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V28 is no longer a transition issue. It is the live operating environment for Medicare Advantage risk adjustment in 2026. CMS completed the three-year phase-in of the 2024 CMS-HCC model for CY 2026, meaning plans and providers are now operating under the full model rather than a blended version.
That makes mid-year the right moment for a hard operational check. Not a high-level “how are we doing?” review, but a specific look at whether documentation and coding workflows are actually performing under V28. The key question is not whether conditions are eventually being found somewhere in the process. It is whether they are being documented clearly, specifically, and defensibly early enough to matter.
Teams that wait until year-end to answer that question lose time they cannot get back. Mid-year is where you find out whether your program is built on first-pass accuracy or retrospective cleanup.
What should risk adjustment teams measure first under V28?
Risk adjustment teams should first measure whether diagnoses are being captured accurately and supported completely during the encounter. Under V28, first-pass capture and documentation support matter more than downstream recovery because the model now operates fully on the updated CMS-HCC logic, and CMS continues to publish 2026 initial and midyear/final ICD-10 mappings and model software that teams need to track as the year progresses.