
Risk Adjustment
Modernizing Medicare Risk Adjustment
Short-Term Steps for Long-Term Sustainability
Risk adjustment is a system that keeps providers and plans financially stable by accounting for how sick patients are — so payments to health care providers are fair, no matter who they treat. Risk adjustment uses data (like age, medical conditions, and past health care use) to predict how much care each patient is likely to need.
CMS attempted to improve the current risk adjustment model, which relies on outdated approaches/data and unfortunately leads market distortions in how funds are redistributed, by reducing payments tied to certain diagnoses to limit inappropriate overpayments, though the change overlooks common but underdiagnosed conditions—like chronic kidney disease, obesity, and major depressive disorder—that still require attention but don’t affect provider payments. Modernizing the Medicare risk adjustment system to account for common population health risk factors is a key component of enhancing payment accuracy, reducing administrative burden, and promoting prevention-oriented care for Medicare beneficiaries.
By The Numbers
$50 billion
estimate of Medicare Advantage overpayment in 2021 ¹
1%-22%
variations in coding intensities among the top 20 Medicare Advantage plans ²
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Approach and Impact
The Accelerator is focused on improving the HCC model by using real-world data and empirical insights. We assess how clinical data (like lab results or pharmacy data from EHR-derived sources) can supplement traditional billing data to make risk adjustment more accurate and less burdensome. The expected impact of this work includes:
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Building evidence to compare the effectiveness and workload of using clinical data versus claims data.
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Exploring new technologies (like bulk FHIR) to make data sharing easier and reduce administrative work.
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Creating short-term policy recommendations that support a shift from paying for volume to paying for value in Medicare.
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Gaining support and agreement among stakeholders for a better alternative to the current HCC system.
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Utilizing shared learning and data collaboration to refine and support the rollout of the proposed approach.
Duke-Margolis Project Team

Audrey Ford, MS
Policy Research Associate

Kylie Brown, MPH
Policy Analyst
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Frank McStay, MPA
Assistant Research Director

Sara Debab
Policy Analyst
West Health Project Team

Namrata Uberoi, PhD, MPH
Director, Health Policy

Chris Crowley, PhD
Director of Strategy, West Health Institute
Project Collaborators

Michael McWilliams, MD, PhD
Warren Alpert Foundation Professor of Health Care Policy, Professor of Medicine, Department of Health Care Policy, Harvard Medical School

Purva Rawal, PhD
Former Chief Strategy Officer, Center for Medicare and Medicaid Innovation