MA risk scores run higher than traditional Medicare for comparable people. This lesson reports what the current estimates actually say.
Coding intensity is the tendency for the same person to generate a higher risk score in Medicare Advantage than in traditional Medicare. It is not a claim that MA enrollees are sicker. It is a claim that their conditions are recorded more completely, and because payment follows recorded diagnoses, more complete recording means more money.
Why it happens
MA plans have both the incentive and the infrastructure to capture diagnoses thoroughly. The toolkit from the intro course applies here: annual wellness visits structured to re-document every chronic condition, chart review programs, in-home assessments, and prompts built into the clinical workflow. Traditional Medicare, where payment does not depend on the risk score, has no comparable machinery.
What the current estimates show
The numbers move as new data arrives, and reporting them honestly means reporting the revisions too.
In its March 2026 report, MedPAC lowered its estimate of 2025 coding intensity from 16.4 percent to 12.5 percent, after incorporating 2024 data, the first year of the v28 phase-in. Even after that downward revision, MedPAC estimates coding intensity remains about 10.3 percent higher in MA than in traditional Medicare.
The dollars attached are substantial. MedPAC estimates Medicare pays MA plans about 14 percent more per person than comparable beneficiaries in traditional Medicare in 2026, roughly $76 billion in additional spending, and that higher risk scores account for about $22 billion of that total.
| Component | Estimate for 2026 |
|---|---|
| MA payments above traditional Medicare | About 14 percent, roughly $76 billion |
| Attributable to higher risk scores | About $22 billion |
| Remaining coding intensity gap versus FFS | About 10.3 percent |
Worth remembering: the downward revision matters as much as the headline. The v28 model did compress scores, and a careful analyst reports that the problem shrank rather than implying it did not. It also has not gone away: a 10.3 percent gap on a program this size is still many billions of dollars. Both halves are true, and reporting only one is advocacy rather than analysis.
Why it is hard to fix
CMS applies a uniform across-the-board coding intensity adjustment, a haircut to all MA risk scores. But a uniform adjustment penalizes plans that code accurately along with those that code aggressively, and it does not distinguish between them. Model revisions like v28 help, but as the intro course put it, any model that pays on self-reported inputs will bend those inputs. The arms race is structural, not a one-time fix.
Key takeaways
- Coding intensity is a gap in recorded diagnoses, not in actual illness, and it raises MA payment.
- MedPAC revised its 2025 estimate down from 16.4 to 12.5 percent with new data, and still finds MA coding about 10.3 percent higher than fee-for-service.
- MA is paid about 14 percent more per person in 2026, roughly $76 billion, with about $22 billion attributable to higher risk scores.
Sources
Check your understanding
What does 'coding intensity' mean in Medicare Advantage?
Coding intensity is the gap in recorded diagnoses, not in actual illness. The same person generates a higher risk score in MA than in fee-for-service, and payment follows the score.