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No UPCODE Act: How to Protect Your Organization with Smarter Risk Adjustment

The No Unreasonable Payments, Coding, or Diagnoses for the Elderly (No UPCODE) Act is the latest—and loudest—wake-up call for Medicare Advantage (MA) plans and risk-bearing provider groups. With bipartisan support, this legislation signals that inflated coding practices and weak documentation won’t just draw attention, they’ll draw penalties. Is your organization prepared to adapt to the new coding regulations?

July 1, 2025 1 min read

The No Unreasonable Payments, Coding, or Diagnoses for the Elderly (No UPCODE) Act is the latest—and loudest—wake-up call for Medicare Advantage (MA) plans and risk-bearing provider groups. With bipartisan support, this legislation signals that inflated coding practices and weak documentation won’t just draw attention, they’ll draw penalties. Is your organization prepared to adapt to the new coding regulations?

For health plans and provider groups, this is more than just proposed legislation—it’s a signal that the compliance bar is rising fast. Are your coding processes ready?

 

The Regulatory Net is Tightening

The No UPCODE Act, paired with RADV audit extrapolation and a surge in CMS enforcement activity, means even small coding errors can have outsized financial consequences. A diagnosis that lacks clear encounter-based documentation could jeopardize millions in payments when findings are extrapolated across a plan's population. It’s no longer enough to hope retrospective reviews or one-off audits will catch issues.

Today’s environment demands proactive, systemic solutions that prevent problems before they start.

 

 

Is your organization prepared to adapt to the new coding regulations?

 

What Aptarro’s Playbook Delivers

The Risk Adjustment Playbook lays out a practical framework for organizations that want to stay ahead of this rising tide. It’s not just about coding faster—it’s about coding smarter, with built-in compliance checks that protect both revenue and reputation. Inside, you’ll learn how to:

  • Surface documentation gaps in real time, so coders can act before audits uncover issues.
  • Prioritize high-risk encounters, ensuring coding teams focus where their effort delivers the greatest impact.
  • Align compliance and revenue goals, eliminating the trade-offs that often leave one vulnerable.
  • Strengthen audit readiness, with tools and workflows that give you visibility into risk areas long before regulators come calling.
  • Improve team efficiency without adding headcount, helping you do more with what you have.

 

Why This Matters Now

Aptarro’s clients have already proven this approach works. One provider group uncovered $6 million in validated revenue in just a year. Another boosted coder productivity by 300% while strengthening audit defense. These results aren’t hypothetical—they’re what happens when teams stop chasing codes and start controlling risk.

 

👉 Download The Risk Adjustment Playbook to get started on a stronger, smarter compliance path today.

 

Download the report

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