Care, Capture, Growth, Flow: 2026 Risk Adjustment Deadlines and a Five-Month Framework for Medicare Advantage Plans
By Subbu Ramalingam, Managing Director, Risk Adjustment, Stars & Quality, ATTAC Consulting Group
Originally published in the Vivega Health newsletter on August 6, 2026. Read the original here →
The Star Rating Preview period has officially begun, and litigation over how CMS calculates the ratings is making an already stressful time feel more uncertain. AEP opens October 15 and closes December 7, with a set of risk adjustment deadlines landing in between. Medicare Advantage plans have a five-month window where a handful of decisions, made against those deadlines, determine next year’s Star Ratings, medical loss ratio, and enrollment numbers.
There’s a lot happening in the macro environment that makes this window matter more than usual. Humana has added a leading AI executive to its board, and Centene and UnitedHealth Group both spoke at length about AI during Q2 earnings calls. UnitedHealth’s MA plans lost roughly 647,000 enrollees from 2025 to 2026, while Humana gained 1.3 million. And MedPAC’s June 2026 report to Congress found that Medicare Advantage has lowered healthcare spending while, somewhat paradoxically, increasing costs to the public-private program overall, pointing to overcoding and favorable selection as drivers.
Against that backdrop, here’s what’s actually in a plan’s control over the next five months.
Key Takeaways
- The Star Ratings Preview period is open, and litigation is adding to the uncertainty around how CMS calculates the ratings. (See our take on the litigation itself →)
- AEP runs October 15 through December 7, 2026.
- The final Payment Year 2026 risk adjustment run lands around the end of January 2027; the Payment Year 2027 mid-year run follows in March.
- Starting CY2027, unlinked chart reviews will no longer count toward risk-adjusted revenue.
Care: Quality Is Also a Revenue Decision, Not Just a Clinical One
Close care gaps as members are seen, not through a chart chase months later. Get ahead of avoidable readmissions with real coordination between care managers, providers, and community partners. Make sure every member lands in the right setting, not the emergency department, not a delayed referral, before a preventable problem becomes an expensive claim.
Good care delivered on time is also the input to next year’s HEDIS, CAHPS, and HOS scores, which means the Star Ratings bonus payment finance teams are modeling for 2028 is being earned or lost right now, five months before anyone reviews a Preview report.
Capture: The Risk Adjustment Deadlines That Determine Your Revenue
Every undocumented diagnosis is revenue you never collect, and this cycle’s risk adjustment deadlines decide how much of it actually gets kept. Beyond capturing conditions for care delivered the rest of this year, this is also the window for retrospective chart reviews to capture conditions from 2025 care that weren’t submitted appropriately to CMS.
Two risk adjustment deadlines matter for the rest of this cycle. The final Payment Year 2026 risk adjustment run lands around the end of January. The Payment Year 2027 mid-year run follows in March. Every dollar of accurate, well-documented revenue captured before those dates is money kept without a fight. Every legitimate diagnosis a team misses is revenue simply never collected. And starting CY2027, unlinked chart reviews will no longer count toward risk-adjusted revenue at all.
Only a handful of health plans are meaningfully ahead of their retro campaigns and CMS risk adjustment sweep submissions right now. A “delete” recommendation deserves the same seriousness as a “new code” one.
Growth: AEP Is a Growth Lever, Not Just a Compliance Date
AEP opens October 15 and closes December 7, and it’s the best growth opportunity of the year. Member experience during enrollment is itself a retention lever. People remember how they were treated when they signed up, and that memory shows up in next year’s CAHPS scores and in whether they stay. Growth this cycle means keeping the members a plan already has, for the right reasons, alongside adding new ones.
Flow: How You Lead Through It
None of the above happens by checklist. It happens through people, and how leaders manage them through these five months is its own performance decision, not a softer conversation set apart from the one about revenue.
Give each team one priority at a time. A team asked to close gaps, support AEP, and prep for a RADV audit simultaneously will do all three worse than if the work were sequenced. Protect real, uninterrupted blocks of time for the complex work, budgeting, coding, documentation, gap closure, that falls apart under constant interruption.
Check the pace in September and November, not just the outcome in December, so adjustments happen before the crunch instead of after. Build recovery time into the calendar on purpose, right after AEP and right after the January close, instead of leaving it to chance. A depleted team is where errors, missed gaps, and quiet resignations come from, and all three cost more than the time it would have taken to prevent them.
Get the Sequence Right
Get Care, Capture, Growth, and Flow right, in sequence, and next year’s Star Ratings, medical loss ratio, and enrollment numbers can all move in the right direction. Get them wrong, and plans are back here in twelve months disputing a rating instead of building on one.
Frequently Asked Questions
When does AEP open in 2026?
AEP, the Medicare Annual Enrollment Period, opens October 15, 2026 and closes December 7, 2026.
What is the Care, Capture, Growth, Flow framework?
It’s a five-month framework for Medicare Advantage plan leaders from ATTAC Consulting Group’s Subbu Ramalingam. It focuses on closing quality care gaps (Care), capturing risk adjustment revenue (Capture), using AEP as a growth and retention lever (Growth), and leading teams effectively through the year-end crunch (Flow).
When are the Payment Year 2026 and Payment Year 2027 risk adjustment deadlines?
The final Payment Year 2026 risk adjustment run lands around the end of January 2027. The Payment Year 2027 mid-year run follows in March 2027.
Will unlinked chart reviews count toward risk-adjusted revenue in CY2027?
No. Starting in CY2027, unlinked chart reviews will no longer count toward risk-adjusted revenue for Medicare Advantage plans.
Why does member experience during AEP matter for Star Ratings?
Member experience during enrollment functions as a retention lever. How members are treated when they sign up shows up in next year’s CAHPS scores and affects whether they stay enrolled.
What is the Star Ratings Preview period?
The Star Ratings Preview period is the window when CMS gives Medicare Advantage plans an early look at draft Star Ratings data before the public release, so plans can validate their data and flag potential disputes.
How ATTAC Can Help
ATTAC’s Risk Adjustment Advisory and STAR Rating Advisory practices help Medicare Advantage plans act on exactly this framework, closing quality gaps, validating risk adjustment revenue before the January and March deadlines, and building RADV audit readiness into the process rather than bolting it on afterward. Our practice has recovered $1.25M in submission gap revenue in 45 days for one Medicare Advantage client through an end-to-end data trace, and our retrospective chart coding work has surfaced 8 to 10% more HCCs on average versus prior coding efforts.
Subbu Ramalingam is ATTAC Consulting Group’s Managing Director, Risk Adjustment, Stars & Quality. A former health plan executive with more than 20 years of experience, including 9 years inside health plans, he has led ACA, Medicare Advantage, and Medicaid risk adjustment and Stars and quality programs end to end.
