.

Ensure your risk adjustment process is built for the new era of compliance. Schedule a demo to see how MedChartScan helps you build a strategy based on high-quality, defensible documentation.